2. PERSONAL INFORMATION
3. COLLECTION OF INFORMATION
4. USE OF PERSONAL INFORMATION
5. DISCLOSURE OF PERSONAL INFORMATION
6. THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING
7. YOUR CHOICES
8. THIRD-PARTY WEBSITES
9. DATA RETENTION
12. UPDATES TO THIS POLICY
13. CONTACTING US
14. CALIFORNIA-SPECIFIC DISCLOSURES
Last updated: May 8, 2023
“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, 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 Service and sometimes, we collect 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.
- Personal Information Automatically Collected
We, and our third-party partners, automatically collect certain types of usage information when you visit our Site, 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, 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, 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 Site (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 Site and to understand more about the demographics of our users.
Collection of Voluntarily Provided Information
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.
- Information from Other Sources and Third Parties
We may receive information about you, including personal information, from third parties, including but not limited to publicly-available sources and data suppliers, businesses with which you interact or from which you otherwise seek to obtain services, businesses with which we offer co-branded services, service providers retained to perform services on our behalf, and social media providers. We 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.
USE OF PERSONAL INFORMATION
We use personal information to: provide services and information that you request; enhance, improve, operate, and maintain the Site, Service, our programs, and other systems; prevent fraudulent use of our Site and Service; tailor your user experience; maintain a record of our dealings with you; conduct research and analytics to understand our customers; develop new products; market our Service; ensure internal quality control; communicate about customer accounts and activities; comply with regulatory and legal requirements; prevent, investigate or provide notice of fraud or unlawful or criminal activity; enforce and carry out contracts and agreements between us and you; protect the safety of any person; address fraud, security or technical issues; protect our rights or property; and for other administrative and internal business purposes.
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 informational 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 providing 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.
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 online browsing history and your interests. We may permit third-party online advertising networks, social media companies, or other third-party services to collect information about your use of our Service over time so that they may play or display ads on other websites, apps, 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 cookies or similar tracking technologies. We may share a common account identifier (such as an e-mail address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. We and our third-party partners may 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.
LinkedIn Ads. We use LinkedIn Ads to recognize you and link the devices you use when you visit our Site on your browser or otherwise engage with us. We share a unique identifier, like a user ID or hashed e-mail address, with LinkedIn to facilitate the service. LinkedIn Ads allows us to better understand how our users interact with our Site and to tailor our advertisements and content to you. For information on how LinkedIn Ads collects and processes data, as well as how you can control information sent to LinkedIn, review LinkedIn’s “Manage Advertising Preferences” page located here (https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences?lang=en). You can learn more about currently available opt-outs, including opting out of targeted advertising here (https://www.linkedin.com/psettings/guest-controls)
- Email Communications
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.
- Interest-Based Advertising
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.
We will usually store the personal information we collect about you for as long as 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.
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.
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%. If 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.
Collection and Use of Personal Information
Purposes for Collecting Personal Information
Sales of Personal Information
We do not sell personal information and will not sell personal information unless we provide proper notice to consumers and, in the case of personal information collected prior to that notice, we obtain explicit consent for the sale of personal information relating to those individuals with whom we previously interacted.
We do not collect or otherwise process sensitive information.
Recipients of Personal Information
Service providers and advisors that perform services for us or 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 Site, 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; and
Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Service.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain exceptions and limitations at law):
- The Right to Know. The right to confirm whether we are processing personal data about you, 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.
- 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.
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 California Consumer Rights
To submit a request to exercise one of the privacy rights identified above, please submit a request by:
- Emailing email@example.com with the subject line “California Rights Request,” or
- Calling 877-6-SNTLNK (877-6-76-8565)
We may need to verify your identity before processing your request, which may require us to request additional personal information from you, including but not limited to email, mailing address, and date of birth. We will only use personal information provided in connection with your 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. 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.
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by applicable California law) to submit requests on your behalf through the designated methods set forth in these CA Disclosures where we can verify the authorized agent’s authority to act on your behalf by:
- For requests to know, access, delete, or correct personal information: receiving a power of attorney valid under the laws of California from you or your authorized agent or receiving sufficient evidence from the authorized agent to show that you have provided the agent a signed permission to submit the request; and (i) verifying your own identity directly with us pursuant to the instructions set forth in these CA Disclosures and (ii) directly confirming 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”: receiving a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
Appealing Privacy Rights Decisions
You may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted at firstname.lastname@example.org.