Last Updated: September 1, 2020
1. The information we collect about you
- When you sign up for our Services you give us Personal Data voluntarily by providing it to us, for example when you sign up for an account. We collect and use that information in order to authenticate you when you register an account and use the Services, to make sure you are eligible and able to receive the Services, and so that you receive the correct version of the Services. Depending on which of the Services you use, that may include your name, mailing address, phone number, residency, gender, date of birth (as needed to verify eligibility), and email address. We may collect this information through various forms and in various places on the Service, including at account creation and registration, newsletter sign-up forms, “contact us” forms, or when you otherwise interact with the Service. We use that information to fulfil those Services to you and to provide related customer support to you.
- As a general policy, no personally identifiable information, such as your name, address, or e-mail address, is automatically collected from your visit to the Sites or download and install the Apps. However, we may automatically and passively collect and use certain information from your device whenever you visit, use, or interact with our Service, including: the Internet Protocol address (IP address) of the machine which accessed the Services, general location information, the date and time of your visit, the path taken through the Services, content preferences, the browser and operating system being used, a list of files downloaded or viewed, the amount of time spent accessing files, any errors encountered, crash reports which may be automatically generated when or if our Services crash and includes information about the system and the crash, and other similar data.
- You also give us Personal Data when you make a purchase through us, subscribe to our publications or Subscriptions, or communicate with us. Providing this information is completely voluntary on your part; however, it may be required to use or access some of our Services and Subscriptions. For example, if you choose to contact us via email, we may retain your email and email address along with any other associated information. Doing so is completely voluntary on your part, and you have the choice about whether and what information to disclose via your email.
- We may, from time to time, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.
- In addition, please note, our Services may use third-party platforms to access the Services and/or we may provide third party interfaces or links on the Service to facilitate your sending a communication from the Service. When you use these third-party platforms, the third-party platforms may or may not provide us with information about you. We are not responsible for the terms, policies, disclosures or actions of any third-party platforms.
- Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on bulletin boards, social medial, comments sections, in feedback to us, or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. You acknowledge and agree that you have no expectation of privacy concerning the transmission of any user generated content or communications, including without limitation e-mail, chat, text, or voice communications. Because voice, chat, text, and other communications and user generated content may be viewed and/or heard by other users, users should avoid revealing any personally identifiable information in those communications.
- We may collect certain personal information from you during the course of our normal business operations if you do business with us and/or are employed by us. For example, we may collect certain personal information about you (such as, without limitation, name, email address, date of birth, address, and phone number) either directly from you or from your representative, or from third parties authorized by you.
2. How we use the information we collect about you
We have and rely on a legitimate interest in using your Personal Data as follows: Use of Information by Us. We may use your information:
- to provide you with our Services;
- to improve our Services and to customize your experience with the Services;
- to maintain your account with us;
- for internal business purposes;
- for any purposes disclosed at the time you provide your information;
- any purposes provided for in our Terms;
- to provide technical and customer support to you;
- to offer new or additional features for our Services;
- to enforce our Terms;
- to send you materials by email or via notifications, or other commutations;
- to carry out anti-fraud or other measures prohibited under our Terms;
Third Parties. We may engage vendors, agents, service providers, and affiliated entities to provide services to us. In providing their services, they may access, receive, maintain or otherwise process data on our behalf. Our contracts with these service providers do not permit use of your data for their own marketing and other purposes.
Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you, and any other information that we may have about you as may be permitted or required by law or to prevent or investigate suspected fraud or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information and/or communications in situations that we believe to be: (i) emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat; or (ii) your conduct that we believe is inappropriate and inconsistent with generally accepted norms of behavior.
3. Who we share information with
We will not share any Personal Data that we have collected from or regarding you except as described below:
- run, operate and maintain our Services through third party platform and software tools;
- perform content moderation and crash analytics;
- run email and mobile messaging campaigns;
- perform Service and marketing analytics;
- provide payment attribution and process payments for purchases; and
- provide technical and customer support.
Information Shared with Other Users. When you use the Services, information about you may be shared or visible to other users in certain instances and therefore become publicly available, including without limitation: your username, submitted content and questions, basic location, and public messages.
Information Shared with Our Partners. We may also share information about you with our business and promotional partners to further those interests. However, personally identifiable information is never sold or leased to any third parties.
Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.
Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale, or if assets related to a business unit are acquired by a third party as a result of a transaction, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.
We also use “web beacons” (also known as web bugs, pixel tags, or clear GIFS) which are small graphics with a unique identifier that may be included on our Services for example to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on a user's hard drive or Device, web beacons are typically embedded invisibly on web pages (or in an email).
Types of Cookies
We use the following types of cookies:
- Strictly Necessary Cookies: These are cookies that are essential to enable you to use the Services, for example moving around our websites and using their features (e.g. cookies that enable you to log into the Services).
- Performance Cookies: These are cookies which collect information about how and when you and other visitors interact with our Services (e.g. pages viewed most often) and the information collected by these cookies is used to improve how our Services work.
- Functionality Cookies: These are cookies that allow our Services to remember choices you have made (such as your login information) and provide you with content and features which are customized to you. For example, providing you with relevant content by using a cookie to remember which region you are in.
- Advertising Cookies: These are cookies which are used to deliver adverts to you which are more relevant to you and your interests. We may also share this type of information with third parties for these purposes.
The types of cookies described above may be “session cookies” or “persistent cookies”. Session cookies are only stored on your device whilst you are using the Services, and are deleted when you log off from the Services or close your browser. Persistent cookies remain on your device for a period of time after you log off from the Services or close your browser.
Third Party Cookies
Some cookies may be placed by third parties when you use the Services as some third party service providers that we engage (including third party advertisers) may place their own cookies on your hard drive or Device. These cookies may provide information to those third parties about your browsing habits or may be used for security. Some also help to serve you with advertisements which are more relevant to you. Similarly, if you visit or use third party websites or services linked from our Services, those third parties may place cookies or similar technologies on your device.
For more information about what cookies or similar technologies those third parties use, please review the third party services’ cookie policies.
You may decline cookies that are not Strictly Necessary by clicking “Decline” in the cookie banner at the bottom of your screen. Additionally, although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. However, if you don’t accept cookies, you may not be able to access all portions or features of the Services.
5. How we keep your Personal Data safe
We have appropriate security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. How long we will keep your Personal Data
When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.
7. Your rights and choices
If for any reason you are concerned that any information you provided to us is not correct and you wish to change or delete it, you have the ability to review and update your personal information to the extent we have it. If you would like to do so, please contact us as set forth below or otherwise view and update your information in your Account profile. You may also contact us to request access to, transfer of, or erasure of your personal information to the extent we have any. Specify the nature of your request and the information that is subject to your request.
We reserve the right not to allow access to your information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal information even if you withdraw your consent or request transfer or erasure. Please note that changes or access you request may not be effective immediately. Please also note that despite any request for removal of or change to personal information, we may need to retain certain information for recordkeeping purposes and there may also be residual information that will remain within our databases and other records, which will not be removed or changed.
8. Legal Grounds
We rely on the following legal grounds to use your data:
- Where it is needed to provide you with our Service.
- Where it is in our legitimate interests to do so, such as: managing our products and services, and providing our Service to you.
- To comply with our legal obligations.
- With your consent or explicit consent, where applicable.
- For a public interest.
9. Your Rights Under Data Protection Laws.
Here is a list of the rights that individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not.
- The right to be informed about the processing of your personal information.
- The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed.
- The right to object to processing of your personal information.
- The right to restrict processing of your personal information.
- The right to have your personal information erased (the “right to be forgotten”).
- The right to request access to your personal information and to obtain information about how we process it.
- The right to move, copy or transfer your personal information (“data portability”).
- Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.
If you have any questions or concerns regarding these rights please contact us via the contact information below.
Unless stated otherwise for a particular Service, children are not allowed to use the Services, and we do not collect Personal Data from them. We define “children” as anyone under 18 years old. If a parent has any further questions or concerns about his or her child's use of the Services, we encourage the parent to contact us via the contact information below.
12. Third Parties
13. Disclosures Specific to California Residents
We do not sell your Personal Data and have not done so in the past 12 months. The information listed in Section 1 falls under the following California Consumer Privacy Act (CCPA) categories: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, and visual information.
14. Non-United States Users
Please note that the Services are directed towards users who reside in the United States. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States, where permitted by law. Some of these countries may not offer the same level of privacy protection as your own. Therefore, you should not provide personally-identifying information through the Services. If you provide such information, you acknowledge that it is necessary to internationally transfer and process it in the United States. You also agree that you are responsible for compliance with applicable laws, including local laws regarding online conduct and content and U.S. export laws and regulations.
15. Contact Information