(Last Updated: April 29, 2016)
1 Information that we collect about you.
2 Cookies and other tracking technology that we use.
3 What we do with the information that we collect.
4 With whom we share the information we collect.
5 Our opt-out policy.
6 Our policy on correcting and updating the personally identifiable information and deactivation of your account.
INFORMATION THAT WE COLLECT ABOUT YOU
Information Provided by You Upon Registration. Upon registration, you may be required to provide some or all of the following personally identifiable information ("PII"):
2 E-mail address
3 ZIP/Postal Code
4 Home Phone
5 Mobile Phone
6 Credit Card Number
Passively Collected Information. When you interact with us through a Site, we receive and store certain additional information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Examples include IP addresses, browser types, domain names, and other anonymous statistical data involving your use of a Site and/or our services.
COOKIES AND OTHER TRACKING TECHNOLOGIES
Technologies such as: cookies, beacons, tags and scripts are used by us and our affiliates, marketing and advertising partners, and service providers. These technologies are used in analyzing trends, administering the Sites, services and products, tracking users' movements around the Sites and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. In some instances we may link this automatically collected data to other information we collect about you. We do this to optimize our marketing efforts as well as to improve the functionality, stability, and availability of the services we offer.
LSOs (HTML 5). Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your web browsing activity use LSOs such as HTML 5. Various browsers may offer their own management tools for removing HTML5 LSOs.
Behavioral Targeting / Re-Targeting. We partner with third parties to either display advertising on our Sites or to manage our advertising on other websites. Our third party partners may use technologies such as cookies to gather information about your activities on the Sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
WHAT WE DO WITH THE INFORMATION WE COLLECT
Use of PII. If you provide PII for a certain reason, we will use the PII in connection with the reason for which it was provided. For example, we will use the PII you input during the registration process to administer your access to a Site. We may also use the registration data that you provide to personalize your experience with us and for verification purposes. We also use contact information from your registration data to send you information about us and to keep you informed of our other products and services that may be of interest to you. Your contact information is also used to reach you, when necessary, regarding issues concerning the use of the Sites and/or our service. We use PII collected through the Sites to help us improve the Sites and our products and services, and to better understand our users. We may use your PII to create aggregate data. Aggregate data is data that describes the demographics, usage or other characteristics of a Site's users as a group without disclosing PII. We reserve the right to transfer and/or sell aggregate or group data about a Site's users for lawful purposes. We may also create internal reports on aggregated user demographics and traffic patterns and share these reports with our advertisers and partners. This information allows our third-party advertisers and partners to deliver, and our users to receive, more relevant advertisements. We use your IP address to help diagnose problems with our server, and to administer the Sites. Your IP address is also used to gather broad and specific demographic information as well as for validation purposes.
Use of Information that is NOT PII. We may pool information that is not PII with other information in order to track, for example, the total number of visitors to a Site, the number of visitors to each page of a Site, and the domain names of our users' Internet service providers. No PII is available or used in this process.
US Residents - Amended Telemarketing Sales Rule. For U.S. residents, with your consent, by submitting your e-mail address via a Site and/or obtaining services from us, you agree to receive e-mail marketing from us and our third-party advertisers. In addition, you agree that such act constitutes a purchase, an inquiry and/or an application for purposes of the Amended Telemarketing Sales Rule, 16 CFR 310 et seq. (the "ATSR"). Notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, we retain the right to contact you via telemarketing in accordance with the ATSR. Moreover, by registering with, or requesting information from, a third-party advertiser at or through a Site, such action shall constitute a purchase, an inquiry and/or an application with the respective third-party advertiser for purposes of the ATSR and you may be contacted via e-mail, direct mail and/or telemarketing by such third-party advertiser in accordance with the ATSR.
WITH WHOM WE SHARE THE INFORMATION WE COLLECT
Service Providers. We, like many businesses, sometimes hire other companies ("Service Providers") to perform certain business-related functions. Examples include mailing information, maintaining databases, and hosting services. When we employ a Service Provider to perform a function of this nature, we provide it with the information that it needs to perform its specific function, which may include PII and other information that you provide to us via a Site. These companies are authorized to use your PII only as necessary to provide these services to us. All information that we provide to a Service Provider, as well as information that you share directly with a Service Provider, will be governed by such Service Provider's privacy policies. When you call a Service Provider using a phone number available via a Site, we, or our third party service providers, may record these phone calls and share such recordings with the applicable Service Provider. The recordings shall be maintained by the Service Providers in accordance with their privacy policies.
Legal Requirements. We may disclose PII if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena or similar legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of users of any Site or the public, (d) protect against legal liability, or (e) or as otherwise required or permitted by law. Moreover, you hereby consent to disclosure of any record or communication to any third party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with other third parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time.
Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, PII may be part of the transferred assets. You will be notified via e-mail and/or a prominent notice on our Sites of any change in ownership or uses of your PII, as well as any choices you may have regarding your PII.
Frames. Some of our pages utilize framing techniques to serve content to from our partners while preserving the look and feel of our Sites. Please be aware that you are providing your PII to these third parties and not to
To stop receiving newsletters or marketing communications from us or to opt out of having your PII shared with third parties, please send an e-mail with your Login Name and e-mail address to email@example.com.
Service Related Announcements. We will also send you service related e-mail announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an e-mail. You do not have an option to opt out of these e-mails, which are not promotional in nature. If you no longer wish to receive these e-mails, please send an e-mail with your Login Name and e-mail address to firstname.lastname@example.org.
OUR POLICY ON CORRECTING AND UPDATING PII AND DEACTIVATING YOUR ACCOUNT
You may access, correct, update or delete your PII, or deactivate your account, by e-mailing our Customer Support at email@example.com. We will respond to your request to access your PII within 30 days. We may need to verify your identity before granting access to PII in our custody or control.
Data Retention. We will retain personal data for as long as needed in order to provide our services and as required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements.
Other Websites. The Sites may contain links to third-party owned and/or operated websites. We are not responsible for the privacy practices or the content of such websites. We suggest that you contact these third parties directly for information regarding their privacy, security and data collection and distribution policies prior to providing them with any information.
Testimonials. We may post customer testimonials on the Sites which may contain PII such as the customer's name. We obtain the customer's consent to post his/her PII along with the testimonial, prior to posting the testimonial. If you want to remove your PII that is being displayed on a Site under public pages, please send your request to firstname.lastname@example.org.
Single Sign-On. You can apply for an open position listed on our Careers page using sign-in services such as LinkedIn. This service will authenticate your identity and provide you the option to share certain PII with us such as your name and e-mail address to pre-populate our sign up form. Services like LinkedIn give you the option to post information about your activities on the Sites to your profile page to share with others within your network.
Security. We take commercially reasonable steps to protect PII from loss, misuse, unauthorized access, disclosure, alteration and destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from a Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any PII to us or to any other party via the Internet. The security of your PII is important to us. When you enter sensitive information (such as a credit card number) on our order forms or login credentials (such as username and password) on our platform login, we encrypt the transmission of that information using secure socket layer technology (SSL). Your PII will be stored in the United States and will be subject to laws applicable in that country. If you have any questions about security on our Site, you can contact us at email@example.com.
Minors. Visitors under 18 years of age are not permitted to use and/or submit their PII at any Site. We do not knowingly solicit or collect information from visitors under 18 years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
The TRUSTe program does not cover information that may be collected through downloadable software. The TRUSTe program covers only information that is collected through this Web site and the information that may be collected once you login. If you have an unresolved privacy or data use concern that we have not satisfactorily addressed, please contact TRUSTe at:
E.U. and Swiss Safe Harbor. Promotely, Inc. complies with the U.S. — E.U. Safe Harbor framework and the U.S. — Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Promotely, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Promotely, Inc.'s certification, please visit
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San Francisco, CA 94105