In this Section 5, We have done our best to summarize the rights that you may have under applicable data protection law. These are complex, and not all of the details have been included herein. In light of this, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. Your principal rights under Data Protection Regulation are all or some of the following: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent. You have the right to confirmation as to whether or not We process your PII and, where We do, access to the PII, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of PII concerned and the recipients of the PII. Providing the rights and freedoms of others are not affected, and as requested or approved by you, We will supply to you a copy of your PII. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request to access your PII by requesting an e-mail summary from: [email protected]. You have the right to have any inaccurate PII about you rectified and, taking into account the purposes of the processing, to have any incomplete PII about you completed. In some circumstances you have the right to the erasure of your PII, by providing adequate evidence attesting to your identity, without undue delay. Those circumstances include: the PII is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; and the PII have been unlawfully processed. There are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims. In some circumstances you might have the right to restrict the processing of your PII. Those circumstances are (to the extent applicable under applicable Data Protection Regulation): you contest the accuracy of the PII; processing is unlawful but you oppose erasure; We no longer need the PII for the purposes of our processing, but you require PII for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, We may continue to store your PII. However, We will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. You might have the right to object to our processing of your PII on grounds relating to your particular situation (to the extent applicable under applicable Data Protection Regulation). If you make such an objection, We will cease to process the PII unless We can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. To the extent that the legal basis for our processing of your PII is consent, and such processing is carried out by automated means, you have the right to receive your PII from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. If you consider that our processing of your PII infringes Data Protection Regulation, you have a legal right to file a complaint with a supervisory authority responsible for data protection. To the extent that the legal basis for our processing of your PII is consent you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. You may exercise any of your rights in relation to your PII by written notice to us in addition to the other methods specified in this Section 5.
When you provide us with PII for a secondary reason, like marketing or other secondary reasons which We will convey to you from time to time if applicable, We will ask for your consent. After you opt-in, you may withdraw your consent at any time, by contacting us at [email protected] .
We follow generally accepted industry standards to protect against unauthorized access to or unauthorized use, alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while We strive to use commercially acceptable means to protect PII, We cannot guarantee its absolute security. The PII is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required by contract to keep the information confidential. We implement a variety of security measures to maintain the safety of the PII.
California residents have specific rights under the California Consumer Privacy Act (“CCPA”). For more information and to exercise your rights, please see the Privacy Notice for California Residents below.
When it comes to the collection of PII from children under the age of 13 years old, the Childrens Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect childrens privacy and safety online. We do not market to children under the age of 13 years old, and 13 year old are prohibited from using this Website without proper consents from guardians.
In order to be in line with Fair Information Practices We will take the following responsive action, should a data breach occur: We will notify you within the time required by applicable law, but no later than three business days from becoming aware of any such breach. We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only those individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to: Send information, respond to inquiries, and/or other requests or questions Send you additional information related to the Services. Market to our mailing list or continue to send emails to our clients after the original engagement has occurred. To be in accordance with CANSPAM, We agree to the following: Not use false or misleading subjects or email addresses. Identify the message as an advertisement in some reasonable way. Include the physical address of our business or site headquarters. Monitor third-party email marketing services for compliance, if one is used. Honor opt-out/unsubscribe requests quickly. Allow users to unsubscribe by using the link at the bottom of each email.
By using our Website, you represent that you are at least the age of majority in your state, province or country of residence (“Age of Majority”), or that you are the age of majority in your state, province or country of residence and you have given us your consent to allow any of your minor dependents to use this site. We do not knowingly collect, solicit or maintain PII from anyone under the Age of Majority or knowingly allow such persons to register for our Services. If you are under the Age of Majority, please do not send any PII about yourself (such as your name, address, telephone number, or email address) to us. No one under the Age of Majority should provide any PII to or on the Services. In the event that we learn that we have collected PII from a child under the Age of Majority without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months: Category Examples Collected A. Identifiers A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, drivers license number, passport number, or other similar identifiers YES B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, drivers license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES C. Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES E. Biometric information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO F. Internet or other similar network activity Browsing history, search history, information on a consumers interaction with a website, application, or advertisement. YES G. Geolocation data Physical location or movements. YES H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO I. Professional or employment-related information Current or past job history or performance evaluations. NO J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO K. Inferences drawn from other personal information. Profile reflecting a persons preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES L. Sensitive Personal Information under the CPRA Social security, drivers license, state identification card or passport number. account log-in, financial account, debit card or credit number combined with any required security or access code, password or credentials allowing access to an account. racial or ethnic origin, religious or philosophical beliefs or union membership. The contents of a consumer’s physical mail, email and text messages, unless the business is the intended recipient of the communication. Precise geolocation. Genetic data. Biometric information processed for the purpose of uniquely identifying a consumer. Personal information collected and analyzed concerning a consumer’s health. Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. YES We obtain the categories of personal information listed above from the following categories of sources: Directly from our clients or their agents. For example, from information our clients provide to us related to the Services for which they engage us. Directly from you. For example, through information we ask from you when you subscribe and engage our Services. Directly and indirectly from you when using our Services. For example, usage details collected automatically in the course of your interaction with our platform.
We may use or disclose the personal information we collect, sell or share, for one or more of the following business purposes: To fulfil or meet the reason for which the information is provided. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns. To provide you with email alerts and other notices concerning our Services. To improve our Services to you. To provide, support, personalize, and develop our products, and services. To create, maintain, customize, and secure your account with us. To help maintain the safety, security, and integrity of our products and services, databases and other technology assets, and business. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. For testing, research, analysis and product development. As necessary or appropriate to protect the rights, property or safety of us, our clients or others. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. As described to you when collecting your personal information or as otherwise set forth in the CCPA. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following categories of third parties: Please note, the CPRA amends the definition of “Third Party”, to be read as follows (amendments to the CCPA are provided in italic : “Third party” means a person who is not any of the following: (1) The business with whom the consumer intentionally interacts and that collects personal information from the consumer as part of the consumer’s current interaction with the business under this title. (2) A service provider to the business; or (3) A contractor. Subsidiaries and affiliates Our clients or their agents for which you have engaged in a business contract. Service providers and contractors. Third parties to whom you or your agents authorize us to disclose your personal information in connection with our Services. Data aggregators If you share PI with a third party for cross-contextual behavioral advertising, it must be mentioned. Cross-context behavioral advertising” means the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s activity across businesses, distinctly- branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Identifiers Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Commercial information Internet or other similar network activity In the preceding twelve (12) months, we have not sold any personal information. While we do not sell personal information in exchange for any monetary or other valuable consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). This includes sharing personal information with advertising networks, website analytics companies, and event sponsors.
The CCPA and CPRA provide consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA and CPRA rights and explains how to exercise those rights. Access to Specific Information and Data Portability Rights You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the following, if applicable: The categories of personal information we collected about you. The categories of sources for the personal information we collected about you. Our business or commercial purpose for collecting that personal information. The categories of third parties with whom we share that personal information. The specific pieces of personal information we collected about you (also called a data portability request). If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. Correction of Inaccurate Personal Information Rights You have the right to request that we correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct your personal information as directed by you (and direct our service providers to correct it as well). Deletion Request Rights You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to: Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. Debug products to identify and repair errors that impair existing intended functionality. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. Comply with a legal obligation. Make other internal and lawful uses of that information that are compatible with the context in which you provided it. Exercising Access, Data Portability, Correction and Deletion Rights To exercise the access, data portability, correction of inaccurate personal information and deletion rights described above, please submit a verifiable consumer request to us by either: (a) sending an e-mail to us at [email protected]; or (b) sending a letter to us at 1000 N. West Street, Suite 1410 Wilmington, DE 19801 or (c) calling us at +1 302-300-1042. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”). We do not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is between 13 and 16 years of age. Consumers who opt-in to personal information sales may opt-out of future sales or shares at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following link our webpage or sending us a message: [email protected]. Under the CPRA the link should be titled: “Do not Sell or Share My Personal Information”. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.
Yoh have the right to direct us to limit our use of your sensitive personal information (except for sensitive personal information that is collected or processed without the purpose of inferring characteristics about you; which shall be treated as personal information) to the necessary required to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services. To exercise the right to limit the use of sensitive PI, you (or your authorized representative) may submit a request to us by visiting the following link our webpage or sending us a message: [email protected]. Link should be titled: “Limit the Use of My Sensitive Personal Information Once we receive a direction from you not to use or disclose your sensitive personal information, we will wait at least twelve (12) months before asking you to reauthorize use or disclosure of your sensitive personal information. However, you may change your mind and opt back in at any time by visiting our website and sending us a message.
We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA, we will not do any of the following in connection with the exercise of your CCPA or CPRA rights: Deny you use of our Services. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We are required to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. We adhere to the standards set out in this Privacy Notice and do not monitor or respond to Do Not Track browser requests.
We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the bottom of this page. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.