RASi Privacy Notice
Last Updated: 11/10/23
Welcome! We are Registered Agent Solutions, Inc. (RASi). Our mission is to build long-term client relationships through service excellence, increase client efficiency through innovation, and build long-term value. This Privacy Notice explains how Chronicle Bidco, Inc., and its affiliates and subsidiaries (collectively "RASi", "we", "us" or "our") collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our websites, including https://www.rasi.com/ and other websites we own and operate that link to this Privacy Notice (collectively, the "Sites"), and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the "Services"). It does not address our privacy practices relating to RASi employees and other personnel.
RASi is the controller of the personal information we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal information is used.
In certain situations, RASi may function as a service provider for other businesses. In the course of providing services for other businesses, we may collect your personal information on behalf of our business customers who are the data "controllers". We refer to this type of personal information as "Customer Data". We collect and process Customer Data on behalf of our business customers subject to restrictions set forth in our contracts with them, including, but not limited to, HIPAA business associate agreements. This Privacy Notice does not apply to such processing, and we recommend you read the privacy notice of the respective customer if their processing concerns your personal information.
I. WHAT IS PERSONAL INFORMATION?
When we use the term "personal information" in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person, or any other data or information that constitutes "personal data", "personal information," or "personally identifiable information" under applicable privacy and data protection laws.
II. OUR COLLECTION AND USE OF PERSONAL INFORMATION
We collect personal information in a variety of ways. For example, you may provide us your personal information when you register for an account, download resources, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications, submit a job application, participate in a survey, contest or sweepstakes, redeem a promotion, or use some other feature of our Service.
We may link or combine your activities and information collected from you on our websites and mobile apps with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.
Personal Information Collected from You
We may collect the following categories of personal information submitted to us by individuals through the Services:
- Contact Information, including first and last name, company or firm, job title, your area of responsibility, phone number, email, your city and state, the type of service interested in, and communication preferences. We use this information to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
- Account Information, including first and last name, company name, employer, job title, business email address, user ID and password, general type of representation (i.e., whether you often represent a plaintiff or defendant), profile information, affiliations, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information (including send you invoicing information and information related to the Services), communicate with you regarding your account and your use of the Service, and for customer support purposes. Please note we may utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Services.
- Billing and Payment Information. If you schedule or sign up for one of our Services requiring payment (i.e., place a registered agent order, or register as a Premier Client), we collect the information provided in connection with such billing. Depending on your subscription type, you may be able to pay via wire transfer, credit card, or check and we may collect the financial information associated with such payment (e.g., routing and account number, wire transfer information details). Please note that we use third party payment processors to process credit card payments made to us. As such, except for limited information connected to the transaction such as name and last four of the credit card number, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor's use of your personal information is governed by their privacy notice
- Services-Related Information/ If you schedule or sign up for one of our Services, we collect information relevant to the specific service request. For instance, if you request our Registered Agent Solutions, we may collect information such as jurisdictions applicable, company or firm information, company name, state of incorporation, financial designation, company email, and any other information required for us to fulfill your requested service. Similarly, if you schedule a deposition or order transcripts, we will collect Contact Information and any other information relevant to the service such as deponent or witness, case information, and information regarding the type of facilities or additional services requested. Other Services will also require us to collect information relevant to that service.
- Inquiry and Communications Information, including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
- Newsletter, Marketing Emails, and Blog Information, i
- Contact Information, including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the "unsubscribe link" provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
- Contest, Sweepstakes, Promotions, and Survey Information, including information provided when you enter a contest or sweepstakes, or information included in any questions submitted through surveys or content of any testimonials. We use this information to administer and facilitate the Services, to respond to your submission, to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
- Event and Webcast Information, including registration information, call-in details, attendee badge information, and contact information. We use this information to administer and facilitate the Services and improve and grow our business.
- Information Collected Through the Use of the Service, including any files, documents, videos, images, data, or information you choose to upload or transmit through your communications with us or your use of the Site (collectively, "User Content"). User Content and any information contained in the User Content, including personal information you may have included, is stored and collected as part of the Service. We use the User Content to provide you with the Service.
- Feedback Information. We may also collect feedback and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
- Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g. email, phone, address), job title, and any other information related to the performance of the agreement with us.
- Employment Application Information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.
Personal Information Automatically Collected
As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:
- Log Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services). Some Log Data may overlap with the other categories of data below, such as Platform data.
- Analytics data, including the electronic path you take to our services, through our services and when exiting our services, UTM source, as well as your usage and activity on our services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with. We may also analyze the interaction between you and your customer using our Services.
- Location data, such as general geographic location that we or our third-party providers may derive from your IP address.
- Platform data: If you have an account to use the services we offer as a processor, we may in addition also collect your name, phone number, email address, company information, status in the sales cycle, lead and commercial details (like platform specifics, initial marketing channel), and user and account ID and other identifiers (such as Salesforce ID), user profile/history data, account health status, event attendance, status as lead/account, integrations.
We and our third-party providers may use (i) cookies or small data files that are stored on an individual's computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, "cookies") to automatically collect this personal information. We may also use this information to distinguish you from other users of our Services. This helps us monitor and analyze how you use and interact with our Services. It also helps us and our partners to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see our Cookie Notice.
Personal Information from Third Parties
We also obtain personal information from third parties; which we often combine with personal information we collect either automatically or directly from an individual.
We may receive the same categories of personal information as described above from the following third parties:
- RASi Entities: We may receive personal information from other companies and brands owned or controlled by RASi, and other companies owned by or under common ownership as RASi.
- Your Employer / Company: If you interact with our Services through your employer or company, we may receive your information from your employer or company, including another representative of your employer or company. We use this information to operate, maintain, and provide to you the features and functionality of the Service.
- Other Users or Individuals who Interact with our Services: We may receive your information from other users or other individuals who interact with our Services. For example, if you engage in one of our communications (including web or audio meetings) hosted on third-party platforms, we will be able to see any public communications made within that platform.
- Social Media: When an individual interacts with our Services through various social media networks, such as when someone "Likes" us on Facebook or follows us or shares our content on LinkedIn, Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual's privacy settings with the social network, Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
- Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your orders. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
- Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services on our Services. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
- Other Sources: We may also collect Personal Information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
Through the provision of our Services, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. RASi will maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by RASi satisfies the requirements under applicable law.
Additional Uses of Personal Information
We may use personal information we collect to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions, including, for example, providing you with a white paper you have requested or an online product demonstration;
- Verify your identity and entitlement to products or Services, when you contact us or access our Services;
- Register you for and provide you access to events and webcasts;
- Communicate with individuals, including via email, phone, or social media channels;
- Request individuals to complete surveys about our organization, organizations we partner with, and Services;
- For marketing and advertising purposes, including to market to you or offer you through email, direct mail, information and updates on products or services we think that you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so);
- Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services or using generative artificial intelligence and machine learning tools that may be integrated into our Services;
- Process payment for our Services;
- Facilitate customer benefits and services, including customer support;
- Identify and analyze how individuals use our Services;
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- To enforce our agreements, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
- Comply with contractual and legal obligations and requirements; and
- For any other lawful purpose, or other purpose that you consent to.
Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information requests where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.
III. OUR DISCLOSURE OF PERSONAL INFORMATION
We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:
- RASi Entities: We may share personal information with other companies owned or controlled by RASi, and other companies owned by or under common ownership as RASi, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
- Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
- Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
- Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- Contests, Sweepstakes, and Survey Providers: We share personal information with third parties who assist us in delivering our contests, sweepstakes, or survey offerings and processing the responses.
- Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.
- Ad Networks and Advertising Partners: : We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see our Cookie Notice for more information.
- Business Partners: From time to time, we may share personal data with our business partners at your direction or we may allow our business partners to collect your personal information. Our business partners will use your information for their own business and commercial purposes, including to send you any information about their products or services that we believe will be of interest to you.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- to protect the health and safety of us and others; or
- as otherwise required by applicable law.
- With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual's consent or direction we may post their testimonial on our Sites or service-related publications.
IV. THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING
We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.
For more information about these practices and your choices regarding interest-based advertising, please see our Cookie Notice.
V. CONTROL OVER YOUR INFORMATION
You may control your information in the following ways:
- Email Communications Preferences: You can stop receiving promotional email communications from us by clicking on the "unsubscribe" link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
- Modifying or Deleting Your Information: If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at [email protected]. We may not be able to modify or delete your information in all circumstances.
VI. DATA RETENTION
We will usually store the personal information we collect about you for no longer than necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.
To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.
Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.
VII. CHILDREN'S PERSONAL INFORMATION
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.
VIII. LINKS TO THIRD-PARTY WEBSITES OR SERVICES
Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
IX. UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
X. CONTACT US
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to [email protected].
XI. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES
For residents of the States of California, Colorado, Connecticut, Nevada, Utah and Virginia: These Additional U.S. State Privacy Disclosures ("U.S. Disclosures") supplement the information contained in our Privacy Notice by providing additional information about our personal data processing practices relating to individual residents of these States. For a detailed description of how we collect, use, disclose, and otherwise process personal data in connection with our services, please visit our Privacy Notice. Unless otherwise expressly stated, all terms defined in our Privacy Notice retain the same meaning in these U.S. Disclosures.
For the purposes of these U.S. Disclosures, personal information does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you. Additionally, the U.S. Disclosures set out in this section do not describe our practices when we process Customer Data as a service provider on behalf of our clients in accordance with our contractual agreements with our customers.
Your Privacy Choices
Depending on your state of residency, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
- The Right to Know. The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you in the last 12 months, including:
- The categories of personal data collected;
- The categories of sources of the personal data;
- The purposes for which the personal data were collected;
- The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom the personal data were disclosed;
- The categories of personal data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for those purposes; and
- The categories of personal data sold (if any), and the categories of third parties to whom the personal data were sold.
- The Right to Access and Portability. The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
- The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
- The Right to Correction. You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
- The Right to Opt Out of Sales or Sharing for Targeted Advertising. You have the right to direct us not to "sell" personal information we have collected about you to third parties for monetary or other valuable consideration, or "share" your personal information to third parties for cross-context behavioral advertising purposes. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
How to Exercise Your Privacy Rights
To submit a request to exercise one of the privacy rights identified above, please submit a request by:
- Emailing [email protected] with the subject line "Data Subject Rights Request,"
- Calling 888-705-7274, or
- Filling out our Individual Rights Request Form
We may need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Exercise Your Right to Opt-Out of Personal Information Sales or Sharing for Targeted Advertising
Unless you have exercised your Right to Opt-Out, and as described in the Our Disclosure of Personal Information section of the Privacy Notice, we may disclose or "sell" your personal information to third parties for monetary or other valuable consideration in relation to online tracking technologies, or "share" your personal information to third parties for cross-context behavioral advertising purposes (targeted advertising). The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies.
You do not need to create an account with us to exercise your Right to Opt-Out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
To exercise your right to opt-out as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, please click on the "Do Not Sell or Share My Personal Information" link below. Please note this opt out is browser specific. You must reset your preferences if you clear cookies or use a different browser or device.
Do Not Sell or Share My Personal Information (Cookie Management)
Authorized Agents
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in these U.S. Disclosures where we can verify the authorized agent's authority to act on your behalf.
For requests to know, delete, or correct personal information, we require the following for verification purposes:
- (a) a power of attorney valid under the laws of California from you or your authorized agent; or
- (b) sufficient evidence to show that you have:
- 1. provided the authorized agent signed permission to act on your behalf; and
- 2. verified your own identity directly with us pursuant to the instructions set forth in these U.S. Disclosures; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
For requests to opt-out of personal information "sales" or "sharing", we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted using the Individual Rights Request Form.
CALIFORNIA-SPECIFIC DISCLOSURES
The following disclosures only apply to residents of the State of California.
- Personal Information Collection. In the last 12 months, we may have collected the following categories of personal information: identifiers, commercial information, internet/network information, geolocation data, professional/employment information and inferences generated from your use of our sites. For more information about our collection of personal information, the sources of personal information, and how we use this information, please see Our Collection and Use of Personal Information section of our Privacy Notice.
- Disclosure of Personal Information. In the last 12 months, we may have disclosed all of the categories of information we collect with third parties for a business purpose, as described in the Our Disclosure of Personal Information section of the Privacy Notice. The categories of third parties to whom we sell or disclose your personal information for a business purpose include:
- Service providers and advisors that perform services for us, on our behalf, which may include providing marketing and advertising services, providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or similar services.
- Select marketing and strategic partners who use this information to market to you, to perform analytics and conduct research, or for other purposes;
- Ad networks and advertising partners, including social networks, to deliver advertising and personalized content to you on our services, on other sites and services you may use, and across other devices you may use, as well as provide advertising-related services such as reporting, attribution, analytics, and market research;
- Social networks for advertising or personalization purposes, or to engage with you.
- Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Service;
- We may also disclose personal information to other third parties at your direction or upon your request, or to comply with legal process or contractual obligations, as described in our Privacy Notice.
- Sales of Personal Information and Sharing for Targeted Advertising. In the previous 12 months, we have sold the following categories of personal information to third parties, subject to your settings and preferences and your Right to Opt Out: Commercial Information and Internet / Network Information.
In addition, please see our Cookie Notice to learn more about how third-party advertising networks, social media companies and other third party businesses collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our Services or otherwise engage with us. - Minors. We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization form either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at [email protected] to inform us if you, or your minor child, are under the age of 16.
If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at [email protected]. We may not be able to modify or delete your information in all circumstances.
If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child's behalf (i.e., you are the child's legal guardian or authorized representative). - "Shine the Light". The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please email us at [email protected].
- Notice of Financial Incentives. We may offer various programs, promotions and other financial incentives that may result in differences in our prices or services offered to consumers. For example, we may offer discounts, or other benefits in connection with signing up to use our Services. To obtain access to these offerings, we may collect and retain personal information, such as name, contact information, professional information, account information.
We have determined that the value of these programs and other incentives are reasonably related to the value of the personal data we receive and otherwise process in connection with these programs and offerings, based on our reasonable but sole determination. We estimate the value of the personal data we receive and otherwise process in connection with these programs and offerings by considering the expense we incur in collecting and processing the personal data, as well as the expenses related to facilitating the program or offering.
The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer. Participating in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program's terms and conditions or contact us using the contact information below. Participating individuals may also opt out of receiving marketing communications by following the instructions set forth in the Control Over Your Information section of our Privacy Notice.
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COOKIE NOTICE
Last Modified: 6/23/23
Unless otherwise expressly stated, terms in this notice have the same meaning as defined in the Privacy Notice.
1. SCOPE OF NOTICE
This Cookie Notice supplements the information contained in the Privacy Notice and explains how we and our business partners and service providers use cookies and related technologies in the course of managing and providing our online services and our electronic communication to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.
In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information, please review the Privacy Notice.
2. WHAT ARE COOKIES AND RELATED TECHNOLOGIES
As is common practice among websites, our Services use cookies, which are tiny files downloaded to your device that allow us and our third-party partners to collect certain information about your interactions with our email communications, websites and other online services, and that improve your experience. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, "cookies").
We use the following types of cookies:
- (a) Strictly necessary cookies. These cookies enable core functionality such as security, network management and accessibility. You may disable these by changing your browser settings, but this may affect how the Services function. The legal basis for our use of strictly necessary cookies is our legitimate interests, namely being able to provide and maintain our Services.
- (b) Functional cookies. These enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. The legal basis for our use of functionality cookies is our legitimate interests, namely being able to provide and maintain our Services.
- (c) Analytical/performance cookies. These cookies allow us to recognize and count the number of visitors to our Services, and to see how visitors move around our Services when they are using them. This helps us to improve the way our Services work, for example, by ensuring that users are finding what they are looking for easily.
- (d) Targeting cookies. These cookies record your visit to our Services, the pages you have visited and the links you have followed. They are used to track visitors across our Services.
3. WHAT WE COLLECT WHEN USING COOKIES
We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications and Services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. Our emails may also contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. We may also collect analytics data or use third-party analytics tools to help us measure usage and activity trends for our online services and better understand our customer base. We also may collect location data, including general geographic location based on IP address or more precise location data when a user accesses our online services through a mobile device.
We may include or engage in the following as part pf our Services:
- Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook "Like" button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
- Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
- Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website, "How Google uses data when you use our partners' sites or apps" located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics' currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI's online resources at http://www.networkadvertising.org/choices.
4. HOW WE USE INFORMATION COLLECTED VIA COOKIES
We use cookies for a variety of reasons outlined below:
- If you create an account with us, we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out; however, in some cases, they may remain in order to remember your site preferences when logged out.
- We use cookies when you are logged in so that we can remember you. These cookies are typically removed or cleared when you log out to ensure you can only access restricted features and areas when logged in.
- The Services offer newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
- The Services may offer payment capabilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly. For example, we may use cookies to remember information that can be used to pre-fill a form.
- When you submit data through a form, such as those found on the contact pages or comment forms, cookies may be set to remember your user details for future correspondence.
- In order to provide you with a great experience on the Services, we provide the functionality to set your preferences for how the Services run when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a website page.
- We use cookies to provide and monitor the effectiveness of our Services, monitor online usage and activities of our Services, and facilitate the purposes identified in the How We Use Your Personal Information section of our Privacy Notice.
- We may also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver information about products and services that may be of interest to you.
- Tracking technology used in emails helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and help us understand if you have opened and how you interacted with our email.
Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in our Privacy Notice.
5. YOUR CHOICES ABOUT COOKIES
If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.
Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.
Cookie settings in Internet Explorer
Cookies settings in Safari web and iOS
You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance's (DAA) resources and/or the Network Advertising Initiative's (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest-based ads" (Android). You may also be able to opt-out of some - but not all - interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties' opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA's Principles.