Privacy Policy
Privacy
Statement
Last Updated on December 11th, 2023
PRIVACY, SECURITY AND TRANSPARENCY
Thank you for visiting the online and mobile resources published by . Our privacy statement, contained in the pages that follow, serves,
to give notice about the types of personal information we collect, how we use
it, who we share it with and why, and what we do to try to protect it. We delve
into those matters in a fair amount of detail in the pages that follow. We
encourage you to read them carefully. In the meantime, we provide a quick
overview below.
What do we collect?
There are two types of information that we obtain from you online and then
store and use:
· non-personal
information that’s collected automatically from each visitor, such as your
device operating system; and
· personal information that you
voluntarily provide to us or that is collected automatically.
More details
Why do we use it?
We use non-personal information to administer our online and mobile
resources, make them better, and to make business decisions about what programs
our customers might like.
We use voluntarily provided personal information to respond to your
inquiries and provide you with the services you have requested, amongst other
uses as further described below. We do not sell or rent your personal
information to third party data vendors or marketing companies. As you might
expect, we disclose your information when required by law.
More details
Your Privacy Choices and Rights
You do not have to provide personal information to enjoy most of the
features of our online and mobile resources. Moreover, you can opt out of
certain activities like newsletters and announcements. You may have certain
additional rights depending upon the jurisdiction in which you reside, or in
which your personal data was collected from, pursuant to the applicable data
protection laws.
More details
Contacting Us
Questions about this highlights page or our online privacy statement may
Text HELP for help
The English language version of this privacy statement is the controlling
version regardless of any translation you may attempt.
NAVIGATING THROUGH THIS STATEMENT
You can use the links below to navigate to areas of this statement that
apply specifically to you, or which may otherwise be of interest:
· Who Do We Collect Personal
Information From?
· What We Collect
· Your Rights And Options
· Children’s Privacy
· How Do We Protect Collected
Personal Information?
· The California Consumer
Privacy Act
· The EU General Data Protection
Regulation
· Rights of Data Subjects in
Other Jurisdiction
· Changes To This Privacy
Statement
· Contacting Us
(“,” “us,”
“we,” or “our”) thanks you for visiting the online and
mobile resources we publish. We use the words “you” and “your”
to mean you, the reader, and other visitors to our online and mobile resources
who are, in all cases, over the age of 13. Our privacy statement (“this
statement,” “this privacy statement,” and “our statement”)
informs you about from whom and the types of personal information we collect,
how we use it, who we share it with and why, and what we do to try to protect
it.
Online and mobile resources means the
websites and other internet features we own that allow you to interact with our
websites, as well as apps we’ve created and distributed to let our customers
and followers view our online and mobile resources or otherwise interact with
the content we provide.
WHO WE COLLECT PERSONAL INFORMATION FROM
We may collect personal information from the following groups of data
subjects: visitors to, and users of, our online and mobile resources; our
customers; current members of our workforce and those who apply for posted
jobs; and third party vendors and business partners.
Personal information generally means
information that can be used to identify you or that can be easily linked to
you (for example, your name, address, telephone number, email address, social
security number and date of birth). The privacy laws in some jurisdictions include
unique elements in what they consider to be the personal information of the
consumers or data subjects they protect. If those laws apply to us, as in the
case of the California Consumer Privacy Act (“CCPA”) or European General
Data Protection Regulation (“GDPR”), our use of the phrase “personal
information” includes the unique elements required by such laws.
The categories of information we collect from each of these groups, and
the ways in which we use it, differs. As you may have noticed, it’s possible
that the same person could fall into more than one group. Most of this
statement addresses our processing and sharing of personal information
collected from visitors to and users of our online and mobile resources and our
customers.
Nonetheless, we collect and retain the types of professional or employment
related personal information you would expect an employer to have
about its existing and former workforce and new job applicants. We provide
legally required notices of collection, and describe our use and sharing of the
personal information of our workforce and applicants in greater detail in
confidential internal human resource manuals and documents accessible to
members of our workforce, or by publication on the proprietary
workforce/applicant portals and apps we operate. In some cases, such portals
and apps may be operated by third parties who transfer the personal information
to us. In those situations, the legal responsibility to provide notice usually
rests with the third party, not us.
In addition, like all corporate enterprises, we buy goods and services,
lease equipment and office space and attend industry events. In doing so, we
interact with many existing and potential vendors and business partners from
whom we necessarily collect certain personal information in connection with our
contractual and business relationships. As with our customers, this information
is typically limited to minimum business contact information. We use and share
personal information collected from our vendors and business partners to
manage, administer and perform under our contracts with them, or share
information about our products. We describe our use of vendor and business
partner personal information in greater detail in our confidential contracts
with those parties or on the internal vendor management portals we operate.
WHAT WE COLLECT
There are two types of information that we obtain from you online and then
store and use: (i) non-personal information that’s
collected automatically from each visitor, such as your device operating
system; and (ii) personal information that you voluntarily provide to us or
that is collected automatically.
By using our online and mobile resources or purchasing our products or
services, you are signifying to us that you agree with this section of our
privacy statement and that we may use and disclose your information as
described.
Voluntarily Submitted Information.
If you participate in certain activities via our online and mobile
resources, you may be asked to provide us with information about yourself. The
types of personal information we collect in those situations includes identifiers (such
as your name, email address, physical address, and phone number), professional
information (such as the business you are in), and financial
account information (such as your credit card information). We do not
sell, rent, or trade voluntarily submitted personal information with third
parties.
If you don’t want us to collect this type of personal information, please
don’t provide it. This means you shouldn’t participate in the activities on our
online and mobile resources that request or require it and you may want to
communicate with us by phone or regular mail instead. Participation is strictly
your choice. Not participating may limit your ability to take full advantage of
the online and mobile resources, but it will not affect your ability to access
certain information available to the general public on the online and mobile
resources.
Some of the ways you voluntarily give us your personal information and how
we use it:
Emails and Online Forms – When you send us
an email or fill out an online form, such as to contact us, your email address
and any other personal information (e.g., home address or phone number) that
may be in the content of your message or attached to it, are retained by us and
used to respond back directly to you and to process your request. Depending on
the personal information provided, communications from us may be in the form of
emails, telephone calls, and/or text messages. We may also send you information
about any of our products or services we think may be of interest to you.
Registering for an Account – When you register
for an account or you register your child for a sub-account, you submit
personal information to us such as your name and email address (or your child’s
name and email address) which we then retain. We use that information to create
and manage your account and in some cases establish a password and profile to
communicate with you and any sub-accounts you created via email.
Registering for Events – When you register
for events, conferences or programs we ourselves may host (rather than
outsource to a third party event manager with its own privacy policies), you
will be submitting the types of identifiers described above. If the event
requires a fee, we may also ask you to submit credit card or other
financial information. We use this information to register you for the
event and send you communications regarding the event.
Becoming a Subscriber to Our Service – We use any information provided from our customers to perform
our contractual obligations and provide the products and services purchased to
them, to manage their accounts and communicate with them.
Social Media and Community Features – Some of our online and mobile resources may offer social
media-like community features letting users post messages and comments, and/or
upload an image or other files and materials. If you choose to make use of
these features, the information you post, including your screen name and any
other personal information, will be in the public domain and not
covered/protected by this statement.
Automatically Collected Information.
When you visit our online and mobile resources, basic information is
passively collected through your web browser via use of tracking technologies,
such as a “cookie” which is a small text file that is downloaded onto your
computer or mobile device when you access the online and mobile resources. It
allows us to recognize your computer or mobile device and store some
information about your preferences or past actions.. You can learn more about
cookies and tracking technologies in general here.
We allow third party vendors to use cookies or similar technologies to
collect information about your browsing activities over time following your use
of the site. For example, we use Google Analytics, a web analytics service
provided by Google, Inc. ("Google"). Google Analytics uses cookies to
help us analyze how you use the online and mobile
resources and enhance your experience when you visit the online and mobile
resources. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. You can learn more about how to opt out of Google Analytics by going
to https://tools.google.com/dlpage/gaoptout.
The 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 and mobile resources; the type of browser and
operating system you use; the date and time and length of your visit; the
specific page visited, graphics viewed and any documents downloaded; the
specific links to other sites you accessed from our online and mobile
resources; and the specific links from other sites you used to access our online
and mobile resources.
Additionally, if you access our online and mobile resources from a phone
or other mobile device, the mobile services provider may transmit to us
uniquely identifiable mobile device information which allows us to then collect
mobile phone numbers and associate them with the mobile device identification
information. Some mobile phone vendors also operate systems that pinpoint the
physical location of devices and we may receive this information as well if
location services are enabled on your device. If you do not want us to collect
and use geolocation data, disable location services through your device
settings.
Regardless, we use both automatically collected information and mobile
device information to compile generic reports about popular pages on our online
and mobile resources, and to see how our customers and followers are accessing
our online and mobile resources. We then use that data to administer the online
and mobile resources and make them better, make your activities more convenient
and efficient and to enhance the functionality of our online and mobile
resources, such as by remembering certain of your information in order to save
you time.
We use and retain your personal information in accordance with applicable
law and as long as necessary to carry out the purposes described above in
accordance with our internal data retention procedures.
We use and retain your personal information in accordance with applicable
law and as long as necessary to carry out the purposes described above in
accordance with our internal data retention procedures.
User Beware: External Sites, Apps, Links and Social Media.
We maintain a presence on one or more external social media platforms such
as Twitter, Facebook, YouTube and LinkedIn. We may further allow features of
our online and mobile resources to connect with, or be viewable from, that
external social media presence. Similarly, our online and mobile resources may
contain links to other websites or apps controlled by third parties.
We are not responsible for either the content on, or the privacy practices
of, social media platforms, or any third party sites or apps to which we link.
Those apps, sites and platforms are not controlled by us and therefore have
their own privacy policies and terms of use. If you have questions about how
those apps, sites and platforms collect and use personal information, you
should carefully read their privacy policies and contact them using the
information they provide.
WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION
We use non-personal information to administer our online and mobile
resources, make them better, and to make business decisions about what programs
our customers might like.
We use voluntarily provided personal information for our legitimate
interests, including to respond to your inquiries and provide you with the
services you have requested, amongst other uses as further described below. We
do not sell or rent your personal information to third party data vendors or
marketing companies. As you might expect, we disclose your information when
required by law. We may use your personal information when we have your consent
to do so, where required or permitted under applicable law.
We use voluntarily provided personal information for our legitimate
interests, including to respond to your inquiries and provide you with the
services you have requested, amongst other uses as further described below. We
do not sell or rent your personal information to third party data vendors or
marketing companies. As you might expect, we disclose your information when
required by law. We may use your personal information when we have your consent
to do so, where required or permitted under applicable law.
Affiliates.
In addition to those third parties set forth above, we may share your
information, including personal information, within our family of companies.
Those companies will use such information in generally the same manner as we do
under this privacy statement which includes sending you information about their
products, services, or initiatives that may be of interest to you.
Legally Compelled Disclosures.
We may disclose your information, including personal information, to
government authorities, and to other third parties when compelled to do so by
such government authorities, or at our discretion or otherwise as required or
permitted by law, including but not limited to responding to court orders and
subpoenas.
To Prevent Harm.
We may disclose your information, including personal information, when we
have reason to believe that someone is causing injury to or interference with
our rights or property, other users of the online and mobile resources, or
anyone else that could be harmed by such activities.
Business Transfer.
If we or any of our affiliates, or substantially all of its or 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 personal information, with our
vendors and other third parties with whom we have a contractual relationship.
We may also share your information, including personal information, with
vendors who provide third party software services that you have chosen to
assist you with your sales funnels. We do our best to disclose only the
information each of those parties need.
We have adopted standards for those vendors and business partners who
receive personal information from us. We attempt to bind such vendors and
business partners to those standards via written contracts. We further attempt
to contractually restrict what our vendors and business partners can do with
the personal information we provide to them such that it is used only to the
extent necessary to carry out the business purpose for which it was provided;
is not disclosed to anyone else without our consent or under our instruction;
remains, as between us and the applicable vendor or business partner, our
property; and is not transferred out of the United States without our consent.
Please note, however, 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 they do agree, they will always fully comply.
YOUR RIGHTS AND OPTIONS
You can choose not to provide personal information, but in doing so some
of the features of our online and mobile resources may not be available to you.
Moreover, you can opt out of certain activities like newsletters and
announcements. Data subjects in certain locations, or whose personal data was
obtained while they were in certain locations, may have additional rights
pursuant to the applicable data protection laws
GDPR Jurisdictions means the countries
composed of the European Economic Area, the United Kingdom (which soon will
leave the European Union), Switzerland and Japan which, having received an
“adequacy decision” from the European Commission, adheres to the material terms
of the GDPR.
If we are using personal information you provided to us in order to enable
us to send you materials, such as newsletters or product alerts via text or
email, and you decide you don’t want to receive such materials, you may opt out
by following the opt-out instructions in the email or other communication
(e.g., by responding to the text with “STOP”), or by contacting us using the
contact information below. When we receive your request, we will take
reasonable steps to remove your name from our distribution lists. You need to
understand it may take a period of time to remove your name from our lists
after your request and due to such latency you may still receive materials for
a period of time after you opt out. In addition to opting out, you have the
ability to access, amend, and delete your personal information by contacting us
using the contact information below.
Some browsers have a “do not track” feature that lets you tell websites
that you do not want to have your online activities tracked. At this time, we
do not specifically respond to browser “do not track” signals.
CHILDREN’S PRIVACY
Federal laws impose special restrictions and obligations on commercial
website operators who direct their operations toward, and collect and use
information from, children under the age of 13. We take those age-related
requirements very seriously, and consistent with it do not intend for our
online and mobile resources to be used by children under the age of 13 without
first obtaining the verifiable consent of such child’s parent or legal
guardian. Moreover, we do not knowingly collect personal information from
minors under the age of 13, only a parent or legal guardian may provide such
information after adhering to our verification process for submitting such
information via the online and mobile resources. If we become aware that anyone
under the age of 18 has submitted personal information to our online and mobile
resources without such parental or legal guardian approval and that is not an
integral part to accessing or using our Services, we will delete that
information and will not use it for any purpose whatsoever. If you believe that
someone under the age of 18 has submitted personal information to our online
and mobile resources, please Text HELP for help 773 417
6988. We encourage parents and legal guardians to talk with
their children about the potential risks of providing personal information over
the Internet.
HOW WE PROTECT COLLECTED PERSONAL INFORMATION
We will take all reasonable security precautions to protect your personal
information provided to our online and mobile resources. We have adopted a
security program that includes technical, organizational, administrative, and
other security measures designed to protect, in a manner consistent with
accepted industry standards and applicable law, against anticipated or actual
threats to the security of personal information (the “Security Program”).
We cannot, however, guarantee that your information, whether during
transmission or while stored on our systems or otherwise in our care, will be
free from unauthorized access or that loss, misuse, destruction, or alteration
will not occur. Except for our duty to maintain the Security Program under
applicable law, we disclaim any other liability for any such theft or loss of,
unauthorized access or damage to, or interception of any data or communications
including personal information. We have every reason to believe our Security
Program is reasonable and appropriate for our business and the nature of
foreseeable risks to the personal information we collect. We further
periodically review and update our Security Program, including as required by
applicable law.
Nonetheless, as part of our Security Program, we have specific incident
response and management procedures that are activated whenever we become aware that
your personal information was likely to have been compromised. We further
require, as part of our vendor and business partner oversight procedures, that
such parties notify us immediately if they have any reason to believe that an
incident adversely affecting personal information we provided to them has
occurred.
THE CALIFORNIA CONSUMER PRIVACY ACT
When we collect personal information from California residents we become
subject to, and those residents have rights under, the California Consumer
Privacy Act or “CCPA”. This section of our statement is used to allow us
to fulfill our CCPA obligations and explain your CCPA
rights. For purposes of this section, the words “you” and “your”
mean only such California residents.
What did we collect from California Residents?
We collect the following categories of personal information: identifiers such
as name, address, IP address, and other similar identifiers; personal
information described in subdivision (e) of Section 1798.80 (California
customer records statute) such as a name, address, telephone number, credit
card number; commercial information such as products or
services purchased; internet/electronic activity such as
browsing history and search history; geolocation data including
geographic coordinates/physical location; and audio, video, electronic or other
similar information. We have disclosed these categories of personal information
for a business purpose within the last 12 months. We do not sell, and within
the last 12 months have not sold, personal information to third parties.
Rights of California Residents
You have the following rights under the CCPA, in summary disclosure,
access and delete. More information can be found . It’s important to us that you know that if you exercise these rights,
we will not “discriminate” against you by treating you differently from other
California residents who use our sites and mobile resources or purchase our
services but do not exercise their rights.
You can exercise these rights up to two different times every 12 months.
To do so, just Text HELP for help 773 417
6988. We may ask you to fill out a request form. The CCPA
only allows us to act on your request if we can verify your identity or your
authority to make the request so you will also need to follow our instructions
for identity verification.
If you make a verifiable request per the above, we will confirm our
receipt and respond in the time frames prescribed by the CCPA.
THE EU GENERAL DATA PROTECTION REGULATION
We do collect or otherwise obtain personal information from data subjects
located in the GDPR Jurisdictions. We fulfill our
GDPR obligations with respect to our workforce/job applicants, our customers
(and their own end-clients), and our vendors and business partners through a
series of separate notices, contracts or other terms provided to them at the
time, and in the manner and form, GDPR and local law within each GDPR
Jurisdiction requires.
We describe, in the immediately following section of this statement, how
we comply with the GDPR for personal information collected from visitors to and
users of our online and mobile resources while they were in a GDPR
Jurisdiction. Thus for purposes of that section, the words “you” and “your”
mean only such GDPR Jurisdiction-based visitors and users.
What do we collect from you in the GDPR Jurisdictions and how do we use it?
We collect from you the categories of personal information already
described. The lawful basis on which we rely for such collection, later use and
disclosure, is what the GDPR refers to as legitimate interest. As stated
elsewhere in this statement, we do not sell any of your personal information to
third parties nor do we use it for automated decision making.
Cross-border Data Transfers and Third Party Processors
If we transfer personal information from the GDPR Jurisdictions to a
location that has not been deemed by the European Commission to have adequate
privacy protections, we do so in the manner the GDPR permits.
Rights of Data Subjects in the GDPR Jurisdictions
While we attempt to allow all visitors and users of our online and mobile
resources to exercise a degree of control over their personal information,
under the GDPR we have a legal obligation to do so for you. More specifically,
with respect to personal information collected from you while you were in a
GDPR Jurisdiction, you have these rights: transparency, access, correction and
deletion, portability, who, what, why and where, and restriction/objection (for
more information click here).
If you would like to exercise any of these rights, please Text HELP at 773
417 6988. Your ability to exercise these rights is subject to certain
conditions and exemptions that you can read about in Articles 12 through 23 of
the GDPR. Among those conditions is our right to decline part or all of a
request if we cannot satisfy our reasonable doubts and concerns about your
identity in a manner that helps us minimize the risk that unauthorized persons
might use a GDPR right to access your personal information. We will respond to
all requests without undue delay, and in accordance with the time frames, if
any, prescribed by the GDPR. If you are not satisfied with how we use your
personal information or respond to your requests, you have the right to
complain to your data protection regulator. Contact information for the EU data
protection regulators can be found here.
RIGHTS OF DATA SUBJECTS IN OTHER JURISDICTIONS
In other jurisdictions, with similar data privacy regulations, we may
collect from you the categories of personal information already described. We
collect and manage (including disclose) such data in compliance with applicable
local law(s). As noted, we do not sell any of your personal information to
third parties nor do we use it for automated decision making.
CHANGES TO THIS PRIVACY STATEMENT
The English language version of this privacy statement is the controlling
version regardless of any translation you may attempt.
We reserve the right to change or update this statement from time to time.
Please check our online and mobile resources periodically for such changes
since all information collected is subject to the statement in place at that
time.
CONTACTING US
If you have questions about our privacy statement or privacy practices,
please contact us at:
Text HELP for help