This Privacy Policy describes Our policies
and procedures on the collection, use and disclosure of Your information when
You use the Service and tells You about Your privacy rights and how the law
protects You.
We use Your Personal data to provide and
improve the Service. By using the Service, You agree to the collection and use
of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
The words of which the initial letter is
capitalized have meanings defined under the following conditions. The following
definitions shall have the same meaning regardless of whether they appear in
singular or in plural.
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created
for You to access our Service or parts of our Service.
Business, for the purpose of the CCPA
(California Consumer Privacy Act), refers to the Company as the legal entity
that collects Consumers' personal information and determines the purposes and
means of the processing of Consumers' personal information, or on behalf of
which such information is collected and that alone, or jointly with others,
determines the purposes and means of the processing of consumers' personal
information, that does business in the State of California.
Company (referred to as either "the
Company", "We", "Us" or "Our" in this
Agreement) refers to Seawin Global, LLC., 200 Centennial Ave Suite 201
Piscataway, NJ 08854.
For the purpose of the
GDPR, the Company is the Data Controller.
Consumer, for the purpose of the CCPA
(California Consumer Privacy Act), means a natural person who is a California
resident. A resident, as defined in the law, includes (1) every individual who
is in the USA for other than a temporary or transitory purpose, and (2) every
individual who is domiciled in the USA who is outside the USA for a temporary
or transitory purpose.
Cookies are small files that are placed
on Your computer, mobile device or any other device by a website, containing the
details of Your browsing history on that website among its many uses.
Country refers to: New Jersey, United
States
Data Controller, for the purposes of the
GDPR (General Data Protection Regulation), refers to the Company as the legal
person which alone or jointly with others determines the purposes and means of
the processing of Personal Data.
Device means any device that can access
the Service such as a computer, a cellphone or a digital tablet.
Do Not Track (DNT) is a concept that has
been promoted by US regulatory authorities, in particular the U.S. Federal
Trade Commission (FTC), for the Internet industry to develop and implement a
mechanism for allowing internet users to control the tracking of their online
activities across websites.
Facebook Fan Page is a public profile
named Seawin Global specifically created by the Company on the Facebook social
network, accessible from https://www.facebook.com/SeawinGlobal
Personal Data is any information that
relates to an identified or identifiable individual.
For the purposes for GDPR,
Personal Data means any information relating to You such as a name, an
identification number, location data, online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity.
For the purposes of the
CCPA, Personal Data means any information that identifies, relates to,
describes or is capable of being associated with, or could reasonably be
linked, directly or indirectly, with You.
Sale, for the purpose of the CCPA
(California Consumer Privacy Act), means selling, renting, releasing,
disclosing, disseminating, making available, transferring, or otherwise
communicating orally, in writing, or by electronic or other means, a Consumer's
personal information to another business or a third party for monetary or other
valuable consideration.
Service refers to the Website.
Service Provider means any natural or
legal person who processes the data on behalf of the Company. It refers to
third-party companies or individuals employed by the Company to facilitate the
Service, to provide the Service on behalf of the Company, to perform services
related to the Service or to assist the Company in analyzing how the Service is
used. For the purpose of the GDPR, Service Providers are considered Data
Processors.
Third-party Social Media Service refers
to any website or any social network website through which a User can log in or
create an account to use the Service.
Usage Data refers to data collected
automatically, either generated by the use of the Service or from the Service
infrastructure itself (for example, the duration of a page visit).
Website refers to Seawin Global,
accessible from www.seawinglobal.com
You means the individual accessing or
using the Service, or the company, or other legal entity on behalf of which
such individual is accessing or using the Service, as applicable.
Under GDPR (General Data
Protection Regulation), You can be referred to as the Data Subject or as the
User as you are the individual using the Service.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide
Us with certain personally identifiable information that can be used to contact
or identify You. Personally identifiable information may include, but is not
limited to:
Email address
First name and last name
Phone number
Address, State, Province,
ZIP/Postal code, City
Usage Data
Usage Data
Usage Data is collected automatically when
using the Service.
Usage Data may include information such as
Your Device's Internet Protocol address (e.g. IP address), browser type,
browser version, the pages of our Service that You visit, the time and date of
Your visit, the time spent on those pages, unique device identifiers and other
diagnostic data.
When You access the Service by or through a
mobile device, We may collect certain information automatically, including, but
not limited to, the type of mobile device You use, Your mobile device unique
ID, the IP address of Your mobile device, Your mobile operating system, the
type of mobile Internet browser You use, unique device identifiers and other
diagnostic data.
We may also collect information that Your
browser sends whenever You visit our Service or when You access the Service by
or through a mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking
technologies to track the activity on Our Service and store certain
information. Tracking technologies used are beacons, tags, and scripts to
collect and track information and to improve and analyze Our Service. The
technologies We use may include:
·
Cookies or Browser Cookies. A cookie is
a small file placed on Your Device. You can instruct Your browser to refuse all
Cookies or to indicate when a Cookie is being sent. However, if You do not
accept Cookies, You may not be able to use some parts of our Service. Unless
you have adjusted Your browser setting so that it will refuse Cookies, our
Service may use Cookies.
·
Flash Cookies. Certain features of our
Service may use local stored objects (or Flash Cookies) to collect and store
information about Your preferences or Your activity on our Service. Flash
Cookies are not managed by the same browser settings as those used for Browser
Cookies. For more information on how You can delete Flash Cookies, please read
"Where can I change the settings for disabling, or deleting local shared
objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
·
Web Beacons. Certain sections of our
Service and our emails may contain small electronic files known as web beacons
(also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit
the Company, for example, to count users who have visited those pages or opened
an email and for other related website statistics (for example, recording the
popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or
"Session" Cookies. Persistent Cookies remain on Your personal
computer or mobile device when You go offline, while Session Cookies are
deleted as soon as You close Your web browser. Learn more about cookies: What Are Cookies?.
We use both Session and Persistent Cookies
for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are
essential to provide You with services available through the Website and to
enable You to use some of its features. They help to authenticate users and
prevent fraudulent use of user accounts. Without these Cookies, the services
that You have asked for cannot be provided, and We only use these Cookies to
provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies
identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies
allow us to remember choices You make when You use the Website, such as
remembering your login details or language preference. The purpose of these
Cookies is to provide You with a more personal experience and to avoid You
having to re-enter your preferences every time You use the Website.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by:
Third-Parties
Purpose: These Cookies are
used to track information about traffic to the Website and how users use the
Website. The information gathered via these Cookies may directly or indirectly
identify you as an individual visitor. This is because the information
collected is typically linked to a pseudonymous identifier associated with the
device you use to access the Website. We may also use these Cookies to test new
pages, features or new functionality of the Website to see how our users react
to them.
For more information about the cookies we
use and your choices regarding cookies, please visit our Cookies Policy or the
Cookies section of our Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the
following purposes:
·
To provide and maintain our Service,
including to monitor the usage of our Service.
·
To manage Your Account: to manage Your
registration as a user of the Service. The Personal Data You provide can give
You access to different functionalities of the Service that are available to
You as a registered user.
·
For the performance of a contract: the
development, compliance and undertaking of the purchase contract for the
products, items or services You have purchased or of any other contract with Us
through the Service.
·
To contact You: To contact You by email,
telephone calls, SMS, or other equivalent forms of electronic communication,
such as a mobile application's push notifications regarding updates or
informative communications related to the functionalities, products or
contracted services, including the security updates, when necessary or
reasonable for their implementation.
·
To provide You with news, special offers
and general information about other goods, services and events which we offer
that are similar to those that you have already purchased or enquired about
unless You have opted not to receive such information.
·
To manage Your requests: To attend and
manage Your requests to Us.
·
To deliver targeted advertising to You:
We may use Your information to develop and display content and advertising (and
work with third-party vendors who do so) tailored to Your interests and/or
location and to measure its effectiveness.
·
For business transfers: We may use Your
information 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 Data held by Us about our Service users is among the assets
transferred.
·
For other purposes: We may use Your
information for other purposes, such as data analysis, identifying usage
trends, determining the effectiveness of our promotional campaigns and to
evaluate and improve our Service, products, services, marketing and your
experience.
We may share Your personal information in
the following situations:
·
With Service Providers: We may share
Your personal information with Service Providers to monitor and analyze the use
of our Service, to advertise on third party websites to You after You visited
our Service, to contact You.
·
For business transfers: We may share or
transfer Your personal information in connection with, or during negotiations
of, any merger, sale of Company assets, financing, or acquisition of all or a
portion of Our business to another company.
·
With Affiliates: We may share Your
information with Our affiliates, in which case we will require those affiliates
to honor this Privacy Policy. Affiliates include Our parent company and any
other subsidiaries, joint venture partners or other companies that We control
or that are under common control with Us.
·
With business partners: We may share
Your information with Our business partners to offer You certain products,
services or promotions.
·
With other users: when You share
personal information or otherwise interact in the public areas with other
users, such information may be viewed by all users and may be publicly
distributed outside. If You interact with other users or register through a
Third-Party Social Media Service, Your contacts on the Third-Party Social Media
Service may see Your name, profile, pictures and description of Your activity.
Similarly, other users will be able to view descriptions of Your activity,
communicate with You and view Your profile.
·
With Your consent: We may disclose Your
personal information for any other purpose with Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data
only for as long as is necessary for the purposes set out in this Privacy Policy.
We will retain and use Your Personal Data to the extent necessary to comply
with our legal obligations (for example, if we are required to retain your data
to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
The Company will also retain Usage Data for
internal analysis purposes. Usage Data is generally retained for a shorter
period of time, except when this data is used to strengthen the security or to
improve the functionality of Our Service, or We are legally obligated to retain
this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data,
is processed at the Company's operating offices and in any other places where
the parties involved in the processing are located. It means that this
information may be transferred to — and maintained on — computers located
outside of Your state, province, country or other governmental jurisdiction
where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy
followed by Your submission of such information represents Your agreement to
that transfer.
The Company will take all steps reasonably
necessary to ensure that Your data is treated securely and in accordance with
this Privacy Policy and no transfer of Your Personal Data will take place to an
organization or a country unless there are adequate controls in place including
the security of Your data and other personal information.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger,
acquisition or asset sale, Your Personal Data may be transferred. We will
provide notice before Your Personal Data is transferred and becomes subject to
a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company
may be required to disclose Your Personal Data if required to do so by law or
in response to valid requests by public authorities (e.g. a court or a
government agency).
Other legal requirements
The Company may disclose Your Personal Data
in the good faith belief that such action is necessary to:
·
Comply with a legal obligation
·
Protect and defend the rights
or property of the Company
·
Prevent or investigate possible
wrongdoing in connection with the Service
·
Protect the personal safety of
Users of the Service or the public
·
Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is
important to Us, but remember that no method of transmission over the Internet,
or method of electronic storage is 100% secure. While We strive to use
commercially acceptable means to protect Your Personal Data, We cannot
guarantee its absolute security.
Detailed Information on the Processing of
Your Personal Data
The Service Providers We use may have
access to Your Personal Data. These third-party vendors collect, store, use,
process and transfer information about Your activity on Our Service in
accordance with their Privacy Policies.
Analytics
We may use third-party Service providers to
monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web
analytics service offered by Google that tracks and reports website traffic.
Google uses the data collected to track and monitor the use of our Service.
This data is shared with other Google services. Google may use the collected
data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having
made your activity on the Service available to Google Analytics by installing
the Google Analytics opt-out browser add-on. The add-on prevents the Google
Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information
with Google Analytics about visits activity.
For more information on the
privacy practices of Google, please visit the Google Privacy & Terms web
page: https://policies.google.com/privacy
Email Marketing
We may use Your Personal Data to contact
You with newsletters, marketing or promotional materials and other information
that may be of interest to You. You may opt-out of receiving any, or all, of
these communications from Us by following the unsubscribe link or instructions
provided in any email We send or by contacting Us.
We may use Email Marketing Service
Providers to manage and send emails to You.
Behavioral Remarketing
The Company uses remarketing services to
advertise to You after You accessed or visited our Service. We and Our
third-party vendors use cookies and non-cookie technologies to help Us
recognize Your Device and understand how You use our Service so that We can
improve our Service to reflect Your interests and serve You advertisements that
are likely to be of more interest to You.
These third-party vendors collect, store,
use, process and transfer information about Your activity on Our Service in
accordance with their Privacy Policies and to enable Us to:
·
Measure and analyze traffic and
browsing activity on Our Service
·
Show advertisements for our
products and/or services to You on third-party websites or apps
·
Measure and analyze the
performance of Our advertising campaigns
Some of these third-party vendors may use
non-cookie technologies that may not be impacted by browser settings that block
cookies. Your browser may not permit You to block such technologies. You can
use the following third-party tools to decline the collection and use of
information for the purpose of serving You interest-based advertising:
·
The NAI's opt-out platform: http://www.networkadvertising.org/choices/
·
The EDAA's opt-out platform http://www.youronlinechoices.com/
·
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
You may opt-out of all personalized
advertising by enabling privacy features on Your mobile device such as Limit Ad
Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile
device Help system for more information.
We may share information, such as hashed
email addresses (if available) or other online identifiers collected on Our
Service with these third-party vendors. This allows Our third-party vendors to
recognize and deliver You ads across devices and browsers. To read more about the
technologies used by these third-party vendors and their cross-device
capabilities please refer to the Privacy Policy of each vendor listed below.
The third-party vendors We use are:
Google Ads (AdWords)
Google Ads (AdWords)
remarketing service is provided by Google Inc.
You can opt-out of Google
Analytics for Display Advertising and customise the Google Display Network ads
by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends
installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout
- for your web browser. Google Analytics Opt-out Browser Add-on provides visitors
with the ability to prevent their data from being collected and used by Google
Analytics.
For more information on
the privacy practices of Google, please visit the Google Privacy & Terms
web page: https://policies.google.com/privacy
Facebook
Facebook remarketing
service is provided by Facebook Inc.
You can learn more about
interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266
To opt-out from Facebook's
interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the
Self-Regulatory Principles for Online Behavioural Advertising established by
the Digital Advertising Alliance. You can also opt-out from Facebook and other
participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/,
the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European
Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/,
or opt-out using your mobile device settings.
For more information on
the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
Pinterest
Pinterest remarketing
service is provided by Pinterest Inc.
You can opt-out from
Pinterest's interest-based ads by enabling the "Do Not Track"
functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data
You can learn more about
the privacy practices and policies of Pinterest by visiting their Privacy
Policy page: https://about.pinterest.com/en/privacy-policy
LinkedIn
Their Privacy Policy can be
viewed at https://www.linkedin.com/legal/privacy-policy
Usage, Performance and Miscellaneous
We may use third-party Service Providers to
provide better improvement of our Service.
Invisible reCAPTCHA
We use an invisible captcha
service named reCAPTCHA. reCAPTCHA is operated by Google.
The reCAPTCHA service may
collect information from You and from Your Device for security purposes.
The information gathered by
reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the
following conditions:
·
Consent: You have given Your consent for
processing Personal Data for one or more specific purposes.
·
Performance of a contract: Provision of
Personal Data is necessary for the performance of an agreement with You and/or
for any pre-contractual obligations thereof.
·
Legal obligations: Processing Personal
Data is necessary for compliance with a legal obligation to which the Company
is subject.
·
Vital interests: Processing Personal
Data is necessary in order to protect Your vital interests or of another
natural person.
·
Public interests: Processing Personal
Data is related to a task that is carried out in the public interest or in the
exercise of official authority vested in the Company.
·
Legitimate interests: Processing
Personal Data is necessary for the purposes of the legitimate interests pursued
by the Company.
In any case, the Company will gladly help
to clarify the specific legal basis that applies to the processing, and in
particular whether the provision of Personal Data is a statutory or contractual
requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the
confidentiality of Your Personal Data and to guarantee You can exercise Your
rights.
You have the right under this Privacy
Policy, and by law if You are within the EU, to:
·
Request access to Your Personal Data.
The right to access, update or delete the information We have on You. Whenever
made possible, you can access, update or request deletion of Your Personal Data
directly within Your account settings section. If you are unable to perform
these actions yourself, please contact Us to assist You. This also enables You
to receive a copy of the Personal Data We hold about You.
·
Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate
information We hold about You corrected.
·
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as
the legal basis for Our processing and there is something about Your particular
situation, which makes You want to object to our processing of Your Personal
Data on this ground. You also have the right to object where We are processing
Your Personal Data for direct marketing purposes.
·
Request erasure of Your Personal Data.
You have the right to ask Us to delete or remove Personal Data when there is no
good reason for Us to continue processing it.
·
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your
Personal Data in a structured, commonly used, machine-readable format. Please
note that this right only applies to automated information which You initially
provided consent for Us to use or where We used the information to perform a
contract with You.
·
Withdraw Your consent. You have the
right to withdraw Your consent on using your Personal Data. If You withdraw
Your consent, We may not be able to provide You with access to certain specific
functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access,
rectification, cancellation and opposition by contacting Us. Please note that
we may ask You to verify Your identity before responding to such requests. If
You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data
Protection Authority about Our collection and use of Your Personal Data. For
more information, if You are in the European Economic Area (EEA), please
contact Your local data protection authority in the EEA.
Facebook Fan Page
Data Controller for the Facebook Fan Page
The Company is the Data Controller of Your
Personal Data collected while using the Service. As operator of the Facebook
Fan Page https://www.facebook.com/SeawinGlobal,
the Company and the operator of the social network Facebook are Joint
Controllers.
The Company has entered into agreements
with Facebook that define the terms for use of the Facebook Fan Page, among
other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php
Visit the Facebook Privacy Policy https://www.facebook.com/policy.php
for more information about how Facebook manages Personal data or contact
Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601
Willow Road, Menlo Park, CA 94025, United States.
Facebook Insights
We use the Facebook Insights function in
connection with the operation of the Facebook Fan Page and on the basis of the
GDPR, in order to obtain anonymized statistical data about Our users.
For this purpose, Facebook places a Cookie
on the device of the user visiting Our Facebook Fan Page. Each Cookie contains
a unique identifier code and remains active for a period of two years, except
when it is deleted before the end of this period.
Facebook receives, records and processes
the information stored in the Cookie, especially when the user visits the
Facebook services, services that are provided by other members of the Facebook
Fan Page and services by other companies that use Facebook services.
For more information on the privacy
practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy
CCPA Privacy
This privacy notice section for California
residents supplements the information contained in Our Privacy Policy and it
applies solely to all visitors, users, and others who reside in the State of
California.
Categories of Personal Information Collected
We collect information that identifies,
relates to, describes, references, is capable of being associated with, or
could reasonably be linked, directly or indirectly, with a particular Consumer
or Device. The following is a list of categories of personal information which
we may collect or may have been collected from California residents within the
last twelve (12) months.
Please note that the categories and
examples provided in the list below are those defined in the CCPA. This does
not mean that all examples of that category of personal information were in
fact collected by Us, but reflects our good faith belief to the best of our
knowledge that some of that information from the applicable category may be and
may have been collected. For example, certain categories of personal
information would only be collected if You provided such personal information
directly to Us.
Category A: Identifiers.
Examples: A real name,
alias, postal address, unique personal identifier, online identifier, Internet
Protocol address, email address, account name, driver's license number,
passport number, or other similar identifiers.
Collected: Yes.
Category B: Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name,
signature, Social Security number, physical characteristics or description,
address, telephone number, passport number, driver's 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.
Collected: Yes.
Category C: Protected classification characteristics under
California or federal law.
Examples: 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).
Collected: No.
Category D: Commercial information.
Examples: Records and
history of products or services purchased or considered.
Collected: No.
Category E: Biometric information.
Examples: 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.
Collected: No.
Category F: Internet or other similar network activity.
Examples: Interaction with
our Service or advertisement.
Collected: Yes.
Category G: Geolocation data.
Examples: Approximate
physical location.
Collected: No.
Category H: Sensory data.
Examples: Audio,
electronic, visual, thermal, olfactory, or similar information.
Collected: No.
Category I: Professional or employment-related information.
Examples: Current or past
job history or performance evaluations.
Collected: No.
Category 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)).
Examples: 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.
Collected: No.
Category K: Inferences drawn from other personal information.
Examples: Profile
reflecting a person's preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Under CCPA, personal information does not
include:
·
Publicly available information
from government records
·
Deidentified or aggregated
consumer information
·
Information excluded from the
CCPA's scope, such as:
·
Health or medical information
covered by the Health Insurance Portability and Accountability Act of 1996
(HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or
clinical trial data
·
Personal Information covered by
certain sector-specific privacy laws, including the Fair Credit Reporting Act
(FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information
Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal
information listed above from the following categories of sources:
·
Directly from You. For example, from the
forms You complete on our Service, preferences You express or provide through
our Service.
·
Indirectly from You. For example, from
observing Your activity on our Service.
·
Automatically from You. For example,
through cookies We or our Service Providers set on Your Device as You navigate
through our Service.
·
From Service Providers. For example,
third-party vendors to monitor and analyze the use of our Service, third-party
vendors to deliver targeted advertising to You, or other third-party vendors
that We use to provide the Service to You.
Use of Personal Information for Business Purposes or
Commercial Purposes
We may use or disclose personal information
We collect for "business purposes" or "commercial purposes"
(as defined under the CCPA), which may include the following examples:
·
To operate our Service and
provide You with our Service.
·
To provide You with support and
to respond to Your inquiries, including to investigate and address Your
concerns and monitor and improve our Service.
·
To fulfill or meet the reason
You provided the information. For example, if You share Your contact
information to ask a question about our Service, We will use that personal
information to respond to Your inquiry.
·
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.
·
For internal administrative and
auditing purposes.
·
To detect security incidents
and protect against malicious, deceptive, fraudulent or illegal activity,
including, when necessary, to prosecute those responsible for such activities.
Please note that the examples provided
above are illustrative and not intended to be exhaustive. For more details on
how we use this information, please refer to the "Use of Your Personal
Data" section.
If We decide to collect additional
categories of personal information or use the personal information We collected
for materially different, unrelated, or incompatible purposes We will update
this Privacy Policy.
Disclosure of Personal Information for Business Purposes
or Commercial Purposes
We may use or disclose and may have used or
disclosed in the last twelve (12) months the following categories of personal
information for business or commercial purposes:
Category A: Identifiers
Category B: Personal
information categories listed in the California Customer Records statute (Cal.
Civ. Code § 1798.80(e))
Category F: Internet or
other similar network activity
Please note that the categories listed
above are those defined in the CCPA. This does not mean that all examples of
that category of personal information were in fact disclosed, but reflects our
good faith belief to the best of our knowledge that some of that information
from the applicable category may be and may have been disclosed.
When We disclose personal information for a
business purpose or a commercial 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.
Sale of Personal Information
As defined in the CCPA, "sell"
and "sale" mean selling, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise communicating
orally, in writing, or by electronic or other means, a consumer's personal
information by the business to a third party for valuable consideration. This
means that We may have received some kind of benefit in return for sharing
personal information, but not necessarily a monetary benefit.
Please note that the categories listed
below are those defined in the CCPA. This does not mean that all examples of
that category of personal information were in fact sold, but reflects our good
faith belief to the best of our knowledge that some of that information from
the applicable category may be and may have been shared for value in return.
We may sell and may have sold in the last
twelve (12) months the following categories of personal information:
Category A: Identifiers
Category B: Personal
information categories listed in the California Customer Records statute (Cal.
Civ. Code § 1798.80(e))
Category F: Internet or
other similar network activity
Share of Personal Information
We may share Your personal information
identified in the above categories with the following categories of third
parties:
Service Providers
Our affiliates
Our business partners
Third party vendors to whom
You or Your agents authorize Us to disclose Your personal information in
connection with products or services We provide to You
Sale of Personal Information of Minors Under 16 Years of
Age
We do not knowingly collect personal
information from minors under the age of 16 through our Service, although
certain third party websites that we link to may do so. These third-party
websites have their own terms of use and privacy policies and we encourage
parents and legal guardians to monitor their children's Internet usage and
instruct their children to never provide information on other websites without
their permission.
We do not sell 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 less than 13 years of age. Consumers who opt-in to the sale of
personal information may opt-out of future sales at any time. To exercise the
right to opt-out, You (or Your authorized representative) may submit a request
to Us by contacting Us.
If You have reason to believe that a child
under the age of 13 (or 16) has provided Us with personal information, please
contact Us with sufficient detail to enable Us to delete that information.
Your Rights under the CCPA
The CCPA provides California residents with
specific rights regarding their personal information. If You are a resident of
California, You have the following rights:
·
The right to notice. You have the right
to be notified which categories of Personal Data are being collected and the
purposes for which the Personal Data is being used.
·
The right to request. Under CCPA, You
have the right to request that We disclose information to You about Our
collection, use, sale, disclosure for business purposes and share of personal
information. Once We receive and confirm Your request, We will disclose to You:
·
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 or selling 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
·
If we sold Your personal
information or disclosed Your personal information for a business purpose, We
will disclose to You:
·
The categories of personal
information categories sold
·
The categories of personal
information categories disclosed
·
The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal
information. To submit an opt-out request please contact Us.
·
The right to delete Personal Data. You
have the right to request the deletion of Your Personal Data, subject to
certain exceptions. Once We receive and confirm Your 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, 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 et. 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.
·
The right not to be discriminated against. You have the right not to be discriminated against for exercising
any of Your consumer's rights, including by:
·
Denying goods or services to
You
·
Charging different prices or
rates for goods or services, including the use of discounts or other benefits
or imposing penalties
·
Providing a different level or
quality of goods or services to You
·
Suggesting that You will
receive a different price or rate for goods or services or a different level or
quality of goods or services
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights
under the CCPA, and if You are a California resident, You can contact Us:
By email:
[email protected]
By phone number:
844-773-2946
Only You, or a person registered with the
California Secretary of State that You authorize to act on Your behalf, may
make a verifiable request related to Your personal information.
Your request to Us 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 the required information if we cannot:
·
Verify Your identity or
authority to make the request
·
And confirm that the personal
information relates to You
We will disclose and deliver the required
information free of charge within 45 days of receiving Your verifiable request.
The time period to provide the required information may be extended once by an
additional 45 days when reasonable necessary and with prior notice.
Any disclosures We provide will only cover
the 12-month period preceding the verifiable request's receipt.
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.
Do Not Sell My Personal Information
You have the right to opt-out of the sale
of Your personal information. Once We receive and confirm a verifiable consumer
request from You, we will stop selling Your personal information. To exercise
Your right to opt-out, please contact Us.
The Service Providers we partner with (for
example, our analytics or advertising partners) may use technology on the
Service that sells personal information as defined by the CCPA law. If you wish
to opt out of the use of Your personal information for interest-based
advertising purposes and these potential sales as defined under CCPA law, you
may do so by following the instructions below.
Please note that any opt out is specific to
the browser You use. You may need to opt out on every browser that You use.
Website
You can opt out of receiving ads that are
personalized as served by our Service Providers by following our instructions
presented on the Service:
·
The NAI's opt-out platform: http://www.networkadvertising.org/choices/
·
The EDAA's opt-out platform http://www.youronlinechoices.com/
·
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a cookie on Your
computer that is unique to the browser You use to opt out. If you change
browsers or delete the cookies saved by your browser, You will need to opt out
again.
Mobile Devices
Your mobile device may give You the ability
to opt out of the use of information about the apps You use in order to serve
You ads that are targeted to Your interests:
·
"Opt out of Interest-Based
Ads" or "Opt out of Ads Personalization" on Android devices
·
"Limit Ad Tracking"
on iOS devices
You can also stop the collection of
location information from Your mobile device by changing the preferences on
Your mobile device.
"Do Not Track" Policy as Required
by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not
Track signals.
However, some third party websites do keep
track of Your browsing activities. If You are visiting such websites, You can
set Your preferences in Your web browser to inform websites that You do not
want to be tracked. You can enable or disable DNT by visiting the preferences
or settings page of Your web browser.
Children's Privacy
Our Service does not address anyone under
the age of 13. We do not knowingly collect personally identifiable information
from anyone under the age of 13. If You are a parent or guardian and You are
aware that Your child has provided Us with Personal Data, please contact Us. If
We become aware that We have collected Personal Data from anyone under the age
of 13 without verification of parental consent, We take steps to remove that
information from Our servers.
If We need to rely on consent as a legal
basis for processing Your information and Your country requires consent from a
parent, We may require Your parent's consent before We collect and use that
information.
Your California Privacy Rights (California's
Shine the Light law)
Under California Civil Code Section 1798
(California's Shine the Light law), California residents with an established
business relationship with us can request information once a year about sharing
their Personal Data with third parties for the third parties' direct marketing
purposes.
If you'd like to request more information
under the California Shine the Light law, and if You are a California resident,
You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California
Business and Professions Code Section 22581)
California Business and Professions Code
section 22581 allow California residents under the age of 18 who are registered
users of online sites, services or applications to request and obtain removal of
content or information they have publicly posted.
To request removal of such data, and if You
are a California resident, You can contact Us using the contact information
provided below, and include the email address associated with Your account.
Be aware that Your request does not
guarantee complete or comprehensive removal of content or information posted
online and that the law may not permit or require removal in certain
circumstances.
Links to Other Websites
Our Service may contain links to other websites
that are not operated by Us. If You click on a third party link, You will be
directed to that third party's site. We strongly advise You to review the
Privacy Policy of every site You visit.
We have no control over and assume no
responsibility for the content, privacy policies or practices of any third
party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time
to time. We will notify You of any changes by posting the new Privacy Policy on
this page.
We will let You know via email and/or a
prominent notice on Our Service, prior to the change becoming effective and
update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy
Policy periodically for any changes. Changes to this Privacy Policy are
effective when they are posted on this page.
Contact Us
If you have any questions about this
Privacy Policy, You can contact us:
By email:
[email protected]
By phone number:
844-773-2946