Draft version: August 2019
2. Collection of Information.
Personal Information Collected.
Information that You Provide. Company collects any information that you voluntarily provide, including when you contact us through our Site by providing us with your name, email address, and the questions, comments or other information you submit in the “subject header” and “comments” portions of your email communications, or when you use the Services made available through the Site. Company may also collect information that you provide by electronic mail, telephone or other means. In order for you to access certain of the Services we offer through the Site, we may require that you provide us with certain information that personally identifies you. In no event will the Site request your social security number, driver’s license number, government identification, banking or credit card information or other financial data. To the extent you believe the Site makes a request for such information, you will discontinue use and contact us immediately at email@example.com.
Categories of Information. Personal Information that we collect from you includes the following categories of information: Contact data such as your name and e-mail address. We do not currently collect financial data such as your account or credit card number. We do not currently collect demographic data such as your zip code, age, and income. If you communicate with us by e-mail or otherwise complete online forms or questionnaires, if any, then any information provided in such communications may also be collected by us as Personal Information.
Automatically Collected Information. Company may automatically collect certain technical information from your computer or mobile device when you use the Site such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the Site, the pages you view immediately before and after you access the Site, and the search terms you enter on the Site. This information allows Company to recognize you and personalize your experience if you return to the Site, and to improve the Site and the Services.
How Personal Information Is Used. We use Personal Information to send you information about our company or our Services, or promotional material from some of our partners, or to contact you when necessary. If we make any additional uses of your Personal Information, we will provide you notice of the same.
Your Rights Regarding Personal Information. You have the right to “opt-out” of our collection and use of your Personal Information. You also have the right to request that we delete your Personal Information from our databases. To request information from us on the data we collect and use, please contact firstname.lastname@example.org.
Cookies. Company may collect Personal Information using “cookies,” which are small text files that the Site saves on your computer or mobile device, or similar devices. You can disable cookies in your browser settings, but doing so may affect the functionality of the Site.
Web Beacons. Company may also collect information using “web beacons,” which are clear electronic images that can recognize certain types of information on your computer, mobile device or other devices, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon. Web beacons, alone or in conjunction with cookies, may help Company compile information about your interactions with electronic mail sent to you in connection with the Services.
Cross-Site Tracking. Company does not utilize technical measures in the Site to track your activities across different Web sites or online services, whether you configure your browser’s “Do Not Track” feature or otherwise. The Site may utilize third-party application programming interfaces controlled by third parties, such as to display maps and graphs, that may attempt to track your activity across other sites that utilize those interfaces.
Reviewing and Correcting Information. Personal Information about you that is collected by us can be reviewed by contacting the Company at the contact information listed in the Section above and requesting a review of your personal information.
User Choice Regarding Collection, Use, And Distribution Of Personal Information. You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Site. However, you may not be able to access and use those portions of the Site or Services that require your Personal Information. If you do not wish to receive certain information and promotional material from us or from some of our partners, you may elect to opt-out from receiving such information by contacting the Company at the contact information listed in this Section above and requesting that you no longer receive such information.
3. Use and Disclosure of Personal Information.
Purposes For Collection of Personal Information. Company may use the Personal Information collected from you for a number of purposes, including, but not limited to:
- providing you with the Services, or products, services or information related to the Site or the Services;
- providing you with information or notices about the Site or the Services;
- customizing your experience when using the Site or Services such as by providing interactive or personalized elements on the Site or when using the Services;
- allowing Company to improve the Site and the Services, such as by better tailoring content to users’ needs and preferences;
- generating and analyzing statistics about your use of the Site and Services;
- combining or aggregating any of the information collected through the Site or Services for any of the aforementioned purposes.
Marketing. Company may use collected information for delivering marketing communications or investment materials that may be of interest to you. However, Company does not sell or otherwise share your personally identifiable information with other companies so that they can market to you.
Disclosure By Company. Company may disclose the information Company collects from you through the Site and Services:
- as necessary to provide you with the Services or products, services or information related to the Site or Services;
- to your employees or agents acting on your behalf, if you authorize Company to do so;
- as required by law, such as to comply with a subpoena or other legal process, or to comply with government reporting obligations;
- to affiliates, service providers, advisors and other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of all or a portion of Company’s assets;
- pursuant to your express consent; or
- in the form of aggregate reports on user demographics and traffic patterns, or other information that may or may not be derived from Personal Information but does not personally identify you, both for disclosure to third parties and for the purpose of enhancing the Site or Services and developing new service offerings.
Company’s Service Providers. Company may engage third-party service providers (such as hosting providers and analytics and data security providers) to assist in operating the Site and providing the Services.
Sharing Of Personal Information. We do not share your Personal Information with other companies, except as expressly provided for herein.
Additional Uses. If we decide to make any additional uses of your Personal Information, we will provide you with notice regarding such additional uses.
Disclosure By Third Parties. Company’s business affiliates may disclose personal information about you to others in accordance with their own separate and distinct privacy policies. You should carefully review such third party privacy policies before using the website or services of any of our third party affiliates. Among other things, our business affiliates may use your personal information (a) if they have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of the business partner’s terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims. Even though we do not transfer or sell your personal information to third parties, our business partners may have materially different policies regarding such practices.
4. Confidentiality And Security Of Personal Information.
User Ability To Access, Update, And Correct Personal Information We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. At any time, you may contact the Company at the contact information listed in Section 2 above and request an update of your Personal Information.
Confidentiality and Security of Third Parties. IMPORTANT: Our Site contains links to other websites and portals. We are not responsible for the privacy practices or the content of such websites or portals.
Jurisdiction. Some of the information collected through the Site may be stored in, processed in and subject to the laws of the United States, which may not provide the same level protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the Site, you consent to such transfer to, storage in and processing within the United States.
Security. Company is committed to protecting your information from unauthorized access, use or disclosure. The Site and its operators maintain administrative, technical and physical safeguards designed to protect the information collected through the Site. For example, all information you transmit to the Site is encrypted using Transport Layer Security technology (TLS). However, no information or communication system can be one hundred percent (100%) secure, so Company cannot guarantee the absolute security of your information. Company is not responsible for the security of information that you transmit to the Site over networks that Company does not control, including the Internet and wireless networks.
General Data Protection Regulation. The European Union’s General Data Protection Regulation (“GDPR”) requires that the personal data of an individual residing in an EU country to be subject to certain safeguards and their data rights and freedoms are protected under the GDPR. When an individual leaves an EU country and travels to a non-EU country (like the United States), they are no longer protected by the GDPR.
6. Third-Party Websites.
The Site, Services and communications from Company may contain links to websites, services, and portals operated by third parties. You acknowledge and agree that Company is not responsible for the collection and use of your information by any websites, services and portals that are not under Company’s control.
7. Business Transfer
8. Children’s Information
The Site is not directed to, nor does Company knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided information without your consent, please contact Company immediately using the contact information provided below.
9. Other Agreements, Terms and Policies.
10. Contact Information