Last updated: May 11, 2020
"Personal information," as used in this policy, is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. Such personal information includes an individual’s name, social security number, telephone number, or e-mail address, information about an individual’s activities, including about his or her activity on the Site or credit history, and demographic information, including date of birth, gender, address, geographic area, and preferences.
Personal information does not include aggregate or deidentified information or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that cannot be linked back to any particular individual(s) . We may use and disclose aggregate information, deidentified information and other non-personally identifiable information, for various purposes.
From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.
When you use the Service, some information may be automatically collected, such as your IP address, browser type, system type, the content and pages that you access on the Site, the "referring URL" (i.e., the page from which you navigated to the Site), the site you visit immediately after leaving the Site, as well as the time you spend on the Site.
We collect this information passively using technologies such as standard server logs, cookies (see below for additional information), and clear GIFs (also known as "web beacons"). We use passively-collected information to administer, operate, and improve the Services and our other services and systems, and to provide services and content that are tailored to you. If we link or associate any information gathered through passive means with personal information, we treat the combined information as personal information under this policy. Otherwise, we use information collected by passive means in non-personally identifiable form only.
To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our websites, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
Also, please be aware that third parties may set cookies on your hard drive or use other means of passively collecting information about your use of their services or content. We do not have access to, or control over, these third-party means of passive data collection.
We may collect personal information that our users provide to us in a variety of ways through our Service. For instance, when you request information about our Service or otherwise communicate with us, we collect the personal information that is provided to us. We may collect personal information such as name, telephone number, mailing address, e-mail address, city, state, country, other demographic information, and your interests and preferences in these manners.
We may receive information about you, including personal information, from third parties, and may combine this information with other personal information we maintain about you. If we do so, this policy governs any combined information that we maintain in personally identifiable format. We receive personal information related to you from third parties, including, but not limited to, consumer reporting agencies, publicly-available sources and data suppliers, businesses with which you interreact with or otherwise seek to obtain services from, businesses with which we offer co-branded services, service providers retained to perform Services on our behalf, and social media providers.
We use personal information to provide services and information that you request; to enhance, improve, operate, and maintain the Site and Service, our programs, services, website, and other systems; to prevent fraudulent use of our Site and Service; to tailor your user experience; to maintain a record of our dealings with you; to conduct research and analytics to understand our customers; to develop new products; to ensure internal quality control; to communicate about customer accounts and activities; to comply with regulatory and legal requirements; to prevent, investigate or provide notice of fraud or unlawful or criminal activity, and enforce and carry out contracts and agreements between us and you; to protect the safety of any person, to address fraud, security or technical issues; or to protect our rights or property; and for other administrative and internal business purposes.
For marketing purposes, we may analyze and use personal information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, email, as permitted by applicable law. We allow you to opt-out from receiving marketing communications from us as described in the "Choice" section below.
We may also use aggregate information, deidentified information or other non-personally identifiable information that does not personally identify you in order to understand better how our visitors use the Services, research our visitors’ demographics, interests, and behavior, improve the Services, provide visitors with customized services and information, and for other similar purposes. We may share this information with others for information or promotional purposes, and may use such information in any manner permitted by law.
We will not disclose your personal information to third parties without your consent, other than as described in this policy. We may disclose personal information to vendors and service providers: (i) in connection with the provisioning of IT and related services or as otherwise required to assist us in our work; (ii) to provision information and Services you have requested; (iii) in connection with customer service activities; (iv) for fraud prevention purposes; (v) for analytics services; and/or (vi) in connection with the provisioning of the Services. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions.
We may share personal information about you if we reasonably believe that disclosing the information is needed to: (i) comply with any valid legal process, governmental request, or applicable law, rule, or regulation; (ii) investigate, remedy, or enforce potential violations of any agreement you or a third party may have with us; (iii) protect the rights, property, and safety of us, our customers, or others; or (iv) detect and resolve any fraud or security concerns. We may also disclose personal information if otherwise permitted by applicable law.
In addition, information about our users, including personal information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.
If you receive commercial emails from us and would like to opt out of such communications, you may do so by replying to your SentiLink point-of-contact expressing these sentiments, emailing email@example.com with such sentiments, or, if available, unsubscribing by following the instructions contained within the email.
For your convenience, the Site may contain links to other websites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.
Our Site and Service is hosted in the United States and is generally intended for United States visitors. If you visit from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please be aware that you are transferring personal information to the United States. The United States does not have the same data protection laws as the European Union and some other regions. By providing personal information to us, you consent to the transfer of it to the United States and the use of it in accordance with this policy.
We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate and required, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
We may occasionally update this policy. When we do, we will also revise the "last updated" date at the beginning of the policy. Your continued use of this Service after such changes will be subject to the then-current policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose personal information.
If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
CALIFORNIA PRIVACY NOTICE
Last Updated: May 11, 2020
Scope of Disclosures
Personal Information Disclosures
When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
For the purposes of these Disclosures, personal information does not include:
Collection and Use of Personal Information
In the last 12 months, we have collected the following categories of personal information:
Category of Personal Information Collected
Categories of Sources
Identifiers, such as your name, address, phone number, email address, date of birth or other similar identifiers.
California Customer Records (Cal. Civ. Code § 1798.80(e))
Protected Classification Characteristics
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)
Other Personal Information
Purposes for Collecting Personal Information
Disclosure of Personal Information
We do not sell personal information and will not sell personal information unless we provide proper notice to consumers and, in the case of personal information collected prior to that notice, we obtain explicit consent for the sale of personal information relating to those individuals we previously interacted with.
Recipients of Personal Information
We disclose your personal information to the following categories of third parties:
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
The Right to Know
You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
The Right to Request Deletion
You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising these rights.
However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
“Shine the Light”
California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).
How to Exercise Your California Consumer Rights
To Exercise Your Right to Know or Right to Deletion
To exercise your Right to Know and/or your Right to Deletion, please submit a request by:
We will need to verify your identity before processing your request, which may require us to request additional personal information from you. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Minors Under Age 16
We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at firstname.lastname@example.org to inform us if you, or your minor child, are under the age of 16.
California’s “Shine the Light” Law
In addition to the rights described above, California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year.
To make such a request, please send an email to email@example.com .
We do not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information:
Updates to These CA Disclosures
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.
If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to firstname.lastname@example.org