Last Updated: April 20, 2021
"Personal information," as used in this policy, is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. Such personal information includes an individual’s name, social security number, telephone number, or e-mail address, information about an individual’s activities, including about his or her activity on the Site or credit history, and demographic information, including date of birth, gender, address, geographic area, and preferences.
Personal information does not include aggregate or deidentified information or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that cannot be linked back to any particular individual(s). We may use and disclose aggregate information, deidentified information and other non-personally identifiable information, for various purposes.
Collection of Information
From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.
We, and our third-party partners, automatically collect certain types of usage information when you visit our services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”).
We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:
Information about your device and its software, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
When you access our Sites from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), or Google AdID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.
Information about the way you access and use our services, for example, the website from which you came and the website to which you are going when you leave our services, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other actions you take on the Site.
We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google’s practices at https://policies.google.com/technologies/partner-sites?hl=en-US and view its opt-out options at https://tools.google.com/dlpage/gaoptout.
We use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Site; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.
We may collect personal information that our users provide to us in a variety of ways through our Service. For instance, when you request information about our Service or otherwise communicate with us, we collect the personal information that is provided to us. We may collect personal information such as name, telephone number, mailing address, e-mail address, city, state, country, other demographic information, and your interests and preferences in these manners.
We may receive information about you, including personal information, from third parties, and may combine this information with other personal information we maintain about you. If we do so, this policy governs any combined information that we maintain in personally identifiable format. We receive personal information related to you from third parties, including, but not limited to, consumer reporting agencies, publicly-available sources and data suppliers, businesses with which you interreact with or otherwise seek to obtain services from, businesses with which we offer co-branded services, service providers retained to perform Services on our behalf, and social media providers.
Use of Personal Information
We use personal information to provide services and information that you request; to enhance, improve, operate, and maintain the Site and Service, our programs, services, website, and other systems; to prevent fraudulent use of our Site and Service; to tailor your user experience; to maintain a record of our dealings with you; to conduct research and analytics to understand our customers; to develop new products; to ensure internal quality control; to communicate about customer accounts and activities; to comply with regulatory and legal requirements; to prevent, investigate or provide notice of fraud or unlawful or criminal activity, and enforce and carry out contracts and agreements between us and you; to protect the safety of any person, to address fraud, security or technical issues; or to protect our rights or property; and for other administrative and internal business purposes.
For marketing purposes, we may analyze and use personal information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, email, as permitted by applicable law. We allow you to opt-out from receiving marketing communications from us as described in the "Choice" section below.
We may also use aggregate information, deidentified information or other non-personally identifiable information that does not personally identify you in order to understand better how our visitors use the Services, research our visitors’ demographics, interests, and behavior, improve the Services, provide visitors with customized services and information, and for other similar purposes. We may share this information with others for information or promotional purposes, and may use such information in any manner permitted by law.
Disclosure of Personal Information
We will not disclose your personal information to third parties without your consent, other than as described in this policy. We may disclose personal information to vendors and service providers: (i) in connection with the provisioning of IT and related services or as otherwise required to assist us in our work; (ii) to provision information and Services you have requested; (iii) in connection with customer service activities; (iv) for fraud prevention purposes; (v) for analytics services; and/or (vi) in connection with the provisioning of the Services. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions.
We may share personal information about you if we reasonably believe that disclosing the information is needed to: (i) comply with any valid legal process, governmental request, or applicable law, rule, or regulation; (ii) investigate, remedy, or enforce potential violations of any agreement you or a third party may have with us; (iii) protect the rights, property, and safety of us, our customers, or others; or (iv) detect and resolve any fraud or security concerns. We may also disclose personal information if otherwise permitted by applicable law.
In addition, information about our users, including personal information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.
If you receive commercial emails from us and would like to opt out of such communications, you may do so by replying to your SentiLink point-of-contact expressing these sentiments, emailing firstname.lastname@example.org with such sentiments, or, if available, unsubscribing by following the instructions contained within the email.
For your convenience, the Site may contain links to other websites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. 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 13. If you are under the age of 13, please do 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 13 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 13, we will promptly delete that personal information.
Our Site and Service is hosted in the United States and is generally intended for United States visitors. If you visit from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please be aware that you are transferring personal information to the United States. The United States does not have the same data protection laws as the European Union and some other regions. By providing personal information to us, you consent to the transfer of it to the United States and the use of it in accordance with this policy.
We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate and required, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Updates to this Policy
We may occasionally update this policy. When we do, we will also revise the "last updated" date at the beginning of the policy. Your continued use of this Service after such changes will be subject to the then-current policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose personal information.
California: If you are a resident of the State of California in the United States, please see below for additional California-specific privacy disclosures.
Nevada: Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Note we do not sell your personal information within the meaning of Chapter 603A. However, if you would still like to submit such a request, please contact us at email@example.com.
Additional California Privacy Disclosures
Last Updated: April 20, 2021
Scope of Disclosures
Personal Information Disclosures
When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
For the purposes of these Disclosures, personal information does not include:
Publicly available information from government records.
Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
Information excluded from the CCPA's scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Information relating to our job applicants, employees, contractors and other personnel.
Collection and Use of Personal Information
In the last 12 months, we have collected the following categories of personal information: