Effective Date: [Insert date of publication]
Some of the information we collect about you identifies you. If it identifies you, we call it “Personal Information.” Personal Information does not include any information that is publicly available or information that has been anonymized to the point where a specific individual or household cannot be identified from the remaining information. If we associate non-identifiable information with information that identifies you, we will treat it as Personal Information.
We only collect and use your Personal Information when we have a legitimate reason for doing so. We only collect Personal Information that is reasonably necessary to provide our Services to you and for the purposes set forth in this Policy. The information we collect can come from information you provide, information we collect through automated means, and information we collect from other sources.
We may also use these technologies to collect information regarding your interaction with email messages, such as whether you have opened, clicked on, or forwarded a message.
Be aware that certain Personal Information and other information in connection with your use of the Services may be stored on your device (even if we do not collect that information). You are solely responsible for maintaining the security of your device from unauthorized access.
The companies we work with to provide you with targeted ads are required to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices ; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices ; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services). If you choose to opt out, you will continue to receive advertisements, but they will not be tailored to your interests.
Google also provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.
Please note that if you opt out using any of these methods, the opt-out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any third-party statements regarding their opt-out options or programs.
Depending on the type and version of the operating system of your mobile device, you may also be asked whether to enable targeted advertising. You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).
Marketing Communications and Commercial Email Opt-Out. When you create an account with us, unless you opt-out, we will use your email address to deliver digital communications from us or our advertisers or sponsors. When you communicate with us through any means such as chat or email, we may use your contact details for marketing communications. You can unsubscribe from email and other digital communications by following the instructions in the communication or by sending a request to us using the contact information listed below or through the Contact Us link provided at the bottom of every page of the Site.
If you opt-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Services.
Applicable Law. Subject to applicable law, you may have different rights regarding our use of your information. For example, you may have the following rights:
Right to request access to and to check what Personal Information we maintain about you;
Right to request copies of your Personal Information;
Right to update and correct inaccuracies in your Personal Information;
Right to have your Personal Information deleted;
Right to request restriction of the collection, processing, or use of information about you;
Right to request data portability;
Right to lodge a complaint with a supervisory authority; and
In some cases, the right to object to our processing of your information and to withdraw your consent to our processing of your information.
You can perform many of these actions by going back to the specific Service, logging-in, and making the desired change.
When you request the deletion of your information, object or withdraw your consent to the processing of your information, we may not be able to provide all the features of the Services to you. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to the Services from our servers.
To exercise any of these rights please contact us using the contact information listed “or through the Contact Us link provided at the bottom of every page of the Site. We will promptly review all such requests in accordance with applicable laws.
Please see the Special Notice for California Consumers for more information about rights that apply to residents of certain geographic locations.
Cookies and Other Tracking Technologies.
“Cookies” are alphanumeric identifiers that are stored on a computer, browser, laptop, tablet, mobile phone, or other device (each, a “Device”), which collect information about your activity, browser, and Device. A “web beacon” (sometimes referred to as pixels and tags) is a small object or image that is embedded into a web page, application, or email, and is used to track activity.
We may use both session (for the duration of your visit) and persistent (for the duration of a fixed period of time) cookies and tracking technologies. A cookie does not provide us with access to your computer or to Personal Information beyond what you provide to us.
Some cookies are necessary to use the Services, and these cannot be disabled. Other cookies are not required to use our Services and may be disabled or deleted, but this may prevent you from properly using the Services. Most browsers allow you to adjust your cookie settings.
How Your Information is Secured.
We follow generally accepted industry standards, including the use of appropriate administrative, physical, and technical safeguards, to protect the Personal Information submitted to us. For example, when you enter Personal Information, we encrypt the transmission of that information or use secure connections.
Despite efforts to protect your Personal Information, no method of electronic transmission or storage is 100% secure, and there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the internet may be intercepted.
If we learn of a security system breach, then we may attempt to notify you so that you can take appropriate protective steps. We may post a notice through the Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing, and we will follow all applicable laws.
How Long We Keep Your Personal Information.
We will retain your Personal Information as needed to provide you Services. At any time, you can remove your Personal Information or instruct us to remove it, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our servers. See “Your Choices and Rights” for more information on how you can remove your Personal Information.
Even though you may make changes or request deletion of your Personal Information, we may retain all information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
Special Notice for California Consumers.
Disclosures of Personal Information. As is common practice, within the past 12 months, we have disclosed Personal Information in all or substantially all of the categories identified in Section A of this Additional Notice for California Consumers to vendors who provide services to us, in connection with a sale or transfer of all or part of our business, and as otherwise provided in Section 3 (“How We Share Your Information”).
Right to Opt Out of Sale of Personal Information. You have the right to opt out of the sale of your Personal Information.
We do not sell Personal Information. To the extent we sell Personal Information in the future, you will have the right to request us to stop “selling” your information by using a “Do Not Sell” button on our home page.
Your California Privacy Rights. If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.
Right to Access and Right to Know Your Personal Information. You have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
the categories of Personal Information we have collected about you;
the categories of sources from which the Personal Information is collected;
our business or commercial purpose for collecting or selling Personal Information;
the categories of third parties with whom we share Personal Information;
the specific pieces of information we have collected about you;
the categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and
the categories of Personal Information about you that we disclosed for a business purpose.
Right to Deletion of Personal Information. You have the right to request that we delete Personal Information about you that we have collected from you.
Right to Non-Discrimination. We may not discriminate against you because of your exercise of any of the foregoing privacy rights, or any other rights under the California Consumer Privacy Act, including by:
Denying you goods or services;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing you a different level or quality of goods or services; or
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.
Requests to exercise your rights. You may request to exercise these rights by:
Submitting a request [here]
Calling us toll-free at [here].
As required or permitted under applicable law, please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may limit our response to your exercise of the above rights as permitted under applicable law.
Agent Authorization. You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us to make a request on your behalf. Even if you choose to use an agent, as permitted by law, we may require verification of the agent’s authorization to act on your behalf, require you to confirm you have authorized the agent to act on your behalf, or require you to verify your own identity.
Do Not Track. Please note that our Services are not designed to respond to “do not track” requests from Web browsers.
Shine the Light. California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing. We may share Personal Information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us for more information using either of the addresses provided in the Contact Us section. In your message, please include a description or your request, as well as your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email, online form or postal addresses.
Special Notice for International Users
If you do not consent to such transfer, you may not use the Services. If you choose to access and use the Services from outside the United States, you acknowledge that you are doing so on your own initiative, at your own risk, and are responsible for compliance with applicable laws.
To exercise any of these rights, please contact us by email at <XXXX>.
[insert contact info]