Effective Date: July 1, 2021
To the extent we provide you notice on a Website of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
In addition, please review each Website’s Terms of Service (“Terms of Service”), which governs your use of each Website.
3. What Information Dothe Websites Collect? When you visit a Website, we may collect two types of information about you: (1) information that can be used to identify you, such as your first and last name, e-mail address and home address (“Personal Information“), and (2) information related to your activities on the Website that we automatically collect as you interact with the Website (“Usage Information“).
(a) Personal Information You Voluntarily Provide. Generally, you can visit a Website without telling us who you are and without giving us any Personal Information. The only way that we collect Personal Information at a Website is if you send us a message, through account registration or contact us forms, or if you otherwise voluntarily provide such information through such Website. We will collect whatever Personal Information you voluntarily provide (e.g., name, phone number, postal address, and/or e-mail address). Likewise, if you send us a message, you will be sending us your name, e-mail address, and any other information, including Personal Information, you choose to include in that communication. You are under no obligation to provide Personal Information, but if you elect not to provide it, you may be unable to use certain features of a Website or to communicate with us via a Website.
(b) Usage Information We Collect or Store as You Access or Use the Websites.
Usage Information may include:
- your IP address or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access a Website, and our computers identify your Device by its Device Identifier;
- your Device functionality (including browser, operating system, hardware, mobile network information);
- the URL that referred you to a Website;
- the areas within a Website that you visit and your activities there, including remembering you and your preferences;
- your Device location;
- your Device characteristics; and
- certain other Device data, including the time of day, among other information.
(c) Tracking Technologies. When you visit a Website, we and our service providers may use a variety of technologies that automatically or passively collect or store certain Usage Information related to your activities on such Website. These technologies may set, change, alter or modify settings or configurations on your device. These technologies may include the following:
(i) Cookies and Similar Technologies.
Cookies are small pieces of data stored and managed by your web browser that enable certain Website features and functionality. Cookies and similar technologies can be used to recognize you and your device when you visit a Website, remember your preferences, and make your interactions with such Website faster and more secure. Cookies are a built-in feature of the Web, but they can generally be managed, disabled, or removed using most commercial web browsers. Each browser you use will need to be set separately and different browsers offer different functionality and options for cookies. Please be aware that if you disable or remove cookies on your device, some parts of the Website may not function properly, and that when you revisit the Website your ability to limit cookies is subject to your browser settings and limitations. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit allaboutcookies.org or aboutcookies.org.
The types of cookies that we use on the Websites, and the purposes for which they are used, are as follows:
- Strictly necessary cookies: These cookies are essential to enable you to move around a Website and use its features, such as accessing secure areas. Without these cookies, any services on a Website you wish to access cannot be provided.
https://tools.google.com/dlpage/gaoptout?hl=en-GBM. Further information about Google’s terms and conditions for Google Analytics can be found at:
- Functionality cookies: These cookies allow a Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video. Additionally, these cookies can be used to allow an optional service to function. The information these cookies collect may be anonymized and these cookies cannot track your browsing activity on other websites.
- Targeting cookies. These cookies record your visit to a Website, the pages you have visited and the links you have followed. We use this information to make the Websites more relevant to your interests. We may also share this information with third parties for this purpose.
(ii) Pixel tags
These are also known as a clear GIF or web beacon. These are invisible tags placed on certain pages of a Website but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular device visits a particular page. If you turn off cookies, the pixel tag will simply detect an anonymous website visit.
(iii) Tracking URLs
These are used to determine from which referring website a Website is accessed.
(iv) Social Plugins
A Website may use social plugins (e.g., the Facebook “Like” button) to enable you to easily share information with others. When you visit a Website, the operator of the social plugin may be able to place a cookie on your computer, enabling that operator to recognize individuals who have previously visited such Website. If you have previously logged into the associated social media website (e.g., Facebook) before browsing on a Website, the social plugin allows that social media website to receive information about your visit to particular pages on such Website. The social plugin may collect this information for any such visitors who have logged into social networks, whether or not they specifically interact with the plugin on a Website (e.g., by clicking “Like” or “Share”). The social plugin may also allow the social media website to share information about your activities on a Website with other users of their social media website. For further details about the information shared via a particular social media plugin, you should refer to that social media site’s privacy statement.
(d) Third Party Service Providers. Third party service providers may use such technologies with the Websites and may collect information about you, including Personal Information, without notice to you.
(e) Do Not Track Signals. Some web browsers may transmit “do not track” signals. At this time, we do not take steps to respond to such signals. You can manage your cookie preferences using your own browser settings to accept or block some or all cookies, or to receive notice so you can consent to cookies. If you block all cookies, some features of the Websites may be unavailable to you.
4. How do we use the Information Collected?
(a) Use of Information by Us. We may use your Personal Information and/or Usage Information:
- to respond to your inquiries and personalize your experience on the Websites (your information helps us to better respond to your individual needs);
- to improve the Websites (we continually strive to improve the Websites based on the information and feedback we receive from you);
- to provide you with information about services, changes to the Websites and/or our policies, and other information you may request;
- to enable you to participate in a variety of the Websites’ features;
- to process your registration with the Websites, including verifying your information is active and valid;
- for internal business purposes;
- to contact you in connection with your use of the Websites; and
Where you have provided us with Personal Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this Personal Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.
In addition, Usage Information we collect may be used for a number of purposes, such as system administration, to help us understand the demographics of visitors to the Websites, to enhance the performance and usefulness of the Websites, and to audit use of the Websites.
However, we will not sell or rent your Personal Information to anyone.
(b) Sharing of Personal Information With Third Parties. We may share Personal Information with third parties under various circumstances, including as described in more detail below. We do not, however, share your Personal Information with third parties for those third parties’ marketing purposes.
- Third Parties Providing Services On Our Behalf. We may share Personal Information with third parties who perform services on our behalf. This includes, without limitation, third parties that: host a Website; operate certain functions or features of a Website; archive data; send communications; analyze data; and provide other services or functions on our behalf, including business analytics, customer service, marketing, employment or hiring-related activities, data security functions, and fraud prevention.
- Affiliates, Business Transfers and Corporate Changes. We reserve the right to share Personal Information with our affiliates and in connection with a corporate divestiture, merger, consolidation, or restructuring, the sale of substantially all of our ownership interests and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process or in the event of bankruptcy, insolvency or dissolution.
- Administrative and Legal Reasons. We may also disclose and transfer Personal Information to third parties: (i) in the event we are required to do so to satisfy an applicable law or regulation, to respond to a court order, subpoena, discovery request, or other legal process, or if in our good faith opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an audit, investigation or other inquiry; (iii) to verify or enforce compliance with other agreements or policies governing a Website, or applicable laws, rules, and regulations; or (iv) whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of our firm, clients or a Website, its users or other third parties.
- Sharing of Non-Personal Information. We may also share non-personally identifiable information, such as Usage Information, aggregated user statistics, and anonymous information derived from Personal Information (e.g., de-identified user information), with third parties for any purpose.
5. Third Party Content and Links on the Websites. A Website may contain content that is supplied by third parties and those third parties may collectUsage Information when pages from such Website are served to you. In addition, when you are on a Website you may be directed to other sites operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices used by any of these third parties or their sites and they may be tracking you across multiple sites and sharing the results with us and/or others. We encourage you to note when you leave a Website and to review the third party privacy policies of all third party locations and exercise caution in connection with them.
7. Your Access To and Control Over Personal Information. You are responsible for maintaining the accuracy of theinformation you submit to us. A Website may allow you to review, modify, correct or update Personal Information you have provided through such Website or otherwise, and you may provide updates and changes by contacting us at email@example.com. At any time, you may also contact us at firstname.lastname@example.org to ask that we remove your name, contact information, and email address from the lists we use to send our mailings and contact you. We will make good faith efforts to make any requested changes or removals in our then active databases as soon as reasonably practicable. Further note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information, information that you remove may persist internally for our administrative purposes. Note that if you request us to delete or remove any data, you may be unable to use certain features of a Website or to communicate with us via such Website. Further, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
8. Notice to California Residents – Your California Privacy Rights. Under California’s “Shine the Light” law (California Civil Code Section 1798.83), California residents have the right to receive information about third parties with whom we have shared information about you for their marketing purposes during the previous calendar year and a description of the categories of personal information shared. To make such a request, please contact us at the e-mail or mailing address listed above, with “Request for California Privacy Information” in the subject line or written request. Requests may be made only once a year and are free of charge.
10. Children. The Websites donot offer products or services to children and we do not knowingly collect any Personal Information from children younger than the age of thirteen (13). We will delete any Personal Information collected that we later determine to be from a person younger than the age of thirteen (13).
12. Contact Us; Questions.
13. Do You Need Extra Help?
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