EFFECTIVE AS OF October 1, 2020
About This Policy
The Types of Personal Information We Collect About You and How We Use It
Account Data is information that we collect about you when you inquire about or subscribe to our products and services. This type of information typically includes name, email address, phone number, and photo, and enables us to contact you for purposes such as discussing your interest in our products and services, creating an account for you to access our online services.
Once your account has been created, additional information about you, such as account and communication preferences, may also be requested to enable you to configure and personalize your account. Whether you provide this additional information is up to you. You can choose what additional information you wish to provide, make changes to existing information, and to opt out of future communications at any time by updating your account preferences.
Usage Data is information that we collect about you regarding your use of our Website or Application, and typically includes the following:
Online identifiers such as IP addresses, MAC addresses and “cookie” data (see “What is a Cookie and How Is It Used?” for more information).
Information about the types of devices you are using to access the Website or Application including device type, browser type, operating system and language settings.
Information about the Website or Application pages you visit, including the date, time, and length of your page visits.
Information about which online services you use and how you interact with those services.
Usage Data helps us to optimize the design and operation of our Website or Application to best suit your needs and interests. It also helps us to diagnose, troubleshoot and fix any technical issues involving our Website or Application.
What is a Cookie and How Is It Used?
Sharing of Personal Information We Collect
Except as noted in the table below, we do not sell, trade, rent, or otherwise disclose your personal information to third parties. Where we do share personal information about you with third parties, their use of that information is strictly limited to the following:
Personal Information Retention and Protection
Protecting the confidentiality of any personal information we have collected about you is of utmost importance to us. We retain your personal information for only as long as necessary to satisfy legitimate and essential business purposes such as maintaining the performance and availability of our Website or Application and Services, complying with legal obligations, and resolving any disputes.
We also implement and maintain appropriate technical and operational controls (including encryption and access control measures) to protect your personal information while it is stored on our systems. With that said, please note that no system or data transmission is ever completely secure. While we make all reasonable efforts to protect the confidentiality of the information we collect about you, we make no guarantees, representations, or warranties with respect to the security of your personal information during storage or transmission.
Requesting Deletion of Your Personal Information
At your request, we will delete (or anonymize) any information we have collected about you over the last 12 months. Please understand, though, that we will not (nor are we legally obligated to) respond to more than two such requests within a 12-month period. We may also be legally required or allowed to retain your personal information in certain circumstances even when you’ve requested that we delete your information, including:
Where there is an unresolved issue relating to your account such as an outstanding credit, unpaid balance, or unresolved dispute.
Where we need to retain your personal information for our legal, tax, audit and accounting obligations as required by applicable law.
Where it is necessary to maintain your personal information for our legitimate business interests such as fraud prevention or to maintain the security of our Website or Application.
Please note that by deleting your personal information, you may lose access to or use of certain portions of our Website or Application or services. Therefore, we strongly suggest that you confirm you no longer wish to use our Website or Application or services before making such requests.
Notice to California Residents
If you are a resident of California, then the collection, processing and use of your personal information may be subject to the California Consumer Privacy Act (“CCPA”) as well as other applicable California state privacy laws.
As a company that does business in California and collects the personal information of some California residents, we are required to inform you of the consumer rights afforded to you under the CCPA, and to enable you to exercise those rights with regards to any personal information that we may have collected about you.
Your CCPA Rights
The Right to Know How Your Personal Information is Used
As a California resident, the CCPA affords you the right to request information about the collection, use, and disclosure of your personal information over the previous 12 months, including:
the categories and specific pieces of personal information about you that have been collected;
the purposes for which your personal information have been collected, used or sold (where applicable);
The categories of third parties with whom your personal information have been disclosed;
The categories of personal information about you that have been disclosed for a business purpose; and where applicable:
the categories of personal information about you sold to third parties; the categories of third parties to whom your personal information was sold; and the categories of personal information about you for each third party to whom your personal information was sold.
The Right to Request Deletion of Your Personal Information
You are also afforded the right to request the deletion of any personal information that has been collected about you over the prior 12 months, subject to certain exceptions. Please refer to “Requesting Deletion of Your Personal Information” section for more information.
The Right to “Opt Out” of the Sale of Your Personal Information
Under the CCPA, you may also request that your personal information not be sold to any third parties. Businesses who sell the personal information of California residents are required to respect “opt out” requests for a period of at least 12 months before requesting your authorization to resume selling your personal information.
The Right to Not Be Penalized for Exercising Your Rights
Lastly, businesses required to comply with the CCPA are prohibited from charging you a fee, requiring you to pay higher prices or rates for services, providing you a lower level of service, or terminating your services altogether for exercising your rights under the CCPA; understanding, however, that some personal information may need to be retained in order to continue to deliver those services to you.
How to Exercise My CCPA Rights
Please note that the CCPA does not obligate us to provide the requested information to the same consumer more than twice in a 12-month period.
Opting Out of the Sale of Your Personal Information
We have undertaken extensive steps to identify whether any of our data sharing arrangements would constitute the “sale” of personal information under the CCPA. We continue to maintain that we do not sell, trade, rent or otherwise disclose personal information to a third party for “monetary or other valuable consideration” and, therefore, are not required to provide you the ability to “opt out” of the sale of your information since we do not engage in such activities.
Notice to Canadian Residents
Under Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), business who collect the personal information of Canadian residents are required to adhere to series of privacy principles concerning their handling of such information, including: the principles of accountability; purpose; consent; limited collection; limited use, disclosure and retention; accuracy; safeguards; openness; access; and compliance.
Complaints and Access Requests
Transmissions of Personal Information Across International Borders
Use of Our Website or Application by Children
How to Contact Us