Last Updated: June 22, 2023
YOUR CONTINUED USE OF OUR SITE CONSTITUTES YOUR ACCEPTANCE OF THOSE CHANGES.
The Personal Information We Collect About You
Personal information, means any information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (“personal information”).
We may collect, use, store and transfer different kinds of personal information about you via our Site or in the course of providing services to you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, date of birth, telephone number, fax number, email address.
- Government Issued Identity includes driver’s license, state identification.
- Contact Data includes street address, city, state, zip, email address and telephone numbers.
- Financial Data includes payment card details, account numbers and expiration dates.
- Commercial Transaction Data includes details about our transactions with you and other details of products and services you have purchased from us.
- Internet or other Electronic Network Activity Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site, and information about how you use our Site, products and services.
- Outreach and Communications Data includes your preferences in receiving communications (for example: newsletter and other email communications you elect to receive) from us and our third parties and your communication preferences.
This personal information is required to provide the Site to you. If you do not provide personal information we ask for, it may delay or prevent us from providing certain products and/or services to you.
Collection of Personal Information
We primarily collect your personal information when you provide it to us voluntarily in person, by telephone, text or email and/or through our Site, or, for Company’s customers, when you login to our Site using your username and password. For example, we collect Personal Information when you purchase a product, or participate in other activities on our Site to be able to provide you information related to these registrations.
However, we may also collect information:
- From publicly accessible sources;
- Directly from third parties (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
- From a third party with your consent;
- From cookies on our Site; and
- Via our IT systems, including automated monitoring of our Site and other technical systems, such as our computer networks and connections, communications systems, and email and instant messaging systems.
How We Use Your Personal Information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: (a) where we need to perform the contract we are about to enter into or have entered into with you; (b) where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests; (c) where we need to comply with a legal or regulatory obligation; or (d) where you have given consent.
We use your data in the following ways:
- To fulfill your request or other purposes for which you provided it, including to provide you with our products and/or services;
- To register you as a new guest, user, or customer;
- To process registrations, scheduling and service requests;
- To manage our relationship with you;
- To enable you to complete web forms or survey;
- To administer and protect our Site;
- To ensure business policies are adhered to, e.g. policies covering security and internet use;
- To prevent and detect fraud against you or us;
- To prevent unauthorized access and modifications to systems;
- To deliver relevant Site content to you;
- To use data analytics to improve our Site, services, outreach communications, client relationships and experiences;
- To make suggestions and recommendations to you about services that may be of interest to you;
- To send you information about our programs, services, and upcoming events as well as other materials that we think may be of interest to you;
- For operational reasons, such as improving efficiency, training and quality control;
- To ensure the confidentiality of commercially sensitive information; and
- To update and enhance customer records.
Who We Share Your Personal Information With
We routinely share personal information with:
- Our affiliates;
- Service providers we use to help deliver our products and/or services to you, such as payment service providers;
- Other third parties we use to help us run our business, such as marketing agencies or website hosts;
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
- Our insurers and brokers; and
- Our banks.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information and only to the extent such services providers need access to such information to perform the services we request. We reserve the right to release personal information about you when we believe that such disclosure is necessary or appropriate to comply with applicable law or to protect the safety or property of visitors to our Site, the public, the Company, our affiliates or our personnel.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Aggregate and Non-Personal Information
We may also collect certain non-personal information about your use of the Site (e.g., to determine which pages of our Site are most popular and to improve use of the Site). We may collect IP addresses to analyze trends, administer our Site, track traffic patterns, and gather demographic information for aggregate use. We may share this aggregated non-personal information with our affiliates, licensees and partners, and may post analyses and statistics based on the aggregated data on the Site or use the data for research or promotional purposes relating to our mission.
Company also may use “cookies” to collect information about visitors to our Site. A “cookie” is a small text file that a website places on your computer’s hard drive to make it easier to use certain website functions or to collect information about your activities on the website. The cookie transmits this information back to the website. Many users do not know that “cookies” are placed on their computers when they visit websites. If you want to prevent this from happening, you can set your browser to warn you when a website attempts to place a cookie on your computer. Please note that if you disable cookies you may lose some functionality on our Site.
Providing security for the personal information that you submit is a top priority. We use generally accepted industry standards to protect the personal information we collect, both during transmission and once we receive it. We endeavor to protect the personal information we receive, gather and store, by such means as Transport Layer Security (TLS) encryption, access control procedures, network firewalls, physical security, and other measures intended to protect the information that you provide to us. These measures increase the security and privacy of information traveling to, from, and within Company. Only our authorized employees or agents carrying out permitted business functions are allowed to access personal information.
Please be aware, however, that no physical or electronic security system is impenetrable. We cannot guarantee the security of our servers or databases, nor can we guarantee that the information that you supply to us will not be intercepted during transmission over the internet. Any such transmission of information by you over the internet is at your own risk.
We will maintain a record of every breach of security safeguards involving personal information under our control. We will notify you of any breach of our security safeguards involving your personal information if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to you.
Location of Servers; Transfer of Information to the United States; Other Transfer
How Long Your Personal Information Will Be Kept
We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
Third Party Websites
You should contact the site administrator for such third party website if you have any complaints, claims, concerns or questions regarding such third party website or its privacy practices.
Our Site is not directed to children and we will not knowingly allow anyone under the age of 13 to use the Site or to provide us with any personal information. Children always should get permission from their parents before sending any information about themselves (such as their names, email addresses and phone numbers) over the Internet. If you are under 13, please do not use our services, access the Site, or provide any information about yourself. If a child under 13 submits personal information to us and we learn that the personal information is the information of a child under 13, we will, in compliance with the Children’s Online Privacy Protection Act, delete the information as soon as possible and cancel the corresponding accounts. If you believe that we might have any personal information from a child under 13, please contact us (see the “Contact Us” Section below). Please visit the FTC’s website at www.ftc.gov for tips on protecting children’s privacy online.
Promotional Communications and Opt-Out
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
Message and data rates may apply. We do not charge a fee for our text message programs and assume no responsibility for charges by your carrier that you may incur when you sign up to receive text messages from us.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How We Use Your Personal Information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with other third party organizations for marketing purposes.
If you do not wish to receive promotional communications (e.g., by e-newsletters, e-mail messages, or postal mailings about Company’s programs and services), you can opt out of receiving such promotional communications at any time by:
- Updating your account profile settings; or
- Using the unsubscribe option in the messaging sent to you or “STOP” number in texts.
If you need assistance in completing this request, please inform us by sending an e-mail to: firstname.lastname@example.org. Please indicate if you wish to discontinue receiving promotional communications sent through only certain methods but not others.
We may ask you to confirm or update your preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business. You may receive a final confirmation message to confirm that you will no longer receive email or text messages from the applicable program unless you opt back into such program.
Contact Us; Comments and Questions