Effective date: August 14, 2020
Sources of Personal Data
We collect Personal Data about you from:
- when you provide such information directly to us, and
- when Personal Data about you is automatically collected in connection with your use of our Services.
- Our subsidiaries and affiliates (together, "Affiliates"), when they provide us with Personal Data about you.
- Third parties, when they provide us with Personal Data about you ("Third Parties"). Third Parties that share your Personal Data with us include:
- Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
- Social networks connected to the services. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us
- Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
Categories of Personal Data We Collect
|Category of Personal Data||Personal Data Collected||What is the source of this Personal Data?|
|A.||Personal identifiers Examples_: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number or other similar identifiers._||We collect your email address and your name so we can respond to inquiries from you, and so we can anonymize and then review your use of our site to improve it for you and other clients.||You|
|B.||Customer records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))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.||We collect your email address and your name||You|
|C.||Protected classification characteristics under state 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 or genetic information (including familial genetic information)._||We do not collect this category of Personal Data.||Not applicable.|
|D.||Commercial information Examples_: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies._||We collect data on services you selected and considered in order to improve our services for you and other clients.||You|
|E.||Biometric information Examples_: Genetic, physiological, behavioral, and biological characteristics or identifying activity patterns, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health or exercise data._||We do not collect this category of Personal Data.||Not applicable.|
|F.||Internet or other similar network activity information Examples_: Browsing history, search history, or information on a consumer's interaction with a website, application or advertisement._||We collect information your browsing and search history on our site, and your interactions there, in order to improve our services for you and other clients.||You.|
|G.||Geolocation data Examples_: Physical location or movements._||We do not collect this category of Personal Data.||Not applicable.|
|H.||Sensory data Examples_: Audio, electronic, visual, thermal, olfactory or similar information._||We do not collect this category of Personal Data.||Not applicable.|
|I.||Professional or employment-related information Examples_: Current or past job history or performance evaluations._||We do not collect this category of Personal Data.||Not applicable.|
|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.||We do not collect this category of Personal Data.||Not applicable.|
|K.||Inferences drawn from other personal information Examples_: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes._||We do not collect this category of Personal Data.||Not applicable.|
|L.||Age or date of birth||We do not collect this category of Personal Data.||Not applicable.|
The following sections provide additional information about how we collect your Personal Data.
Information Collected Automatically
We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
- Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled "Information about Interest-Based Advertisements."
You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
Information about Interest-Based Advertisements:
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to clients who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads"). Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular clients on the Services and/or services of third parties. Such information may be gathered through tracking clients' activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
We comply with the Digital Advertising Alliance ("DAA") Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative ("NAI"), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer's online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA's or NAI's consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices.
How We Use Your Personal Data
We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:
- To meet or fulfill the reason you provided the information to us.
- To communicate with you about the Services, including Service announcements, updates or offers.
- To provide support and assistance for the Services.
- To create and manage your Account or other client profiles.
- To personalize website content and communications based on your preferences, including targeted offers and ads served through the Services.
- To process orders or other transactions.
- To respond to client inquiries and fulfill client requests.
- To improve and develop the Services, including testing, research, analysis and product development.
- To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the "CCPA").
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
As noted in the list above, we may communicate with you if you've provided us the means to do so. For example, if you've given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at firstname.lastname@example.org.
How We Share Your Personal Data
Disclosures of Personal Data for a Business Purpose
We may disclose your Personal Data to service providers and other parties for the following business purposes:
- Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
- Performing services on our behalf, including maintaining or servicing accounts, providing customer service, verifying customer information, providing analytic services, or providing similar services on behalf of the business or service provider.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or control.
We disclose your Personal Data to the following categories of service providers and other parties:
- Service providers, including:
- Security and fraud prevention consultants.
- Hosting and other technology and communications providers.
- Analytics providers.
- Staff augmentation and contract personnel.
- Our Affiliates.
- Parties who acquire your Personal Data through an acquisition or other change of control.
- Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
- Other parties at your direction.
- Other clients (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services).
- Third-party business partners who you access through the Services.
- Other parties authorized by you.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. ]You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
California Resident Rights
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:
- The categories of Personal Data that we have collected about you.
- The categories of sources from which that Personal Data was collected.
- The business or commercial purpose for collecting or selling your Personal Data.
- The categories of third parties with whom we have shared your Personal Data.
- The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.
If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data purchased by each category of third party recipient.
You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
- Call us at: 650 240 4950
- Emailing us at: email@example.com
Personal Data Sales Opt-Out and Opt-In
We will not sell your Personal Data.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes; in order to submit such a request, please contact us at firstname.lastname@example.org.
Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support DO Not Track requests at this time. To find out more about "Do Not Track," you can visit www.allaboutdnt.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at email@example.com with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
Personal Data We Collect
The "Categories of Personal Data We Collect" section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The "How We Use Your Personal Data" section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.
- A. Personal identifiers.
- B. Customer records identified by state law.
- D. Commercial information.
- M. Special categories of data under the EU General Data Protection Regulation.
- Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
- A. Personal identifiers.
- B. Customer records identified by state law.
- D. Commercial information.
- F. Internet or other similar network activity information.
- I. Professional or employment-related information.
- K. Inferences drawn from other personal information.
- L. Age or date of birth.
- M. Special categories of data under the EU General Data Protection Regulation.
Examples of these legitimate interests include:
- Operation and improvement of our business, products and Services
- Marketing of our products and Services
- Provision of customer support
- Protection from fraud or security threats
- Compliance with legal obligations
- Completion of corporate transactions
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Sharing Personal Data
The "How We Share Your Personal Data" section above details how we share your Personal Data with third parties.
1 Franklin Parkway
Building 950, Floor 1, Incubator Suite
San Mateo, CA 94403