Updated: February 28, 2020
- Personal data we collect or process, including from the Web Site;
- Cookies policy;
- How we use the data;
- Legal grounds for the processing of your data;
- With whom we may share the personal data;
- Your privacy rights, choices and disclosures, including for Europe and California;
- Retention periods and protection of your data;
- Children's privacy;
- Information about international transfers;
- Links to other sites;
- How you can contact us.
What personal data do we collect or process?
The Company collects information in several ways from different parts of the Web Site. Some personal information is gathered from clients of the Company and users of the Services when they register to use the Web Site. During client registration, the Company asks for the name, email address, and other information on the preferences of the client. The more information volunteered (and the more accurate it is), the better we are able to customize the client experience.
We may receive personal information about you from your employer, such as your name and email address, if your employer has subscribed for services on your behalf in your capacity as an employee.
The Company may also collect information from you through mailing lists and service emails and links. Please be aware that the Company are not responsible for the privacy practices of other sites to which you may have linked to or through the Web Site.
The Web Site captures some information from visitors who browse the Web Site, automatically utilizing background local storage and session storage technologies to improve the user experience. This may include, subject to any opt-out preferences, "clickstream" data, such as their Internet Protocol (IP) address, the type of Web browsing software they are using, the web site they visited before linking to the Web Site and the web site they visit after leaving the Web Site.
How your information is used
The Company's primary goal in collecting personal information is to provide you, the user, with a customized experience on the Web Site. By knowing a little about you, the Company is able to deliver more relevant Services and content and hence a better experience to you.
The Company uses the personal data we collect to respond to your inquiries, provide or enhance our Services, perform our contractual obligations, inform you of new Services or changes in Services, administer the Web Site, to enter into contracts for Services, to fulfill legal obligations we have to governmental authorities or other third parties, and for other legitimate business purposes.
You may also receive updates from the Company by email regarding your transactions with the Company and promotional material about the Company's Services and features if you have indicated in your preferences that you would like to receive them. You can change your account preferences at any time. (Please see “Your privacy rights, choices and disclosures" for more information.)
The Company does research on Web Site users' demographics, interests, and behavior based on the information provided to us at registration, from our server log files, or from surveys or third-party analytics tools. We do this to better understand and serve our users. This research is compiled and analyzed on an aggregated basis. The Company may share this aggregated data with advertisers or business partners. (Please see “With whom does the Company share my information?" for more information on how the Company discloses aggregate data.)
Legal grounds for processing your personal data
We rely on the following legal grounds to process your personal information:
Performance of a contract. We may need to collect and use your personal information to enter into an agreement with you or to perform under an agreement that you have with us. When we process personal data on behalf of third parties, we do so in performance of agreements with such third parties.
With whom your information may be shared
The Company is a global provider of Services headquartered in the United States, and as such may need to share information with internal personnel located in different geographic locations in order to fulfill our contractual and legal obligations. We may also share, as controller or as processor performing at the direction of our clients, your personal data with third parties (within or outside your country of residence) who perform services on our behalf, including without limitation our technology providers, payment processors, administrative and support personnel, and providers and professional advisers.
The Company may disclose within or outside your country of residence aggregated user statistics to describe our Services to current and prospective partners, advertisers, and other third parties, and for other lawful purposes. Some of our third-party advertising partners may, with your consent, distribute cookies to you in advertisements that are provided to the Company. The Company has no access or control over these cookies.
We use analytics tools and other third-party technologies, such as Google Analytics, to collect information in the form of various usage and user metrics when you use our site. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and demographics, and other similar information. You can deactivate Google Analytics using a browser add-on if you do not wish the website analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout.
Your privacy rights, choices and disclosures
- 1. General. This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at [email protected] or make changes to any user profile information connected to your account.
- You may also opt out of receiving electronic marketing communications from us by clicking on the “unsubscribe” link on the communication. Some non-marketing communications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support-related information. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.
- Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
- With most web browsing software, by modifying your browser preferences you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you will be unable to use those Services from the Company that require registration in order to participate.
- You may edit your Web Site preferences by contacting us by email at [email protected]. We may not be able to honor all preferences with respect to some information you provide to the Company, such as survey responses and clickstream data.
- 2. Your European Rights and Choices. If you reside or otherwise find yourself in the territory of the EU, we are committed to facilitate the exercise of your rights granted by the EU Data Protection Directive. Otherwise you can contact us at any time to discuss your privacy concerns.
Privacy rights under the EU data protection law include:
- Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us at any time.
- Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification, or deletion of such personal information, requests we will do our best to honor subject to any legal and contractual obligations. To make a request or ask us a question about our data practices, please contact us by email [email protected].
- Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
- Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial emails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt out, such as communications about transactions and disclosures to comply with legal requirements.
- Right to data portability. You have the right to data portability of your own personal data by contacting us.
- Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively affect you.
- Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes on your privacy rights according the EU privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.
- 3. California disclosures
California Information-Sharing Disclosure: California residents may request a list of all third parties to which we have disclosed any information about you for direct marketing purposes, as well as the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to [email protected] with “California Privacy Rights” in the subject line.
- California Consumer Privacy Act (“CCPA”) Disclosures. The California Consumer Privacy Act, effective on January 1, 2020, gives California residents the right to request:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose of collecting or selling personal information;
- The categories of third parties with whom we share or sell personal information;
- The categories of personal information about you that we have sold; and
- The specific pieces of personal information we have collected about you.
- Additionally, you have the right to request deletion of your personal information, the right to opt out of the sale of your information (if applicable), and the right not to be discriminated against for exercising any of your CCPA rights.
- (1) Identifiers such as name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address.
(2) Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
(3) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an Internet website, application, or advertisement.
(4) Geolocation data if you voluntarily share your location.
(5) Professional or employment-related information.
(6) Inferences drawn from any of the foregoing information.
- The Company does not sell Personal Information for monetary consideration. If the use of Google Analytics is deemed a “sale” under the CCPA, then you may opt out of Google Analytics Cookies by downloading the browser add-on here: www.tools.google.com/dlpage/gaoptout.
Our contact information is listed at the bottom of this policy. If your name and email address are insufficient to verify your identity and assess your request, we may need to ask for additional information. You may also designate an authorized agent to make a CCPA data subject request.
We retain the personal data we collect for as long as reasonably necessary to fulfill the purposes for which the data was collected; to perform our contractual, legal, and ethical obligations; and for any applicable statute of limitations periods.
As for cookies, “session” cookies last until you close your browser, and “persistent” cookies last until you or your browser delete them (which in the latter case is typically after 1-2 years but may be longer).
We take reasonable administrative, physical, and technical precautions to protect your personal data and communications with us. This includes, when required or as we deem appropriate and feasible under the circumstances, obtaining written commitments from third parties that may have access to your data that they will protect the data with safeguards that are substantially equivalent to those used by the Company.
A client's Web Site preferences are password-protected. You are responsible for maintaining the confidentiality of your account and are fully responsible for all activities that occur under your account. You agree to (a) immediately notify the Company of any unauthorized use of your account or any other breach of security, and (b) ensure that you exit from your account at the end of each session. The Company cannot and will not be liable for any loss or damage arising from your failure to comply with these provisions. Remember to sign out of your Web Site account and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, though we strive to protect your personal information, the Company cannot ensure or warrant the security of any information you transmit to us or from our online products or Services, and you do so at your own risk.
Once we receive your transmission, we endeavor to maintain its security on our systems. By using the Web Site and the Internet in general, you may be subject to various risks, including among others eavesdropping, sniffing, spoofing, forgery, spamming, "imposturing," tampering, breaking passwords, harassment, fraud, electronic trespassing, hacking. You may be subject to system contamination including without limitation, viruses, worms, and Trojan horses, causing unauthorized, damaging, or harmful access and/or retrieval of information and data on your computer and other forms of activity that may be considered unlawful. Information (including registration information, passwords and content) received or delivered or intended to be made available on and through the Web Site may be subject to these and other security or privacy hazards; or it may not reach its destination or reach an erroneous address or recipient. The Web Site is not different than other applications in this respect. Without limitation of the foregoing, although we take seriously the security of all client accounts and other personal and non-personal information associated with our visitors and participants, because of the open communication nature of the Internet, we cannot guarantee that your account will be free from unauthorized access by third parties.
The Web Site is a general audience site and does not offer Services directed at children. Should an individual whom we know to be a child under age 18 send personal information to us, we will delete or destroy such information as soon as reasonably possible.
Information about international transfers
Links and affiliates
How to contact us
In addition, you may contact us at:
149 Fifth Avenue, 15th Floor
New York, NY 10010