Effective Date: July 1, 2021
Acknowledgement and Consent
Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).
We collect only the following types of PII:
|Specific Items of Personal Information|
|Identifiers||first and last name, user name (which may include first and last name), email address, postal address, unique personal identifier, e.g.: customer/account name or number, phone number|
|Internet or other electronic network activity||Internet Protocol (or IP) address, protocol, and sequence information;cookiesbrowser language and type;domain name system requests;material and pages viewed;time and date of access to the Services;number of bytes transferred;number of clicks per visit;operating system and platform, device type and device identifiers;MAC address, device ID / UDID, or similar device-specific code|
Individuals under the Age of 18
We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.
How We Collect Personal Information and from What Sources
Information You Provide Us. The Personal Information we collect through our Website, or from our distributors, resellers, representatives, business partners, or service providers may be obtained as part of the following:
- Information that you provide by filling in webforms on our Website. This includes information provided when creating an online account, purchasing our Products or Services, subscribing to our e-newsletters or other communications, requesting information from us, submitting or posting material (where permitted) on our forums, or interacting with customer support or service, report a problem with our Website, Products, or Services, or otherwise communicating with us.
- Records and copies of your correspondence (including email addresses), if you contact us
- Registering for an event
- When communicating with customer service/support
- On mobile applications (parent, subsidiary and affiliate brands)
- Responding to employment opportunities
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including the following.
- Details of your visits to our Website, including, but not limited to, traffic data, logs, and other communication data and the resources that you access and use on the Website. We also collect information about your activities during your visit in order to personalize your website experience, such as recording your preferences and settings, and to collect statistics to help us improve and further develop our websites, products and services.
- Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.
- Behavioral Tracking
- We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
The information we collect automatically is statistical data and may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver better and more personalized Products and Services, including, but not limited to, by enabling us to: estimate our audience/visitor size and usage patterns, store information about your preferences, allowing us to customize and improve our Website, speed up your searches, and/or, recognize you when you return to our Website.
The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.
Cookies (or browser cookies)
A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer or mobile device (Internet Explorer, Firefox, Safari or Google Chrome).
Different types of cookies which have different purposes are used on our Website.
These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.
These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Website pages from their site and whether your visit has led to the use or purchase of a Product or Service from our Website, including the references for the Product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.
These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
It is possible that you will come across third-party cookies on some pages of sites that are not under our control.
Local Storage Cookies. Certain features of our Website may use local stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.
GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
IP Address. Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.
How We Use Your Information
- We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:
|Choose One for Each Row|
|Uses of Personal Information||Keep||Delete|
|To present our Website and Mobile App and its contents to you.||☒||☐|
|To provide you with information and respond to your questions on Products or Services that you request from us and information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you.||☒||☐|
|To provide you with the Products, Services, or information that you have requested.||☒||☐|
|To process transaction payments, including, but not limited to, product and/or service fees, subscription fees, registration fees, and payments, refunds and reimbursements for any products or services that you choose to purchase from us (though we do not receive your credit or debit card number).||☒||☐|
|To provide you with notices about your account, including expiration and renewal notices.||☒||☐|
|To notify you about information regarding or changes to our Website, our policies, terms, or any Products or Services we offer or provide, or regarding your account.||☒||☐|
|To process your account application and any changes to your account information.||☒||☐|
|To process Personal Information or other information that you submit through to us.||☒||☐|
|To allow you to participate in interactive features on our Website.||☒||☐|
|To contact you about our own and third-parties’ products and services that may be of interest to you.||☒||☐|
|To provide access to restricted parts of our Website, e.g., areas accessible if you have a user account.||☒||☐|
|To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends, or measuring demographics and interests.||☒||☐|
|For internal purposes, such as Website and system administration or internal audits and reviews.||☒||☐|
|For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.||☒||☐|
|To operate, maintain, and provide to you the features and functionality of the Services.||☒||☐|
|To provide statistics about the usage levels of the Website and other related information to our service providers.||☒||☐|
|To notify you of data privacy incidents or provide you with legally required information.||☒||☐|
|To fulfill any other purpose for which you provide Personal Information.||☒||☐|
|In any other way we may describe and for which we obtain your consent when you provide the information and you give your consent.||☒||☐|
How We Share Your Personal Information
We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more the following purposes:
|Who We May Disclose Personal Information to and for What Purpose||Keep||Delete|
|Technology providers who assist in the development and management of our Website or our Mobile App||☐||☒|
|Identity management providers for authentication purposes||☒||☐|
|Legal and compliance consultants, such as external counsel, external auditors, or tax consultants||☐||☒|
|Payment solution providers for the secure processing of payments you provide to us||☒||☐|
Disclosures to Service Providers: We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, data analysis, credit checks, screening checks, collection services, marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, fulfilling orders, sending postal mail and email, removing repetitive information from customer lists, providing search results and links (including paid listings and links).. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).
We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
SALE/DISCLOSURE OF PERSONAL INFORMATION
No Sale of Personal Information. We do not disclose or share your Personal Information with any third parties for which we receive any monetary or other valuable consideration. In other words, we do not sell your Personal Information, period.
Your Consent to Disclosure/Transfer/Sale of Your Personal Information: You consent to our disclosure of your Personal Information, De-Identified Personal Information, and other information you provide to us (“Transferred Information”) to a potential or actual buyer or acquirer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) as part of a Transfer, of any or all of our rights, in whole or in part, in or to Transferred Information and your consents, with or without notice to you and without your further consent. We cannot make any representations regarding the use or transfer of Transferred Information that we may have in the c of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. By providing any Personal Information, you expressly agree and consent to the use and/or transfer of Transferred Information or other information in connection with a Transfer. Furthermore, except as required by law, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the Transferred Information that is disclosed to us.
Data Transfer/Access Outside of the United States
We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the UK, European Economic Area (“EEA”), or Switzerland, we provide protection for the transfer of Personal Information to countries outside of the UK, EEA, or Switzerland through intercompany agreements based on the Standard Contractual Clauses. We may also need to transfer your information to other group companies or service providers in countries outside the EEA. This may happen if our servers or suppliers and service providers are based outside the UK, EEA, or Switzerland, or if you use our services and products while visiting countries outside this area.
If you are a resident of a country other than the United States, you acknowledge and consent to our collecting, transmitting, processing, transferring, and storing your Personal Information out of the country in which you reside.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of Service Providers who have special access rights to our systems, and who are required to keep the information confidential. Our Website, software, and Mobile App software are scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website, software, and Mobile App safe.
Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information. We do not collect or store full credit card numbers.
The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or mobile device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given up those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.
The safety and security of platform login information also depends on you. Subscriber is responsible for keeping confidential all login credentials to our Website, platform or systems (“System”) to which Subscriber is provided access. Subscriber agrees to not disclose any such login credentials with any third party. Subscriber shall have its users authorized to access such System limit access to its computers, devices, and browsers by signing off after an authorized user has finished accessing your account. If Subscriber becomes aware of any potential compromise of a user’s login credentials, Subscriber shall immediately change the relevant password. Subscriber shall promptly deauthorize any of Subscriber’s users for whom access to the System is no longer authorized. Subscriber does hereby release and forever discharge us and our affiliates, subsidiaries, parents, officers, directors, employees, successors and assigns and contractors (collectively, “Company’s Group”), and Subscriber will indemnify, defend and hold Company’s Group harmless, from any and all past, current, and future liability, claims, demands, damages, losses, fines, penalties, assessments, private rights of action, or other actions, of whatever kind of nature, either in law or equity, as well as costs (including, but not limited to, attorneys’ fees and costs), which arise from any failure of Subscriber or its service providers to maintain the security of Subscriber’s email or other accounts which results in unauthorized access by a third party to such account and the transfer of funds by us in reliance of instructions purporting to originate from Subscriber.
The safety and security of platform login information also depends on you. You are responsible for keeping confidential all login credentials to our Website to which you are provided access. You agree to not disclose any such login credentials with any third party. If you become aware of any potential compromise of your login credentials, you must immediately change the relevant password. You agree to and do hereby release and forever discharge us and our affiliates, subsidiaries, parents, officers, directors, employees, successors and assigns and contractors (collectively, “Company’s Group”), and you will indemnify, defend and hold Company’s Group harmless, from any and all past, current, and future liability, claims, demands, damages, losses, fines, penalties, assessments, private rights of action, or other actions, of whatever kind of nature, either in law or equity, as well as costs (including, but not limited to, attorneys’ fees and costs), which arise from any failure of you to maintain the security of your email or other accounts which results in unauthorized access by a third party to such account and the transfer of funds by us in reliance of instructions purporting to originate from you.
The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will retain your Personal Information for as long as your account is active, or as long as you are a registered account holder or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
We may retain De-Identified Personal Information for as long as we deem appropriate.
We retain your information after you request such deletion for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. For example, if we process your payments, we will retain this data for longer periods of time as required for legal, regulatory, tax, or accounting purposes. Additional examples of specific reasons we would retain some data for longer periods of time include:
- Our contractual and business relationships with you.
- Security, fraud and abuse prevention – i.e., to protect you, other people, and us from fraud, abuse, and unauthorized access.
- Financial recordkeeping – when you make a payment to us we are often required to retain this information for long period of time for purposes of accounting, dispute investigation and resolution, and compliance with tax, anti-money laundering, and other financial regulations.
- Complying with legal or regulatory requirements – to meet any applicable law, regulation, legal process, or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.
- Direct communications with us – if you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.
Even if you delete your account, keep in mind that the deletion by our Service Providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. We may retain De-Identified Personal Information for as long as we deem appropriate.
What Information You Can Access, Change, or Delete
Through your user account settings page, you may access and, in some cases, edit, or delete certain information you have provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Products, Website, Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.
Notices; Opting Out
By providing us with your email address (including by “following,” “liking,” linking your account to our Website or Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding the Service, the Website, the Mobile App, your Personal Information, or any aspect of our relationship, to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.
GDPR: The Follow Provisions Apply Only to Citizens and Residents of the United Kingdom, EEA, and Switzerland
Our Legal Basis for Processing Personal Data (UK, EEA, and Swiss Visitors Only)
If you are a visitor using our Website from the UK, EEA or Switzerland, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we need the Personal Data to perform Services for you for which you have contracted with us, or where the processing is in our legitimate interests or rely upon your consent where we are legally required to do so and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
Collection and processing is necessary for the purposes of our legitimate interests: Art. 6 (1)f GDPR
The collection and processing of your personal information may be necessary for the purposes of our legitimate interests. Such legitimate interest purposes may include:
- fraud prevention
- ensuring network and information security
- when we are complying with legal obligations
- processing employee or visitor, member, attendee, or registrant data
- performing the function or service you requested of us
- providing our services and their functionality to you where such processing is necessary for the purposes of the legitimate interests pursued by us or by our service providers related to the services
- direct marketing
- the relevant and appropriate relationship we have with you
- analytics, e.g., assess the number of visitors, page views, use of the Site, etc., in order to understand how our Site and services are being used, to optimize the Site and/or future communications, and to develop new services and Site features
- updating your information and preferences
- offering and improving our services
Your Data Rights Under GDPR
If you are subject to GDPR, your rights include the following:
- The right to access – Upon request, we will confirm any processing of your Personal Information and, and provide you with a copy of that Personal Information in an acceptable machine-readable format.
- The right to rectification – You have the right to have us correct any inaccurate Personal Information or to have us complete any incomplete Personal Information.
- The right to erasure – You may ask us to delete or remove your Personal Information and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion).
- The right to restrict processing – You have the right to ask us to suppress the processing of your Personal Information but we may still store your Personal Information. See below for more information.
- The right to object to processing – You have the right to object to your Personal Information used in the following manners: (a) processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); (b) direct marketing (including profiling); and, (c) processing for purposes of scientific/historical research and statistics. See below for more information.
- The right to data portability – You have the right to obtain your Personal Information from us that you consented to give us or that is necessary to perform fulfillment of member benefits with you. We will give you your Personal Information in a structured, commonly used and machine-readable format.
- The right to complain to a supervisory authority – You have the right to file a complaint with a supervisory authority, in particular in the European member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of Personal Information relating to you infringes upon your rights.
- The right to withdraw consent – If we are processing your Personal Information based on your consent to do so, you may withdraw that consent at any time.