Last updated August 28, 2022
This privacy notice for us, describes how and why we might
collect, store, use, and/or share (“process”)
your information when you use our services
(“Services”), such as when you visit our
website
or any website of ours that links to this privacy notice.
Engage with us in other related ways, including any sales,
marketing, or event. Questions or concerns? Reading this
privacy notice will help you understand your privacy rights
and choices. If you do not agree with our policies and
practices, please do not use our Services. If you still have
any questions or concerns, please contact us
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice.
What personal information do we process? When you visit,
use, or navigate our Services, we may process personal
information depending on how you interact with us and the
Services, the choices you make, and the products and
features you use.
Do we process any sensitive personal information? We do not
process sensitive personal information.
Do we receive any information from third parties? We do not
receive any information from third parties.
How do we process your information? We process your
information to provide, improve, and administer our
Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also process your
information for other purposes with your consent. We process
your information only when we have a valid legal reason to
do so.
In what situations and with which parties do we share
personal information? We may share information in specific
situations and with specific third parties.
How do we keep your information safe? We have organizational
and technical processes and procedures in place to protect
your personal information. However, no electronic
transmission over the internet or information storage
technology can be guaranteed to be 100% secure, so we cannot
promise or guarantee that hackers, cybercriminals, or other
unauthorized third parties will not be able to defeat our
security and improperly collect, access, steal, or modify
your information.
What are your rights? Depending on where you are located
geographically, the applicable privacy law may mean you have
certain rights regarding your personal information.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide
to us.
We collect personal information that you voluntarily provide
to us when you express an interest in obtaining information
about us or our products and Services, when you participate
in activities on the Services, or otherwise when you contact
us.
Personal Information Provided by You. The personal
information that we collect depends on the context of your
interactions with us and the Services, the choices you make,
and the products and features you use. The personal
information we collect may include the following:
names
email addresses
Sensitive Information. We do not process sensitive
information.
All personal information that you provide to us must be
true, complete, and accurate, and you must notify us of any
changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol
(IP) address and/or browser and device characteristics — is
collected automatically when you visit our Services.
We automatically collect certain information when you visit,
use, or navigate the Services. This information does not
reveal your specific identity (like your name or contact
information) but may include device and usage information,
such as your IP address, browser and device characteristics,
operating system, language preferences, referring URLs,
device name, country, location, information about how and
when you use our Services, and other technical information.
This information is primarily needed to maintain the
security and operation of our Services, and for our internal
analytics and reporting purposes.
Like many businesses, we also collect information through
cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related,
diagnostic, usage, and performance information our servers
automatically collect when you access or use our Services
and which we record in log files. Depending on how you
interact with us, this log data may include your IP address,
device information, browser type, and settings and
information about your activity in the Services (such as the
date/time stamps associated with your usage, pages and files
viewed, searches, and other actions you take such as which
features you use), device event information (such as system
activity, error reports (sometimes called “crash
dumps”), and hardware settings).
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve,
and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We
may also process your information for other purposes with
your consent.
We process your personal information for a variety of
reasons, depending on how you interact with our Services,
including:
To request feedback. We may process your information when
necessary to request feedback and to contact you about your
use of our Services.
To identify usage trends. We may process information about
how you use our Services to better understand how they are
being used so we can improve them.
To determine the effectiveness of our marketing and
promotional campaigns. We may process your information to
better understand how to provide marketing and promotional
campaigns that are most relevant to you.
To save or protect an individual’s vital interest. We
may process your information when necessary to save or
protect an individual’s vital interest, such as to prevent
harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only process your personal information when we
believe it is necessary and we have a valid legal reason
(i.e., legal basis) to do so under applicable law, like with
your consent, to comply with laws, to provide you with
services to enter into or fulfill our contractual
obligations, to protect your rights, or to fulfill our
legitimate business interests.
If you are located in the EU or UK, this section applies to
you.
The General Data Protection Regulation (GDPR) and UK GDPR
require us to explain the valid legal bases we rely on in
order to process your personal information. As such, we may
rely on the following legal bases to process your personal
information:
Consent. We may process your information if you have given
us permission (i.e., consent) to use your personal
information for a specific purpose. You can withdraw your
consent at any time.
Legitimate Interests. We may process your information when
we believe it is reasonably necessary to achieve our
legitimate business interests and those interests do not
outweigh your interests and fundamental rights and freedoms.
For example, we may process your personal information for
some of the purposes described in order to:
Analyze how our services are used so we can improve them to
engage and retain users
Support our marketing activities
Understand how our users use our products and services so we
can improve user experience
Legal Obligations. We may process your information where we
believe it is necessary for compliance with our legal
obligations, such as to cooperate with a law enforcement
body or regulatory agency, exercise or defend our legal
rights, or disclose your information as evidence in
litigation in which we are involved.
Vital Interests. We may process your information where we
believe it is necessary to protect your vital interests or
the vital interests of a third party, such as situations
involving potential threats to the safety of any person.
If you are located in Canada, this section applies to
you.
We may process your information if you have given us
specific permission (i.e., express consent) to use your
personal information for a specific purpose, or in
situations where your permission can be inferred (i.e.,
implied consent). You can withdraw your consent at any
time.
In some exceptional cases, we may be legally permitted under
applicable law to process your information without your
consent, including, for example:
If collection is clearly in the interests of an individual
and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are
met
If it is contained in a witness statement and the collection
is necessary to assess, process, or settle an insurance
claim
For identifying injured, ill, or deceased persons and
communicating with next of kin
If we have reasonable grounds to believe an individual has
been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with
consent would compromise the availability or the accuracy of
the information and the collection is reasonable for
purposes related to investigating a breach of an agreement
or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena,
warrant, court order, or rules of the court relating to the
production of records
If it was produced by an individual in the course of their
employment, business, or profession and the collection is
consistent with the purposes for which the information was
produced
If the collection is solely for journalistic, artistic, or
literary purposes
If the information is publicly available and is specified by
the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information in specific situations
described in this section and/or with the following third
parties.
We may need to share your personal information in the
following situations:
Business Transfers. We may share or transfer your
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.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies
to collect and store your information.
We may use cookies and similar tracking technologies (like
web beacons and pixels) to access or store information.
Specific information about how we use such technologies and
how you can refuse certain cookies is set out in our Cookie
Notice.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary
to fulfill the purposes outlined in this privacy notice
unless otherwise required by law.
We will only keep your personal information for as long as
it is necessary for the purposes set out in this privacy
notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal
requirements). No purpose in this notice will require us
keeping your personal information for longer than 90
days.
When we have no ongoing legitimate business need to process
your personal information, we will either delete or
anonymize such information, or, if this is not possible (for
example, because your personal information has been stored
in backup archives), then we will securely store your
personal information and isolate it from any further
processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information
through a system of organizational and technical security
measures.
We have implemented appropriate and reasonable technical and
organizational security measures designed to protect the
security of any personal information we process. However,
despite our safeguards and efforts to secure your
information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not
be able to defeat our security and improperly collect,
access, steal, or modify your information. Although we will
do our best to protect your personal information,
transmission of personal information to and from our
Services is at your own risk. You should only access the
Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to
children under 18 years of age.
We do not knowingly solicit data from or market to children
under 18 years of age. By using the Services, you represent
that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor
dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been
collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our
records. If you become aware of any data we may have
collected from children under age 18, please contact us
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic
Area (EEA), United Kingdom (UK), and Canada, you have rights
that allow you greater access to and control over your
personal information. You may review, change, or terminate
your account at any time.
In some regions (like the EEA, UK, and Canada), you have
certain rights under applicable data protection laws. These
may include the right (i) to request access and obtain a
copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing
of your personal information; and (iv) if applicable, to
data portability. In certain circumstances, you may also
have the right to object to the processing of your personal
information. You can make such a request by contacting us by
using the contact details provided in the section “HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
We will consider and act upon any request in accordance with
applicable data protection laws.
If you are located in the EEA or UK and you believe we are
unlawfully processing your personal information, you also
have the right to complain to your local data protection
supervisory authority. You can find their contact details
here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for
the data protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent
to process your personal information, which may be express
and/or implied consent depending on the applicable law, you
have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using
the contact details provided in the section “HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?” below.
However, please note that this will not affect the
lawfulness of the processing before its withdrawal nor, when
applicable law allows, will it affect the processing of your
personal information conducted in reliance on lawful
processing grounds other than consent.
Cookies and similar technologies: Most Web browsers are set
to accept cookies by default. If you prefer, you can usually
choose to set your browser to remove cookies and to reject
cookies. If you choose to remove cookies or reject cookies,
this could affect certain features or services of our
Services. To opt out of interest-based advertising by
advertisers on our Services visit
http://www.aboutads.info/choices/.
If you have questions or comments about your privacy rights,
you may email us.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and
mobile applications include a Do-Not-Track
(“DNT”) feature or setting you can activate to
signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this
stage no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do
not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to
be tracked online. If a standard for online tracking is
adopted that we must follow in the future, we will inform
you about that practice in a revised version of this privacy
notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are
granted specific rights regarding access to your personal
information.
California Civil Code Section 1798.83, also known as the
“Shine The Light” law, permits our users who are
California residents to request and obtain from us, once a
year and free of charge, information about categories of
personal information (if any) we disclosed to third parties
for direct marketing purposes and the names and addresses of
all third parties with which we shared personal information
in the immediately preceding calendar year. If you are a
California resident and would like to make such a request,
please submit your request in writing to us using the
contact information provided below.
If you are under 18 years of age, reside in California, and
have a registered account with Services, you have the right
to request removal of unwanted data that you publicly post
on the Services. To request removal of such data, please
contact us using the contact information provided below and
include the email address associated with your account and a
statement that you reside in California. We will make sure
the data is not publicly displayed on the Services, but
please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g., backups,
etc.).
CCPA Privacy Notice
The California Code of Regulations defines a
“resident” as:
(1) every individual who is in the State of California for
other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of
California who is outside the State of California for a
temporary or transitory purpose
All other individuals are defined as
“non-residents.”
If this definition of “resident” applies to you,
we must adhere to certain rights and obligations regarding
your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal
information in the past twelve (12) months:
Category Examples Collected
A. Identifiers
Contact details, such as real name, alias, postal address,
telephone or mobile contact number, unique personal
identifier, online identifier, Internet Protocol address,
email address, and account name
– YES
B. Personal information categories listed in the California
Customer Records statute
Name, contact information, education, employment, employment
history, and financial information
– YES
C. Protected classification characteristics under California
or federal law
Gender and date of birth
– NO
D. Commercial information
Transaction information, purchase history, financial
details, and payment information
– NO
E. Biometric information
Fingerprints and voiceprints
– NO
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest
data, and interactions with our and other websites,
applications, systems, and advertisements
– NO
G. Geolocation data
Device location
– NO
H. Audio, electronic, visual, thermal, olfactory, or similar
information
Images and audio, video or call recordings created in
connection with our business activities
– NO
I. Professional or employment-related information
Business contact details in order to provide you our
Services at a business level or job title, work history, and
professional qualifications if you apply for a job with
us
– NO
J. Education Information
Student records and directory information
– NO
K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal
information listed above to create a profile or summary
about, for example, an individual’s preferences and
characteristics
– YES
We may also collect other personal information outside of
these categories through instances where you interact with
us in person, online, or by phone or mail in the context
of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond
to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing
practices can be found in this privacy notice
If you are using an authorized agent to exercise your right
to opt out we may deny a request if the authorized agent
does not submit proof that they have been validly authorized
to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service
providers pursuant to a written contract between us and each
service provider. Each service provider is a for-profit
entity that processes the information on our behalf.
We may use your personal information for our own business
purposes, such as for undertaking internal research for
technological development and demonstration. This is not
considered to be “selling” of your personal
information.
We have not disclosed or sold any personal information to
third parties for a business or commercial purpose in the
preceding twelve (12) months. We will not sell personal
information in the future belonging to website visitors,
users, and other consumers.
Your rights with respect to your personal data
You can ask for the deletion of your personal information.
If you ask us to delete your personal information, we will
respect your request and delete your personal information,
subject to certain exceptions provided by law, such as (but
not limited to) the exercise by another consumer of his or
her right to free speech, our compliance requirements
resulting from a legal obligation, or any processing that
may be required to protect against illegal activities.
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is
used;
whether we sell your personal information to third
parties;
the categories of personal information that we sold or
disclosed for a business purpose;
the categories of third parties to whom the personal
information was sold or disclosed for a business purpose;
and
the business or commercial purpose for collecting or selling
personal information.
In accordance with applicable law, we are not obligated to
provide or delete consumer information that is de-identified
in response to a consumer request or to re-identify
individual data to verify a consumer request
Right to Non-Discrimination for the Exercise of a Consumer’s
Privacy Rights
We will not discriminate against you if you exercise your
privacy rights.
Verification process
Upon receiving your request, we will need to verify your
identity to determine you are the same person about whom we
have the information in our system. These verification
efforts require us to ask you to provide information so that
we can match it with information you have previously
provided us. For instance, depending on the type of request
you submit, we may ask you to provide certain information so
that we can match the information you provide with the
information we already have on file, or we may contact you
through a communication method (e.g., phone or email) that
you have previously provided to us. We may also use other
verification methods as the circumstances dictate.
We will only use personal information provided in your
request to verify your identity or authority to make the
request. To the extent possible, we will avoid requesting
additional information from you for the purposes of
verification. However, if we cannot verify your identity
from the information already maintained by us, we may
request that you provide additional information for the
purposes of verifying your identity and for security or
fraud-prevention purposes. We will delete such additionally
provided information as soon as we finish verifying you.
Other privacy rights
You may object to the processing of your personal
information.
You may request correction of your personal data if it is
incorrect or no longer relevant, or ask to restrict the
processing of the information.
You can designate an authorized agent to make a request
under the CCPA on your behalf. We may deny a request from an
authorized agent that does not submit proof that they have
been validly authorized to act on your behalf in accordance
with the CCPA.
You may request to opt out from future selling of your
personal information to third parties. Upon receiving an
opt-out request, we will act upon the request as soon as
feasibly possible, but no later than fifteen (15) days from
the date of the request submission.
To exercise these rights, you can contact us by email
by visiting
or by referring to the contact details at the bottom of this
document. If you have a complaint about how we handle your
data, we would like to hear from you.
Metrics
Our metrics for all CCPA requests received for the previous
calendar year can be found.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to
stay compliant with relevant laws
We may update this privacy notice from time to time. The
updated version will be indicated by an updated
“Revised” date and the updated version will be
effective as soon as it is accessible. If we make material
changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this
privacy notice frequently to be informed of how we are
protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may
email us.
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on the applicable laws of your country, you may have
the right to request access to the personal information we
collect from you, change that information, or delete it.