Last Updated: January 1, 2023
5. Information Company Collects.
5.1. Personal Information: Company may collect information (i.e., via telephone, text, email, paper and/or other interactions through Account, with the Websites or Products) when Customer provides such information on the Website(s) or through Customer Account, signing up for or using the Products or otherwise interacts with Company (collectively, “Personal Information”) (i.e., the types of Personal Information collected may include, but is not limited to, Internet Protocol (IP) address, name, address, telephone number, birth date, billing, and delivery information, email address, information about Customer, credit card or other financial account information, or other identifying information about Customer):
5.1.1. Registration. Register and manage the Account, including to allow access to and use of the Products; process payments or credits; and offer promotional programs.
5.1.2. Improve the Website and Products. Use information for analytical purposes and to enable us to improve the Website andProducts; and provide tailored and/or optimized experience.
5.1.3. Individualization. Notify Customer about special offers and products or services available from Company, its affiliates, or partners.
5.1.4. Communication. Communicate with Customer or facilitate communication between Customer and Company, its affiliates, or partners; conduct, monitor and record interactions with Company, Website and the Products; host reviews, forum posts, photos, videos, and other content; respond to requests, questions and comments.
5.1.5. Legal Compliance. Resolve disputes or troubleshoot problems; prevent fraud and other potentially prohibited or unlawful activities; comply with relevant regulations and laws, respond to legal requests, prevent harm, and protect Company rights; provide payment services, including to detect and prevent money laundering, fraud and security incidents, to comply with legal obligations, and to enforce any applicable terms of service.
Please note, if Company uses automated decision-making technologies to process Personal Information, Company will implement appropriate measures required to safeguard Customer’s rights and freedoms including Customer’s right to obtain human intervention.
5.2.2. Customer can instruct a browser to refuse all cookies or to indicate when a cookie is being implemented.
5.2.3. If Customer does not accept cookies, use of some features of the Websites and/or Products may not be available.
5.3. Do Not Track Disclosure. Company supports Do Not Track (“DNT”). DNT is a preference Customer can enable a web browser to inform websites not to track Customer’s information.
6. How Personal Information is Collected. Company collects Personal Information by telephone, text, email, paper and/or other interactions by Customer with the Websites or Products.
7. How Company Uses and Shares Personal Information.
7.1. Company strongly believes in both minimizing the data collected and limiting its use and purpose to only that (a) for which Company has been given permission, (b) as necessary to deliver the Websites or Products, or (c) as Company might be required or permitted for legal compliance or other lawful purposes.
7.2. Use of Personal Information. Once collected, Company may use Personal Information including, but not limited to:
7.2.1. Provide service communications such as bill reminders, order confirmations, program registrations, and customer service messages;
7.2.2. Respond to Customer emails or online requests for products, services, or information;
7.2.3. Deliver and process surveys;
7.2.4. Processing submitted job applications;
7.2.5. Personalize and improve the usability of the Websites and/or Products;
7.2.6. Fulfill and/or deliver the Products;
7.2.7. Tailor content, advertising, email marketing automation and marketing to Customer;
7.2.8. Share with third-parties as required by law or to protect Company as described herein;
7.2.9. Share Customer’s email address as permitted as described herein;
7.2.10. Communicate with Customer;
7.2.11. Improve and optimize the operation and performance of the Websites or Products;
7.2.12. Diagnose problems with and identify any security risks, errors, or needed enhancements to the Websites or Products;
7.2.13. Detect and prevent fraud and abuse of Company’s systems, Websites or Products;
7.2.14.Collecting aggregate statistics about use of the Websites or Products; and/or
7.2.15. Understand and analyze Customer use of the Websites or Products.
7.3. Transfer of Data Abroad. Utilization of the Websites or Products from a country other than the country where Company’s servers are located, Customer’s communications and interactions with Company may result in transferring Personal Information data across international borders. In such cases, Personal Information data is handled according to this Policy.
7.4. Sharing to Fulfill Service Requests and Perform Business Functions. Personal Information may be shared with certain third parties to fulfill the Customer’s service requests. Company may also share such information with service providers that perform business functions for Company. Subprocessor List. Company only provides data to service providers that have taken appropriate measures to protect such information under contractual obligations on those service providers to ensure each only uses Personal Information to provide for specific services.
7.5. Sharing Personal Information When Legally Necessary or to Protect Company’s Interests. Company may disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on Company, including, but not limited to, compliance with legal, regulatory and law enforcement requests. In such instances, Company cooperates with government and law enforcement agencies and private parties to enforce and comply with the law. Company will disclose any information about Customer to government or law enforcement agencies or private parties as Company, in Company’s sole and absolute discretion, believes necessary or appropriate to respond to claims and legal process (such as preservation requests, warrants, subpoenas or court orders), to protect Company’s property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity Company considers to be illegal or unethical, among other valid legal reasons. To the extent Company is legally permitted to do so, Company will take reasonable steps to notify Customer in the event that Company is required to provide Customer Personal Information to third parties as part of the legal process; (b) protect and/or defend the rights or property of Company; (c) protect the personal safety of Company personnel or users of the public in appropriate circumstances; or (d) if Company and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged or if Company undergoes some other change including a change to its corporate form as part of a bankruptcy proceeding or otherwise, information may be transferred as part of that transaction or change.
8. How to Manage the Sharing of Personal Information. To access, view, or update Customer’s personal data (where available), Customer can sign into Customer’s Account. Customer may also request a deletion of personal data by emailing email@example.com. The request will apply only to the extent that it is no longer necessary for any Products or required for Company legitimate business purposes or legal or contractual record keeping requirements. Please see Company’s Data Processing Addendum for more information located here.
9. How Long Personal Information Will Be Kept.
9.1. Company will keep Personal Information while Customer maintains a Customer Account or while Company provides the Products to Customer. Company will keep Personal Information for as long as is necessary:
9.1.1. To respond to any questions, complaints, or claims made by Customer or on Customer’s behalf;
9.1.2. To show that Company treated Customer fairly; or
9.1.3. To keep records required by law.
9.2. Company will not retain Personal Information for longer than necessary for the purposes set out in this Policy. Different retention periods apply to different types of Personal Information.
9.3. When Personal Information is no longer necessary to be retained, Company will delete or anonymize the information.
10. How Company May Use and Share Non-Personal Data. Through the use of various technologies and tools, Company may collect Non-Personal Data to improve the usability of the Websites and Products and for other legitimate business reasons. Company may share the Non-Personal Data collected with third parties or permit third parties to place tools such cookies, tags, or web beacons, to collect additional Non-Personal Data when browsing the Websites or using the Products. Please note that Customer may be subject to the privacy policies of non-Company companies when selecting an advertising link or other links to websites not operated by Company.
11. Online Tracking Technologies and Advertising.
11.1. Company and certain third-party service providers operating on Company’s behalf collect information about a user, visitor or Customer’s activity, or activity on devices associated with user, visitor or Customer, on the Websites or Products using tracking and analytical technologies as described in this Policy.
11.2. Company may collect information whether or not a user, visitor or Customer is logged in or registered or maintains a Customer Account, and may associate this tracking data with a Customer Account, in which case Company will handle such information as provided in this Policy.
11.3. Advertisers and third parties also may collect information about a user, visitor or Customer’s activity on the Websites and Products, on devices associated with a user, visitor or Customer, and on third-party websites and applications using tracking technologies. Tracking data collected by these advertisers and third parties may be used to decide which advertisements a user, visitor or Customer may see or to track activity both on or through the Websites and Products and on or through third-party sites and applications.
12. Remarketing Services.
12.1. Company uses remarketing services to advertise on third-party websites after visiting the Websites or Products.
13. Privacy Rights and Reporting.
13.1. In addition to the rights as explained in this Policy, under California’s “Shine the Light” law and California Consumer Privacy Act (“CCPA”), and/or the European General Data Protection Rules (“GDPR”), Customers or Website visitors or users who provide personal information (as defined in the Shine the Light law, CCPA and/or the GDPR) using the Website or Products for personal, family, or household use are entitled to request and obtain from Company, once a calendar year, information about the Personal Information Company shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which Company shared such information for the immediately prior calendar year.
13.2. Company receives and responds to all data subject requests and grants the same rights to all, regardless of country, province or state of residence. To obtain this information click here for all requests received over the reporting period and the response provided. The metrics reflect all requests from all submitters.
14. Canada Anti-Spam Law (“CASL”) and GDPR. Website visitors or users who have provided Company a Canadian or European Union mailing address will not receive unauthorized Commercial Electronic Messages (CEMs) as defined under CASL and/or GDPR unless these individuals have opted-in to receive CEMs. To access, view, update, delete or port personal data (where available), or to update subscription preferences, Customer can sign in to the Customer Account. Residents of the European Union Economic Area (EUEA) and to whom believe Company maintains Personal Information subject to the GDPR after contacting Company, may direct questions, requests or complaints to the UK’s Information Commissioner’s Office at www.ico.org.uk, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom, Phone: 0303 123 1113.
15. Data Retention. Company may retain Personal Information for as long as a Customer Account is active or as otherwise needed to provide Customer with the Website or Products. Company may continue to retain such Personal Information even after deactivation of a Customer Account and/or cease to use the Website or Product, as reasonably necessary to comply with Company’s legal obligations, to resolve disputes regarding Customer, prevent fraud and/or abuse, enforce agreements and/or protect Company’s legitimate interests. Company maintains a data retention policy which applies to information in Company’s control. Subject to any legal requirement, if Personal Information is no longer required, Company will use commercially reasonable efforts Personal Information is securely deleted.
16. Age Restrictions. The Websites and Products are not intended for individuals under eighteen (18) years of age. No one under the age of eighteen (18) should provide any Personal Information to Company through the Websites and Products. Company does not knowingly collect Personal Information from individuals under eighteen (18). If reasons exist to believe any individual under the age of eighteen (18) has provided Company with any Personal Information, please contact Company at firstname.lastname@example.org and provide, in detail, the Personal Information (e.g. full name, address, telephone number) requested to be removed.
17. Information Security. Company implements commercially reasonable security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. Company restricts access to Personal Information to certain companies who may require the information in order to operate, develop, or improve the Websites and/or Products. These individuals or organizations are bound by confidentiality obligations, agreements and may be subject to discipline, including termination and civil and/or criminal prosecution for failing to meet these obligations. Company cannot guarantee or warrant the security of any information Customer transmits to Company, or to or from the Websites and/or Products.
18. Linking to Other Internet Websites, Applications or Platforms. Internet websites linked from the Websites or Products or from Company email or other messages may contain privacy provisions that differ from the provisions of this Policy. To ensure Customer privacy is protected, Company recommends that Customer review the privacy statements of these other linked websites, applications, or other digital platforms.
19. How Customer Can Access and Change Information. Customer may review, update and/or correct through the Customer Account profile information or by emailing email@example.com.
20. To View or Print a Copy of Company’s Data Processing Addendum. View or print the DPA
21. Full List of Company Data Sub-processors
22. Company Contact Information: For any questions, concerns or complaints about this Policy, please email firstname.lastname@example.org or send in writing to RamNode., Attn: Data Protection Team, 555 S. Independence Blvd., Virginia Beach, VA 23452. Company will attempt to resolve any complaints regarding the use of Personal Information in accordance with this Policy. Company will respond to all requests, inquiries and/or concerns within thirty (30) calendar days of receipt of a notice or as required by law.