1. Information We Collect
When you use the Site, we collect the following types of Information:
a. Personal Data
Personal Information means any information associated with or used to identify a specific person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, phone number, email address, and mailing address. Personal Information can also include an identification number, location information, and/or an online identifier.
b. Usage Data
Usage Data does not identify you, but provides insights regarding your use of the Site(s) or Service(s). For example, we collect information about your use of the Site, including but not limited to, Internet connections, computer equipment, web browsers, the pages or features of our Site to which you browsed and the time spent on those pages or features, the frequency with which our Site is used by a user, search terms, the links on our Site that a user clicked on or used, related timestamps, and sites visited before and after using or accessing our Site.
Generally, we do not consider Usage Data as Personal Information because Usage Data by itself usually does not identify an individual. Personal Information and Usage Data may be linked together. Different types of Usage Data also may be linked together and, once linked, may identify an individual person. Some Usage Data may be Personal Information under applicable law.
We use automated information collection tools such as cookies and web beacons to collect certain types of Usage Data. You can set your browser to reject cookies, but that may limit your use of some convenience features on the Sites.
Cookies are small computer files sent to or accessed from your web browser or your computer’s or tablet’s hard drive that contain information about your computer, such as a user ID, user settings, browsing history, and activities conducted while accessing the Site. Cookies are not themselves personally identifiable. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. Cookies help us improve the Services and our Site by enabling us to analyze technical and navigational information about the Site and helping to detect and prevent fraud or malicious behavior. Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org.
We also use other cookies and other data collection tools (such as web beacons and server logs), which we collectively refer to as “data collection tools,” to help improve your experience with the Site. The Services also may use data collection tools to collect information from the device used to access the Services, such as operating system type, browser type, domain and other system settings, as well as the operating system used and the country and time zone in which the computer or device is located.
c. Location Data
Location Data is a category of Personal Information collected about the location of a mobile device or computer, including: the location of the mobile device or computer used to access the Services derived from GPS or WiFi use; the IP address of the mobile device or computer or internet service used to access the Services, other information made available by a user or others that indicates the current or prior location of the user.
You may be given the option to receive push notifications while using our Services. In order to serve push notifications, we may need to collect your IP address and a persistent identifier from your device. You can turn off push notifications in your device settings.
If you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated with our Site, we may receive your Personal Data and other information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts through those services. For example, some social networking services allow you to push content from our Site to your contacts or to pull information about your contacts so you can connect with them on or through our Site. Some social networking services also will facilitate registration or enhance or personalize your experience on our Site. Your decision to use a social networking service in connection with our Site is voluntary. However, you should make sure you are comfortable with the information your third-party social networking services may make available by reviewing privacy policies of those providers and/or modifying your privacy settings directly with those networking sites/services.
2. When Information is Collected
- Use the Services. We collect Personal Information from you when you create an account to use one of the Services, contact us for help or information or otherwise voluntarily provide your Personal Information. We collect the information and content that you submit to us, such as when you enter comments or questions.
- Usage Data. We also automatically collect Usage Data when you interact with the Site and related Services.
3. Use of Information
Once information is collected, we use the information for any of the following specific purposes:
- For Legitimate Interests. We use Usage Data collected by clickstream information collection, web pixels, and cookies to store your preferences, improve Site navigation, make personalized features and other services available to you, to generate statistical information, monitor and analyze user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve the content and the Services, materials, and other content that we describe or make available through the Site, and otherwise help administer and improve the Site.
- For the purpose for which you provided the information and/or your express consent. For example, if you share your name and contact information to ask a question about our Services or to request information, we will use that Personal Information to respond to your inquiry. In addition, we may, from time to time, invite you to participate in online surveys. The information requested in these surveys may include, but is not limited to, your opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent regarding products, events, and Services. The information collected by these surveys is used to research market trends, company growth, community needs, etc. Your input will help us to improve customer experience and shape development of our products and Services.
- To provide, support, personalize, and develop our services. We may conduct aggregate or research analysis and develop our business intelligence that helps us to enhance, improve, evaluate, operate, protect, make informed decisions about, and report on the performance of our Services. We may use certain Usage Data, for example, to help us develop our new products and Services and improve our existing products and Services.
- To communicate. Communications from us may include promotional materials, notifications to changes to relevant agreements, policies, or other terms, and to enforce such terms, if appropriate, and online surveys. If you prefer to not receive promotional emails or other communications, you can notify us or unsubscribe, as applicable.
- To work with our service providers. Third parties may perform certain business functions and services on our behalf.
- To comply with legal obligations. To prevent or investigate fraud, or for risk management purposes, and to help maintain the safety, security, and integrity of our Site and Services, databases, and other technology assets, and business; court orders, or in order to exercise any legal claim or to defend against any legal claim.
- For business reasons. Information may be needed to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the Personal Information held by us about our consumers is among the assets transferred.
4. How We Share and Disclose Information
We may share Personal Information with the following parties:
- Service providers that help us administer and provide the Services (for example, a web hosting company whose services we use to host our platform). These third party services providers have access to your Personal Information only for the purpose of performing services on our behalf under contractual obligations requiring such service providers to follow appropriate privacy policies and practices and to prohibit them from using your Personal Information except for the express purpose for which it is provided.
- In aggregated form, we may share Personal Information or Usage Data in an aggregated form—that is, in a statistical or summary form that does not include any personal identifiers—with third parties in order to discover and reveal trends about how users like you interact with our Services and the Site;
- As we believe necessary (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third party has been posted or transmitted without their consent or as a form of harassment and (VI) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence; and
5. Information Security
We take reasonable steps online and offline to safeguard the Personal Information that you provide to us. Nonetheless, it is common knowledge that transmission of information via the Internet is not wholly secure, and we cannot guarantee the security of your Personal Information, or any other information, transmitted to or through our Site or any of our Services, or be responsible for the theft, destruction, or inadvertent disclosure thereof. Any transmission of Personal Information, or other information, is at your own risk. By using our Services, you acknowledge and accept these risks. It is your responsibility to safeguard any passwords, user IDs, or any other special access features associated with your use of the Services and the Sites. Users of the Services are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of any of Services or on the Sites. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of the Services are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.
If you have any questions about security as part of our Services or on or through the Sites, or if you become aware of any unauthorized use of an account, loss of your account credentials, or suspect a security breach. If our security system is breached, we will notify you of the breach to the extent required under applicable law.
6. Information Retention
7. Links to Third Party Sites
8. Children’s Privacy
The Services are not intended for use by children. We do not knowingly sell products or Services for purchase by anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Information from anyone under the age of thirteen (13) without verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service(s).
10. How to Contact Us
By telephone: +1.780.497.0704
11. Rights to Personal Information
If you are a resident of the European Economic Area (EEA) (“Data Subject”), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Information. You may request to change, edit, update, or delete the information that you provided when you set up your account through our Service(s) through your account settings. You may also request the deletion of this information. If you access our Services from certain jurisdictions, such as the EEA, you may have additional rights and options with regard to accessing, reviewing, correcting, and updating your Personal Information, as well as how we use and disclose your Personal Information.
As a Data Subject, you have the right to request access to your Personal Information as it exists in our records. You also have the right to rectification, correction, or amendment of your Personal Information if it is inaccurate or incomplete. You may also have the right to erasure of your Personal Information; however, this is not always possible due to legal requirements and exceptions may apply.
A Data Subject may have the right to object to the processing of his or her Personal Information, for example, due to his or her particular situation, for direct marketing uses, or for scientific or historical research. In certain circumstances, Data Subjects may have the right to obtain a restriction on our processing of their Personal Information, in which case such Personal Information will, with the exception of storage, only be processed with the Data Subject’s consent or in circumstances such as our exercise or defense of legal claims or the protection of another person. Data Subjects may also have the right to request that we provide data portability for their Personal Information via a copy of the data in a commonly-used format and/or transfer their Personal Information directly to another data controller (where technically feasible). Exceptions to these rights may apply, for example, if the processing is necessary for a task carried out in the public interest. Finally, if a Data Subject has given his or her consent to our processing of his or her Personal Information for certain purposes, he or she has the right to withdraw consent to such use at any time by contacting us via the contact information below.
If you are not satisfied with how we manage your Personal Information, you have the right to make a complaint to a data protection regulator.
In some instances, we may need to transfer your Personal Information outside the EEA. In all cases, we take steps to ensure that transfers of such Personal Information are performed in accordance with applicable law and carefully managed to protect your privacy rights and interests. Transfers are limited to countries that are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. Therefore, where we transfer your Personal Information outside our corporate affiliates or to third parties who help provide our products and services, we obtain contractual commitments to protect your Personal Information under Data Protection Agreements and pursuant to Standard Contractual Clauses. Some of these assurances are well recognized certification schemes or such as the EU – US Privacy Shield for the protection of Personal Information transferred from within the EU to the United States. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before disclosing any Personal Information.
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we disclosed your Personal Information for a business purpose, a separate list identifying the Personal Information categories that each category of recipient obtained.
1. Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, unless an exception applies, we will delete (and direct our service providers to delete) your Personal Information from our records.
2. How to Make a Request
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by calling us at +1.780.497.0704
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. We may require proof from the agent that you have provided the authorized agent written permission to do so, and we may require that you verify your own identity directly with us. If you have provided the agent with power of attorney, that may be sufficient.
You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We verify requests by matching information you provide to information that we maintain in our records. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
3. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, up to an additional forty-five (45) days, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
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