Our firm cares deeply about the privacy of its visitors and users, and is fully committed to protect their personal information and use it properly in compliance with data privacy laws. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information.
We strongly urge you to read this policy and make sure you fully understand it, before you access or use any of our services.
1. PLEASE READ CAREFULLY!
2. WHAT INFORMATION DO WE COLLECT?
2.1. Visitor and User Information
We collect two types of information regarding our Visitors and Users:
2.2. Users of Users Information
We may also collect similar information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf.
2.3. Jobs Applicant Information
We also collect information that is provided to us by jobs candidates (“Applicants”), when they apply to any of the open positions published, or by e-mail.
3. HOW DO WE COLLECT SUCH INFORMATION?
There are two main methods we use:
4. WHY DO WE COLLECT SUCH INFORMATION?
We collect such Non-personal and Personal Information for the following purposes:
We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:
5. WHERE DO WE STORE YOUR INFORMATION?
Visitors’, Users’ and Users-of-Users’ Personal Information may be maintained, processed and stored by our firm and our authorized affiliates and service providers in the United States of America, in Europe, and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.
Jobs Applicants Information will be maintained, processed and stored on our servers, and as necessary, in secured cloud storage provided by our Third Party Services.
Our firm is based in the United States of America.
Our firm affiliates and service providers that store or process your Personal Information on our behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
Upon request, we will provide you with information about whether we hold any of your Personal Information.
Our data storage providers are contractually committed to protect and secure your data.
6. USERS-OF-USERS’ INFORMATION
Our firm may collect, store and process certain Non-personal and Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with our firm, on the User’s behalf.
For such purposes, our firm serves and shall be considered as a “Processor” and not as the “Controller” of such Users-of-Users Information. The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorized usage of your Users-of-Users’ Personal Information, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.
We cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites, in accordance with the applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they consent to them.
If you are a visitor, user or customer of any of our Users, please read the following: We have no direct relationship with the individual Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by our firm on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If requested to remove any Users-of-Users’ Personal Information, we will respond to such request within thirty (30) days.
7. JOBS APPLICATIONS
Our firm welcomes all qualified Applicants to apply to any of the open positions, by sending us their contact details and CV (“Applicants Information”).
We understand that privacy and discreetness are crucial to our Applicants, and are committed to keep Applicants Information private and use it solely for our firm’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).
Please note that we may retain Applicants Information submitted to it for no longer than two years after the applied position has been filled or closed. This is done so we can re-consider Applicants for other positions and opportunities at our firm; so we can use their Applicants Information as reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to his/her work at our firm.
If you previously submitted your Applicants Information to our firm, and now wish to access it, update it or have it deleted from our systems, please contact us.
8. SHARING PERSONAL INFORMATION WITH THIRD PARTIES
Our firm may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
8.1. Law Enforcement, Legal Requests and Duties:
Where permitted by local data protection laws, our firm may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
8.2. Protecting Rights and Safety:
Our firm may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of our firm, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
8.3. Subsidiaries and Affiliated Companies:
Sharing of Personal Information from our subsidiaries. To clarify, we may share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so. Moreover, our firm may transfer, share, disclose or otherwise use Non-personal Information in its sole discretion and without the need for further approval.
Our firm, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, our Users and their Users-of-Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org.
Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Clear Gifs: We and certain Third Party Services may employ a software technology called “clear gifs” (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however are not stored on your device, but instead embedded within our Services.
Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies. Additional information about managing Flash cookies is available here.
(Please note that this website is not provided by our firm, and we therefore cannot ensure its accuracy, completeness or availability).
Behavioral Targeting/Re-Targeting: Certain Third Party Services and ad networks may display advertising on our Website, on our Apps and on our mobile apps, or manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third party Services to provide you with targeted advertising based on your interests and preferences. You may opt-out of receiving targeted ads from certain advertisers and ad networks by clicking here (or if you are located in the European Union click here (provided by YourChoicesOnline.eu). Please note this does not opt you out of receiving all advertising and that your opt-out will only be in relation to the specific advertising. You will continue to receive advertising for which you have not opted out.
User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and Services that may be of interest to you. Where we obtain your Personal Information from these third parties, we ensure that such parties are contractually committed to inform you that your Personal Information will be disclosed to us and we take steps to ensure the accuracy of your Personal Information before using it. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.
10. COMMUNICATIONS FROM OUR FIRM
10.1. Promotional Messages:
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, direct text messages, marketing calls and similar forms of communication from our firm or our partners (acting on our behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify us at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information which we believe may be of interest or relevance to you, based on your information.
10.2. Service and Billing Messages:
Our firm may also contact you with important information regarding our Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a site Visitor or User (which can be done by deactivating your account).
We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.
11. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
It is imperative that you have control over your Personal Information. That’s why we are taking steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
We will make all reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfill your request), subject to legal and other permissible considerations.
Please note that permanently deleting your account erases all of your information from our databases. After completing this process, you can no longer use any services connected to your account, your account and all its data will be removed permanently, and we will not be able to restore your account or retrieve your data in the future.
12. QUESTIONS AND COMPLAINTS
Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.
We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly. Our target response time is 30 days.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a complaint with your local supervisory authority for data protection.
You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.
13. DATA RETENTION
We may continue to retain such Personal Information even after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to information in our care. Where your Personal Information is no longer required we will ensure it is securely deleted.
Our firm has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by our firm, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Information or any other User Content you upload, publish or otherwise share with our firm or anyone else.
We therefore encourage you to set strong passwords for your User Account and User Website, and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm. Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
15. PUBLIC FORUMS AND USER CONTENT
Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any information you provide in any such areas may be read, collected, and used by others who access them. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, we advise against posting any information (or use any posting means to post information) you don’t wish to publicize on these platforms.
If you upload any User Content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.
We have put adequate security measures in place to protect your Personal Information. However, we cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website (including, for instance, password-protected areas on your User Website). You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.
17. UPDATES AND INTERPRETATION