Effective date: October 12, 2020
Irrespective of which country you reside in or supply information from, you authorize us to use your information in the United States and any other country where we may operate. We control and/or operate the Platform from offices in the United States of America. We do not represent that materials on the Platform are appropriate or available for use in other locations. Persons who choose to access this Platform from other locations do so on their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent local laws are applicable.
What types of Personal Information do we collect?
Personal Information you provide to us:
We do not collect or store any personal information on our servers.
Personal Information collected automatically:
In order to understand how our Platform is being used and to make it better, we also automatically receive, store, and log certain types of technical information whenever you interact with our Platform. Information of this sort includes:
• Technical information about a user’s browser and mobile device.
• Usage information such as the pages users request, searches they conduct, emails they open, and features they interact with.
• IP address, tokens, cookies, and device identifiers.
• Crashes and error reports.
How do we share your Technical Information?
We will not disclose Technical Information of our users to any persons or entities outside of our company, nor lease, license, rent, transfer, disclose, sell, disseminate or otherwise grant access to such information unless:;
• We believe in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• We are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, at which point users’ Personal Information may be sold or transferred as part of that transaction;
• It is to any other third party with a user’s prior consent to do so;
• We receive a request in connection with a judicial, governmental or legal inquiry, investigation, order, or proceeding;
• It is reasonably necessary to enforce our other Platform terms and conditions, this Policy, or any other legal agreements we enter with our users;
• It is required to detect, prevent, or otherwise address fraud, abuse, misuse, potential violations of law (or rule/regulation), and/or security or technical issues; or
• It is required or reasonably necessary to protect against imminent harm to the rights, property or safety of us, our users, employees, minors, members of the public and/or our Platform.
We may also disclose information about you to our auditors or legal advisors in conjunction with accessing our disclosure obligations and/or rights under this Policy.
What do we do to keep your Technical Information secure?
We take commercially reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of your Personal Information that you share and we collect and store. These security measures include practices such as:
• Using secure socket layer (“SSL”) technology.
• Using regular Malware scanning.
• Internal reviews of our data collection practices and platforms.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your technical information: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Platform cannot be guaranteed and you transmit such information at your own risk; and (c) any such information and data may be viewed or tampered with in transit by a third party.
What can you do to protect your technical Information?
While we are committed to taking all reasonable precautions to protect your Personal Information, there are steps you can take as well when using online services, such as ours:
• Use only secure websites when disclosing information.
• Create strong passwords and use them wisely (e.g. don’t use the same password for us that you use for your bank, for example).
• Never respond to unsolicited requests for social security number or financial information.
• Do not disclose passwords to the Platform or Account Information to any other person.
• If logins are required for site access, be sure to sign off when finished using a shared computer.
• Be careful about disclosing personal information such as name, address, or e-mail address in discussion forums or other public areas of the sites. Any information disclosed in public user communication, can be collected and used by third parties and may result in unsolicited messages from third parties.
• Only upload photos and other public information if it is appropriate for such information to become public under the circumstances.
Links to other sites
Fair Information Practice Principles
The FTC created the Fair Information Practice Principles as a result of the Commission’s inquiry into the manner in which online entities collect and use personal information and safeguards to ensure that such practices are fair and provide adequate privacy protection. We take our own self-regulation very seriously and support your rights as a consumer to causes of action against disreputable and unprincipled data collectors and users. Consistent with the FTC’s Principles, and in the event of a data breach, we will do the following:
• Notify users by posting a notice on our Platform within 5 business day(s)
- Notify all clients registered on our Platform for our services via email within 5 business day(s)
California Residents – California Civil Code Section 1798.83
California residents have the right to receive: a) information identifying any third party company(ies) to whom we may have disclosed (within the previous calendar year) personal information pertaining to you and your family for that company’s direct marketing purposes; and b) a description of the categories of personal information disclosed. If you are a California resident and wish to obtain such information, submit a request to our email address found at the end of this Policy with “Request for California Privacy Information” as the subject line and in the body of your message. Please be aware that not all information sharing is covered by requirements and only information on covered sharing will be included in our response.
Children’s Online Privacy Protection
Our Platform is not designed or intended for use by children under 13. If you are under 18, you should use the Platform and Services only with involvement of a parent or guardian. Children under 13 may not submit any personally identifiable information to us, and if we discover that we have inadvertently gathered any such information from a child under 13, we will take appropriate steps to delete it. If you are the parent or guardian of a person under the age of 13 who has provided personally identifiable information to us, please inform us by contacting us at [INSERT SUPPORT EMAIL i.e. privacy@___.com] and we will remove such information from our database. If you are concerned about your children’s use of the Platform, you may use web-filtering technology to supervise or limit access to the Platform. Visit www.OnGuardOnline.gov for tips from the Federal Trade Commission on protecting kids’ privacy online.
How we comply with the CAN-SPAM Act
The CAN-SPAM Act is US legislation that regulates commercial emails with strict penalties for those who send emails with materially false or misleading content or fail to provide recipients of commercial emails with an opportunity to decline them. We only collect your Personal Information for the purposes, which we outlined in this Policy, and we will do the following:
- NOT use false or misleading information in the subject line or body of our emails.
- Identify messages as advertisements by using the label “advertisement” in a conspicuous manner.
- Monitor third party email marketing services, if one is used.
- Label any adult content in the subject line of our emails as “ADULT”.
- Provide accurate “From” fields so that users know who is sending the email.
- Provide visible and operable unsubscribe mechanisms in all of our emails.
- Include our physical address in the body of our emails.
- Honor any opt-out requests to our emails within 10 business days.
- Refrain from using harvested email addresses.
You may contact us at the email below if you would like to unsubscribe from our marketing communications at any time.
What will happen if we change this Policy?
We may update this Policy from time to time. Use of information we collect now is subject to the Policy in effect at the time such information is used. This is how you will be notified if we make any material changes to our Policy:
• We will post an updated Policy with a more recent effective date in the header.
How can you contact us?
• By email at firstname.lastname@example.org