PRIVACY, SECURITY AND TRANSPARENCY STATEMENT
Our privacy statement, contained in the following pages, serves to inform you about the type of personal information we collect, how we use it, with whom we share it and why, and what we do to try to protect it. We go into these issues in great detail in the following pages. We encourage you to read them in detail. In the meantime, we’ll provide a quick overview below.
What do we collect?
There are two types of information we collect from your online activity, which we then store and use:
Non-personal information that is automatically collected from each visitor, such as your device’s operating system; and personal information that you voluntarily provide to us or that is automatically collected.
Why do we use it?
We use non-personal information to manage our online resources, to improve them, and to make business decisions about which programs our customers might like.
We use personal information voluntarily provided to respond to your inquiries and provide you with the services you have requested, among other uses as described below. We do not sell or rent your information to third party data providers or marketing companies. As you would expect, we will only disclose personal information when required to do so by law.
When do we share it?
We share personal information when necessary to comply with our legal obligations and when we have to fulfill the contracts we have with our vendors and business partners. We do not sell or rent any personal information to third parties or data intermediaries or marketing companies.
Your Choices and Privacy Rights
You do not have to provide personal information to enjoy most of our online features. In addition, you can opt out of certain activities such as newsletters and advertisements. You may have certain additional rights depending on the jurisdiction in which you reside, or in which your personal data has been collected, under applicable data protection laws.
The English version of this privacy statement is the controlling version regardless of any translation you may attempt to make.
Virtual assets are the features of the websites we own that will allow you to interact with our websites, as well as applications that we have created and distributed to allow our customers and fans to view our virtual assets or otherwise interact with the content we offer.
FROM WHOM WE COLLECT PERSONAL INFORMATION
We may collect personal information from the following groups of stakeholders: visitors and users of our online and mobile resources; our customers; current members of our workforce and those applying for posted jobs; and external suppliers and business partners.
Personal information usually refers to information that can be used to identify you or that can be easily linked to you (e.g., your name, address, telephone number, e-mail address, social security number, and date of birth). Privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of their consumers or stakeholders that they protect. If those laws apply to us, as in the case of the California Consumer Privacy Act (“CCPA”) or the EU General Data Protection Regulation (“GDPR”), our use of the phrase “personal information” includes the unique elements required by those laws.
These categories of information we collect from each of these groups, and the ways in which we use it, differ. As you may have noticed, it is possible for the same person to join more than one group. Most of this statement addresses our processing and sharing of personal information collected from visitors and users, and from our customers of our virtual resources.
However, we collect and retain the types of professional or employee-related personal information that one would expect the employer to have about its current and former workforce and its new job applicants. We provide legally required collection notices, and describe our use and disclosure of our workforce and applicant personal information in greater detail in internal confidential human resources manuals and documents accessible to members of our workforce, or by posting on the proprietary workforce/applicant portals and applications we operate. In some cases, portals and applications may be operated by third parties who transfer personal information to us. In those situations, the legal responsibility to provide notice to us rests with the third party, not with us.
In addition, like any corporate company, we purchase goods and services, lease equipment and office space, and attend industry events. In doing so, we interact with many existing and potential future vendors and business partners, from whom we necessarily collect certain personal information connected to our contractual business relationships. We use and share personal information collected from our vendors and colleagues to manage, administer and fulfill our contracts with them, or share information about our products. We describe our use of our vendors’ or colleagues’ personal information in more detail in the confidential contracts with those parties, or in the vendor management portals in which we work.
WHAT WE COLLECT
There are two types of information we collect from your online use, which we then store and use: (i) non-personal information that is automatically collected from each visitor, such as the operating system used by the visitor’s device; and (ii) non-personal information that is automatically collected from each visitor, such as the operating system used by the visitor’s device. (ii) personal information that you voluntarily provide to us, or that is collected automatically.
By using our online resources or purchasing our products or services, you signify your agreement to this section of our privacy statement and that we may use and disclose your information as we have described.
Information Voluntarily Presented.
If you participate in certain activities through our online and mobile resources (virtual resources), you may be asked to provide us with information about yourself. The types of personal information we collect in those situations are identifiers (such as your name, email address, address, and phone number), professional information (such as what business you are in), and financial accounting information (such as credit card information). We do not sell, rent or trade personal information voluntarily provided to third parties.
If you do not want us to collect this type of personal information, please do not provide it to us. This means that you should not participate in the virtual activities that we propose, and it would be more convenient for you to communicate with us by phone or mail. Participation is your decision alone. Not participating may limit your ability to take full advantage of virtual resources, but will not affect your ability to access certain information available to the general public regarding virtual resources.
Some examples of how you may voluntarily provide us with your personal information and how we may use it:
Emails and Online Forms – When you send us an email or complete an online form, whether to contact us, your email address along with other personal information (e.g., your personal address or telephone number) that may be contained in or attached to your message will be retained by us and used to respond directly to you and to process your request. Depending on the personal information provided, communication from us may be through e-mails, phone calls, and/or text messages. We may also send you information about any of our products or services that we think may be of interest to you.
Registering for an Account – When you register for an account or register your child for a sub-account, you will be providing us with personal information such as your name and email address (or your child’s name and email address), which will be retained by us. We use that information to create and manage your account and in some cases to establish a password and profile to communicate with you and any sub-accounts you have created via email.
Registering for Events – When you register for events, conferences or programs that we may arrange ourselves (as opposed to outsourcing to a third party event manager with its own privacy policies), you will be submitting the types of identifiers we have described above. If the event requests payment of a fee, we may ask for your credit card or other financial information. We use this information to register you for the event and to send you notifications regarding the event.
Subscribe to Our Service – We use any information provided by our customers to perform our contractual obligations and to provide you with the products and services you have paid for, to manage your accounts and to communicate with you.
Social Networking and Community Features – Some of our online resources may offer community features similar to social networking, allowing users to post messages and comments, and/or upload an image or other files. If you choose to make use of these features, the information you upload, including your screen name and any other personal information, will be in the public domain and will not be covered/protected by this statement.
Automatically Collected Information.
When you visit our virtual resources, basic information is collected passively through your browser through the use of tracking technologies, such as a “cookie,” which is a small text file that is downloaded to your computer or mobile device when you access the virtual resources. It allows us to recognize your computer or mobile device and store some information about your preferences or past actions.
Internet activity information collected through cookies and other similar means includes such things as: the domain name and IP address from which you accessed our online resources; the type of browser and operating system you used; the date, time and duration of your visit; which specific page you visited, the graphics you viewed and any documents downloaded; specific links to other sites you accessed from our online resources; and specific links you accessed our online resources from another site.
In addition, if you access our virtual resources from a cell phone or other mobile device, the mobile service provider may transmit only identifiable information from the mobile device to us, which will allow us to collect phone numbers and associate them with the mobile device’s identifying information. Some cellular providers also operate systems that pinpoint the physical location of devices and we may also receive this information if location services are enabled on your device. If you do not want us to use your geolocation information, disable location services in your device settings.
Independently, we use both automatically collected information and mobile device information to compile generic reports about popular pages on our online resources, and to see how our customers and followers access these online resources. We then use that information to manage and improve our online resources, to make your activities more convenient and efficient, and to improve the operation of our online resources, for example, by remembering certain information about you to save you time.
We use and retain your personal information in accordance with the law to the extent necessary to carry out the purposes described above in accordance with our internal retention procedures.
User Beware of: External Sites, Apps, Links and Social Networks.
We maintain a presence on more than one social media platform, including Twitter, Facebook, YouTube and LinkedIn. In addition, we can allow the functions of our virtual resources to connect to, or be visible from, that external social media presence. Similarly, our virtual resources may contain links to other websites or apps that are controlled by third parties.
WHEN/WITH WHOM WE SHARE PERSONAL INFORMATION
We use non-personal information to manage our online resources, to improve them, and to make business decisions about which programs our customers might like.
We use personal information voluntarily provided to us for our legitimate interests, including responding to your inquiries and providing you with the services you have requested, among other uses described below. We do not sell or rent your personal information to third party information vendors or marketing companies. As you would expect, we only disclose your information when required by law. We may use your personal information when we have your consent to do so, when necessary or permitted under applicable laws.
In addition to the third parties set forth above, we may share your information, including your personal information, within our family of companies. Those companies will use that information in the same way we do, which includes sending you information about their products, services or initiatives that may be of interest to you.
Legal Obligation to Disclose Information.
We may disclose your information, including your personal information, to governmental authorities, and to other third parties when compelled to do so by governmental authorities, or at our discretion or as required or permitted by law, including, but not limited to, responding to court orders and subpoenas.
We may disclose your information, including your personal information, when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of our online resources, or anyone else that could be affected by such activities.
Transfer of Company.
If we or any of our affiliates, or substantially all of their assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, personal information may be one of the transferred assets.
Vendors and Business Partners.
We may share your information, including your personal information, with our vendors and other third parties with whom we have contractual relationships. We may also share your information, including your personal information, with vendors who provide software services that you have chosen to assist you with your sales funnels. We do our best to disclose only the information that each of these parties needs.
We have adopted policies for those vendors and business partners who have received personal information from us. We attempt to bind such vendors and business partners to those standards through written contracts. We attempt to contractually restrict what our vendors and business partners may do with the personal information we provide to them because it is used only to carry out the business purpose for which it was provided; it is not disclosed to anyone else without our consent or under our instructions; it remains, as between us and the relevant vendor or business partner, our property; and it is not transferred outside the United States without our consent.
However, please note that we cannot guarantee that all of our vendors and business partners will agree to these contractual requirements; nor can we ensure that, even when agreeing, they will always comply.
YOUR RIGHTS AND OPTIONS
You do not have to provide personal information to take advantage of most of the features of our virtual resources. In addition, you can opt out of certain activities such as newsletters and advertisements. Data subjects in certain locations, or whose personal data was obtained while in certain locations, may have additional rights under applicable data protection laws.
GDPR Jurisdiction means that the countries that make up the European Economic Area, the United Kingdom (which will soon leave the European Union), Switzerland and Japan, having received an “adequacy decision” from the European Commission, adhere to the material terms of the GDPR.
If we are using personal information you have provided to us to allow us to send you materials, such as newsletters and product alerts via email text messages, and you decide that you no longer wish to receive such material, you may opt out by following the instructions for doing so in the email or other communications (e.g., by replying to the text message with “STOP”), or by contacting us using the contact information below. Upon receipt of your request, we will take reasonable steps to remove your name from our mailing list. You should understand that it may take some time for us to remove your name from our contact lists following your request and due to such latency you may continue to receive materials for some period of time after you have been removed. In addition to withdrawing, you have the ability to access, modify, and delete your personal information by contacting us using the personal information below.
Some browsers have a “do not track” feature that allows you to specify to websites that you do not want your online activities to be tracked. At this time we do not specifically respond to browser “do not track” signals.
Federal law imposes special restrictions and obligations on Web site operators who conduct their operations to, and collect and use information from, children under 13. We take these requirements very seriously, and with that in mind we do not expect our virtual resources to be used by children under the age of 13 without first obtaining verifiable consent from the child’s parent or legal guardian. In addition, we do not knowingly collect personal information from children under the age of 13, only a parent or legal guardian may provide such information after adhering to our verification process to submit such information through the virtual resources. If we become aware that anyone under the age of 18 has entered personal information into our virtual resources without the approval of their parent or legal guardian, and is not an integral part of accessing or using our Services, we will delete the information and not use it at all. If you believe that a child under the age of 18 has submitted personal information to our online resources, please contact us at email@example.com. We encourage parents and legal guardians to talk to their children about the potential risks of providing their personal information on the Internet.
HOW WE PROTECT THE PERSONAL INFORMATION WE COLLECT
We will take all security precautions to protect the personal information you have provided to us when using our virtual resources. We have adopted a program that includes technical, organizational, administrative and security measures designed to protect, consistent with accepted industry standards and laws, against anticipated or actual threats to the security of personal information (the “Security Program”). However, we cannot guarantee that your information, whether during transmission or when it is already stored on our systems, will be completely free from unauthorized access, loss, misuse, destruction or alteration. Except for our duty to maintain the Security Program under applicable law, we disclaim any other liability for any theft or loss, unauthorized access to or damage or interception of any data or communications, including personal information. We have every reason to believe that our Security System is reasonable and appropriate for our business and for the nature of the foreseeable risks to the personal information we collect. In addition, we periodically review and update our Security Program, as required by applicable law.
However, as part of our Security Program, we have specific incident response and management procedures that are activated any time we learn that your personal information may have been compromised. In addition, we require, as part of our vendor and business partner monitoring procedures, that such parties notify us immediately if they have any reason to believe that an incident has occurred that adversely affected the personal information we provide to them.
RIGHTS OF INTERESTED PARTIES IN ANOTHER JURISDICTION
In other jurisdictions, with similar data privacy regulations, we may collect the categories of personal information from you that have already been described. We collect and manage (including disclosure) such information in accordance with applicable local laws. As noted above, we do not sell any personal information to third parties, nor do we use it for automated decision making.
CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to change or update this statement at any time. Please check our online resources periodically for such changes, as all information collected is subject to the statement in effect at that time.