This policy describes the type of information we collect from you and/or that you may provide us when you visit and/or use this website and/or any of our mobile applications and related websites (individually or collectively, “Sites”). “You/your/user(s)” means you as a user of our Sites.
We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access.
Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Sites, any transmission of Personal Information is at your own risk. We cannot guarantee that such information will not be intercepted by third parties, and we will not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third-party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for unauthorized circumvention of any privacy settings or security measures contained on the Sites.
INFORMATION WE COLLECT
We collect various information that identifies you as a person (“Personal Information”) in two ways. First, we collect Personal Information that you provide to us. Second, we collect certain Automated Information that may contain Personal Information when you use our Sites.
Personal Information You Provide to Us
The Personal Information you provide to us is generally:
- contact details including name, email, address, and telephone number
- employment and education history and other information that you provide to us if you apply for employment with us through our Sites
We collect Personal Information directly from you when you provide it to us. This typically occurs when you:
- Sign up for any of our email lists
- Send us an inquiry through our Sites
We also collect information, some of which may be Personal Information, through automated means when you visit our Sites (“Automated Information”) such as:
- the IP address of the device you use to connect to the internet (which may include information about your geographic location)
- the unique identifiers of your device
- your browser characteristics
- your device characteristics
- your operating system
- information on actions taken by you on our Sites
- dates and times of your visits to our Sites
- the pages you accessed on our Sites
We collect Automated Information automatically as you navigate through our Sites as explained further below.
We may collect information, which may include certain Personal Information data such as your IP address, from your browser when you use our Sites. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include your (a) IP-address; (b) unique cookie identifier, cookie information and information on whether your device has software to access certain features; (c) unique device identifier and device type; (d) domain, browser type and language; (e) operating system and system settings; (f) country and time zone; (g) information about your interaction with our Sites such as click behavior; and (h) access times and referring URLs.
Most web browsers automatically accept cookies. If you do not wish to have cookies on your system, you can set your browser to refuse them. Please review the specific instructions from your browser in order to do this. However, please note that not accepting cookies may make certain features of our Sites unavailable or difficult to view or use.
In some of our email messages we may use a “click-through URL” linked to content on our Sites. When you click one of these URLs, you will pass through our web server before arriving at the destination web page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our Sites. If you prefer not to be tracked through our emails, simply avoid clicking text or graphic links in the email.
HOW WE USE THE INFORMATION WE COLLECT
Most commonly we will use your Personal Information in the following circumstances:
- Where you have asked us to do so, or consented to us doing so;
- Where we need to do so in order to perform a contract we have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation.
SHARING PERSONAL INFORMATION WITH THIRD PARTIES
We are committed to maintaining your trust and we want you to understand when and with whom we may share Personal Information and information collected about you. We do not share your Personal Information with any third parties except as set forth herein.
We may disclose your Personal Information to outside individuals and/or companies that help us bring you the services we offer and to create, operate, and maintain our Sites. For example, we may work with third parties to: (a) manage a database of personal information; (b) assist us in distributing e-mails; (c) assist us with data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; (g) provide other services designed to assist us in developing and running our Sites and maximizing our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us.
If we seek investors or go through a business transition, including but not limited to, a merger, acquisition by another company, or a sale of all or a portion of our assets, your Personal Information may be shared as part of the negotiation of the transaction and will likely be among the assets transferred in the event of a sale or partial sale of our assets.
We may disclose your Personal Information when legally required to do so, to cooperate with law enforcement investigations or other legal proceedings, to protect against misuse or unauthorized use of the Website, to limit our legal liability and protect our rights or to protect the rights, property or safety of Users of the Sites or the public.
TARGETED ADVERTISING AND REMARKETING
We do not use any Personal Information you share with us through the Sites for targeted advertising and/or remarketing.
If you use a third-party website or application (e.g. Linkedin, Instagram, Twitter) to access our Sites, your activities on such third-party sites or apps are governed by the privacy practices of those sites or apps. The privacy policies of other sites and apps may differ significantly from ours, and we have no control over the operation of those sites or apps or the manner in which the collect, store, or process data.
YOUR CHOICES ABOUT HOW WE USE YOUR INFORMATION AND OPTING OUT
There are ways by which you can control how your Personal Information is used.
If you do not wish to receive our informational emails, please do not opt-in to receiving emails from us. If you do opt-in to receive any of our emails, you may opt-out by clicking on the “unsubscribe” link found in emails we send to you. Please allow up to ten (10) business days for changes to your email preferences to take effect. During that time, you may continue to receive email communications from us that were already in process. Opting out of receiving our communications will not affect your receipt of service-related communications, such as if you request information from us, or if we have a data breach, or other such communications for which we have a legal obligation to inform you and/or to prevent fraud or harm to our Sites, our business, and/or third parties
DISCLOSURE FOR LEGAL PURPOSES
You hereby authorize us to disclose any of your Personal Information pursuant to judicial and administrative proceedings and to law enforcement or government agencies if we are legally required to do so. You also authorize us to disclose Personal Information if we believe the disclosure is necessary or appropriate in the event of an investigation of improper or illegal conduct in connection with the Sites, such as fraud, misrepresentation, intellectual property infringement, or other activity that may put us at risk for liability.
NOTICE TO CALIFORNIA CONSUMERS
If you are a resident of California, please see below for specific provisions that apply to you.
We do not knowingly permit persons under 18 years of age to use the Sites, and we do not knowingly collect, use or disclose Personal Information from anyone under 18 years of age. If we determine upon collection of Personal Information that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian's consent. If we become aware that we have unknowingly collected Personal Information from a child under the age of 18, we will make reasonable efforts to delete such information from our records.
Please do not send us any confidential information through our Sites. Any unsolicited information, materials, suggestions, ideas or comments sent to us through our Sites will be considered non-confidential, and by submitting the same to us, you are giving us the absolute right to use, modify, reproduce, transmit, display and distribute the information for any purpose whatsoever.
If you have any questions about your privacy or security at the Sites, or wish to update your Personal Information, please send an email to firstname.lastname@example.org.
DATE LAST MODIFIED: January 1, 2020
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
The following applies to you only if you are a California resident.
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. We do not share any Personal Information with third parties or corporate affiliates for direct marketing purposes.
Please note the following:
- We will add a link to this Privacy Notice on our home page, or at a minimum, on the first significant page after entering the Sites;
- Users are able to change their Personal Information by emailing us or by calling us;
- Some Internet browsers include the ability to transmit “Do Not Track” signals that give you control over the collection and use of web browsing information. Because uniform standards for “Do Not Track” signals have not yet been adopted, we do not process or respond to such signals in users’ web browsers at this time; and
- We allow the collection of users’ behavioral tracking by third parties for analytical purposes only.
Your Rights and Choices
The California Consumer Privacy Act (“CCPA”) provides consumers who are California residents with specific rights regarding their Personal Information.
Right to Know About Personal Information Collected, Disclosed, or Sold
As a California consumer, you have a right to request what Personal Information we collect, use, disclose, and sell.
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request as described below, we will disclose to you:
- The categories of Personal Information we collected about you
- The categories of the sources for the Personal Information we collected about you
- Our business or commercial purpose(s) for collecting or selling that Personal Information.
- The categories of third parties with whom we shared that Personal Information.
- The specific pieces of Personal information we collected about you
In addition, if we sold or disclosed your Personal Information for a business purpose, we will provide you with two separate lists disclosing:
- Disclosures for a business purpose, identifying the Personal Information categories disclosed that each category of recipient obtained
- Sales and/or disclosures for a commercial purpose, identifying the Personal Information categories that each category of each category of recipient obtained; and
Right to Request Deletion of Personal Information
As a California consumer, you have the right to request that we delete any or all of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request to delete your Personal Information if retaining the Personal Information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
- Debug products to identify and repair errors that impair existing intended functionality
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
- Comply with a legal obligation
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it
Right to Opt-Out of the Sale of Personal Information
As a California consumer, you have the right to opt-out of the sale of your Personal Information. We do not sell any Personal Information.
Right to Non-Discrimination if You Exercise any of Your Rights
As a California consumer, you have the right not to be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, if you exercise any of your California rights, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
How to Exercise Your Rights to Know and to Delete
To exercise your rights to know and/or to delete described above, please submit a verifiable consumer request to us by either:
- Calling us at 212.451.2300.
- Emailing us at email@example.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or your authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with your Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We will confirm receipt of your verifiable consumer request within ten (10) days and provide you with information about how we will process the request, describing our verification process and when you should expect a response. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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. Any disclosures we provide will only cover the 12-month period immediately preceding our receipt of your verifiable request. 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 useable and should allow you to transmit the information from one entity to another entity.
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.
Information We Collect From California Consumers
We collect Personal Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal Information does not include:
- Publicly available information that is lawfully made from federal, state, or local government records
- Deidentified or aggregated consumer information
- Medical information or protected health information governed by California and federal health information privacy laws
- Clinical trial information subject to the Federal Policy for the Protection of Human Subjects (the Common Rule)
- Personal information regulated by the Fair Credit Reporting Act (FCRA)
Within the last twelve (12) months, we have collected the following categories of Personal Information from California consumers through our Sites. Some of the categories may overlap with each other:
Category of Personal Information
A real name, postal address, unique personal or online identifier, Internet Protocol (IP) address, email address, telephone number
B. Personal Information described in the California Customer Records statute (Cal.Civ.Code §1798.80(e))
All of the Identifiers listed above, plus:
Signature, social security number, physical characteristics or description, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
C. Legally Protected Characteristics
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)
D. Commercial information
Records of services obtained or considered
E. Biometric information
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or similar network activity
Browsing history, search history, information regarding a consumer's interaction with a website, mobile application, or online advertisement
G. Geolocation data
Physical location or movements
H. Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information
I. Employment information
Professional or employment-related information
J. Education information, defined as nonpublic personally identifiable information under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g and 34 C.F.R. Part 99)
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records
K. Inferences drawn of other categories of Personal Information
A profile created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from our Users. For example, from information that you provide to us through our online forms, email, or other means
- Indirectly from activity on our Sites. For example, from website usage details collected automatically
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to respond to an inquiry
- To provide you with information or services that you request from us
- To provide you with email alerts and other notices concerning our services, events or news that may be of interest to you
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections
- To improve our Sites and present the contents to you
- For testing, research, and analysis
- As necessary or appropriate to protect the rights, property or safety of us, our Users, or others
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
- As described to you when collecting your Personal Information or as otherwise set forth in the California Consumer Privacy Act (CCPA)
- 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 Personal Information held by us is among the assets transferred
We do not disclose any Personal Information collected through our Sites for a commercial purpose.
We will not collect additional categories of Personal Information through our Sites or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice
Sharing Personal Information
We may disclose your Personal Information to a third party for a business and/or commercial purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a business purpose:
Category A: Identifiers.
Category D: Commercial information
Category F: Internet activity
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a commercial purpose:
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Our service providers
- Third parties to whom you authorize us to disclose your Personal Information in connection with services we provide to you
In the preceding twelve (12) months, we have not sold any Personal Information.
Grievances and Complaints
Under California Civil Code Section 1789.3, residents of California who use this Website are entitled to know that they may file grievances and complaints with: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210, or by email at firstname.lastname@example.org.
Contact for More Information
Date last updated: January 1, 2020.