Effective Date: June 15, 2020
Use of the term “Personal Data” herein means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations.
2. Categories of Personal Data We Collect.
Please find details regarding the categories of Personal Data that we collect and have collected over the past twelve (12) months below
- Contact information and other identifying information that you voluntarily choose to provide to us (e.g., first and last name, and email) (such Personal Data, “Contact Information”).
- Usage and web analytics (e.g., IP address and related location information, interactions with our Site, interactions with our other web properties, device and/or browser information) (such Personal Data, “Usage Analytics”).
- Other information you may provide to us through third-party interactions with our Site or other web properties.
3. Sources of Personal Data.
We collect Personal Data about you from the following categories of sources:
- When you provide such information directly to us.
- When Personal Data about you is automatically collected in connection with your use of our Services.
- Third Parties
- Vendors: For example, we may use third party providers to administer the Site or our funds, or to process web analytics information.
4. How We Use Your Personal Data.
We process your Personal Data for the following business purposes:
- To meet or fulfill the reason you provided Personal Data to us; including personalizing Site content and communications, responding to inquiries and fulfilling requests, providing support and assistance for the Site, personalizing Site content and communications, delivering our other web properties (e.g., newsletters, emails), to facilitate events, etc.
- To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Site.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional emails or email you about your use of the Site. Also, we may receive a confirmation when you open an email from us, which helps us improve our Site. If you do not want to receive communications from us, please indicate your preference by emailing us at email@example.com.
5. How We Share Your Personal Data.
We disclose your Personal Data as indicated above to the following categories of service providers and other parties:
- Service Providers
- Categories of Personal Data Shared: We disclose Contact Information and Usage Analytics to our service providers.
- Purposes for Sharing: These third-party service providers help us provide our services and operate our business, including analytics providers, security and fraud prevention providers, hosting and other technology and communications providers, and staff augmentation and contract personnel. When we share your Personal Data with service providers, they may only use your Personal Data for specific purposes relating to assisting us with running our business.
- Successors to Our Business
- Categories of Personal Data Shared: All Personal Data.
- Purposes for Sharing: Your Personal Data may also be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
6. Security and Retention.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, and administrative security measures and storage and processing practices based on the type of Personal Data. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. We retain Personal Data about you for as long as necessary to provide our Site and/or services to you, comply with our legal obligations, resolve disputes, or as otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data or storing data over the Internet is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.
7. Personal Data of Minors.
We do not knowingly collect or solicit Personal Data about children under 13 years of age. If we learn that we have collected personal information from an individual under the 13 years of age, we will delete such information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at firstname.lastname@example.org.
8. Privacy Rights of California Residents.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months, including the:
- Categories of Personal Data that we have collected about you.
- Specific pieces of Personal Data that we have collected about you.
- Categories of sources from which that Personal Data was collected.
- Business or commercial purpose for collecting your Personal Data.
- Categories of third parties with whom we have shared your Personal Data.
- Categories of Personal Data shared with third parties for a business purpose over the past 12 months, if applicable.
You have the right to request that we delete the Personal Data that we have collected about you, subject to certain exceptions under the CCPA: for example, we may need to retain your Personal Data to provide you with the Site services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your CCPA Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are either the person about whom we have collected Personal Data or are an agent authorized by that person, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You may submit a Valid Request by emailing us at email@example.com.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
We Do Not Sell Your Personal Data
We will not “sell” your Personal Data, as that term is defined in the CCPA, and have not done so over the last 12 months. We also do not sell the Personal Data of minors under 16 years of age.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not deny you access to our Site or provide you a lower quality of services if you exercise your rights under the CCPA. If you have any questions about this section or whether any of the above rights apply to you, please contact us at firstname.lastname@example.org.
9. Privacy Rights of Other United States Residents.
California Resident Rights
California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes, under California Civil Code Sections 1798.83-1798.84. If you would like to submit such a request, please contact us at email@example.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. If you are a Nevada Resident, you can exercise this right by contacting us at firstname.lastname@example.org with the subject line “Nevada Do Not Sell Request” and providing us with your name. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
11. Contact Information.