Last updated 2019-11-18
- Personal Information Collection
- Use of Personal Information
- Sharing of Personal Information
- Information Security and Integrity
- Exercise of Data Subject Rights
- Cookies: are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer.
- Data Controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Information.
- Data Processor: means a natural or legal person, public authority, agency or any other body which Processes Personal Information on behalf of the Data Controller.
- Personal Information: means any information relating to an identified or identifiable natural person, as defined under applicable law, such as name, home address, telephone number, or email address.
- Non-Identifying Information: means information that may relate to an individual but does not by itself identify that individual. For example, Web Information is Non-Identifying Information, as is information such as gender, age, city, and physical location, when not linked with other Personal Information.
Personal Information Collection
- Personal Information submitted to us: This may be personal contact, identification, and location information, such as name, home or work address, personal or business email address, contact details such as mobile phone number, gender, age or date of birth, job title, country of residence, username, domain name (if personally identifiable), that Users may submit in connection with any of our services. This also includes information provided to us on the Website that would constitute personal data under applicable law.
- Personal Information received from a third party: This may include Personal Information such as name and address for identity verification or to Process a request submitted to us.
- Financial information: This may include financial account information, credit card number, or financial transaction information when using any of our services or where such information is requested.
- Automatically logged use information: The Website may automatically record information that is sent by the User's browser or device when accessing and using the Website, which can be identifying or non-identifying. This information may include information such as IP address, browser type, internet service provider (ISP), date/time stamp, page viewed, operating system, mobile device information, clickstream information, preference information, and other similar information.
Use of Personal Information
We will Process Personal Information only for fair, lawful, and legitimate reasons, including to:
- Improve our Website performance, content, and its services;
- Respond to User questions, comments, inquiries, feedback, including those concerning our services;
- Process payments and fulfill a transaction between a User and us, if the User submits payment information in connection with any of our services;
- Perform relevant contractual obligations with the User and other third parties;
- Administer User's application for any of our services or programs;
- To provide updates and other information regarding our services delivery; and
- Provide information or a service requested by the User.
We will also process your Personal Information with your consent to provide you with marketing information concerning news, updates, and other information regarding our services.
We will use Non-Identifying Information generally for the same purposes as with Personal Information, and to improve User services, store User's Website preferences, improve the Website's performance, help maintain personal and device identity verification, Website security, and measure the effectiveness of electronic communications.
We will retain certain Personal Information stored on our servers in accordance with our general archival practices and as required or permitted by law.
We will store the User's Personal Information only for as long as is required to fulfill the purposes set out above. However, where we are required by law to retain a User's Personal Information longer or where a User's Personal Information is required for us to assert or defend against legal claims, we will retain the User's Personal Information until the end of the relevant retention period or until the claims in question have been resolved.
Sharing of Personal Information
We may share certain Personal Information with contractors and other agents for the purpose of Processing this information on our behalf, and providing other services to us or to the User on our behalf. These third parties include providers that provide services such as email transmission, customer relationship management (CRM), IT security, infrastructure service providers, database management. We require that these parties agree to handle this information in compliance with appropriate confidentiality obligations and security measures. We also may publish some Personal Information on the Website in a manner that is viewable by our community members, as described in the relevant program description.
We will not sell or otherwise share any Personal Information with third parties for marketing purposes.
Information Security and Integrity
We will use reasonable industry standard safeguards (which may include physical, procedural and technical measures) to protect against the unauthorized disclosure of Personal Information it collects and holds. We will take reasonable steps to ensure that Personal Information collected is complete and relevant to its intended use.
The Website contains links to other third-party websites, which are subject to the respective privacy policies of those third parties. We are not responsible for the privacy practices of such linked third-party sites, and their owners and operators.
Due to the open communication nature of the Internet, we cannot represent, warrant or guarantee that communications stored on our servers will be free from unauthorized access by third parties, loss, misuse, or alterations. While we will take reasonable and appropriate security measures to protect against unauthorized access, disclosure, alteration or destruction of Personal Information received, WE DISCLAIM ANY AND ALL LIABILITY FOR UNAUTHORIZED ACCESS OR USE OR COMPROMISE OF YOUR PERSONAL INFORMATION TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW. USERS ARE ADVISED THAT THEY SUBMIT SUCH PERSONAL INFORMATION AT THEIR OWN RISK.
Exercise of Data Subject Rights
Users may be entitled to obtain access to information on the Processing of Personal Information, to object to certain Processing, request information portability, and have their Personal Information rectified, deleted, or otherwise restricted in terms of Processing, in each case as permitted under applicable law. Users also may be entitled to withdraw any consent given with prospective effect with respect to the Processing of their Personal Information. Users can exercise these rights or learn more about the Processing of Personal Information by us, by sending a request to email@example.com. Any request is subject to identity verification. All privacy-related access requests are taken seriously, and we will respond to request(s) as soon as reasonably practicable, but in any case, within the legally required period of time. Please note that certain Personal Information may be exempt from such access, correction, objection, or deletion rights pursuant to local laws.
If a User no longer wishes to receive certain electronic communications from us, the User may opt-out from such communication by following the unsubscribe instructions at the bottom of such communication or by accessing any available preference setting functionality in the Website.