(Effective date: December 14, 2018)
SOURCES OF THE INFORMATION WE COLLECT
(a) On our Websites;
(b) In email messages between you and any of the Websites; and
(c) Through cookies included on the Websites.
TYPES OF INFORMATION WE MAY COLLECT; HOW WE COLLECT INFORMATION; AND HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
Types of Information We Collect
We collect several types of information from and about users of our Websites, including information:
- By which you may be personally identified, such as your name, email address, postal address, telephone number, and any other information which you submit voluntarily to us (“Personally Identifiable Information” or “PII”). You may decide whether or not to provide us with PII, but if you choose not to do so, you may not get full functionality from the Website.
- About your Internet connection, the equipment you use to access our Websites and usage details (g., language), and browsing history, such as your navigation within the Websites and which portion(s) of the Websites you used the most.
How We Collect Information
We collect this information in the following ways:
- Directly from you when you voluntarily provide it to us; and
- Automatically when you navigate through the Websites (g., information collected through cookies).
Information That You Provide Voluntarily
We may collect PII information which you submit voluntarily to us. We collect this information directly from you when you provide it to us, such as, for example, when you provide the information:
- On the Websites contact form.
- When you subscribe to a newsletter on the Websites.
- When you otherwise submit it to us, such as when you send us your resume.
- We may also ask you for information when you report a problem on our Websites.
Non-Personally Identifiable Information Collected Automatically
- Details regarding your visit(s) to the Website (g., pages visited),
- Browser information (g., browser name, viewport or viewing pane); and
- User information (g., language).
Google does not identify individual users or associate your anonymized IP address with any other data held by Google. For information regarding how Google uses data when you use our site, see www.google.com/policies/privacy/partners.
By utilizing this Website, you consent to the use of such automatic data collection techniques (e.g., browser cookies). Browser cookies are small files placed on the hard drive of your computer. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please note that if you turn cookies off, some of the features that make your site experience more efficient may not function properly.
How We Respond to “Do Not Track” Signals
We do not track our visitors over time and across third-party websites. As a result, we do not respond to Do Not Track signals.
HOW WE USE AND/OR DISCLOSE INFORMATION THAT WE COLLECT
We do not sell visitors’ PII. We may use and/or disclose PII we collect about you as follows:
- To present the Websites and their contents to you;
- To provide you with information, products, and/or services that you request from us. For example, when you complete and submit the Contact Us form, we only use that information to respond to your inquiry. By submitting this information to us, you consent to our use of the information to respond to your request. If you complete and submit the Contact Us form for information about a particular service, we will use the information you submit to provide you with that information.
- To fulfill any other purpose for which you provide PII.
- To our contractors and/or vendors, but only for the reason(s) for which you submitted the information to our Websites. These contractors and/or vendors are bound by contractual obligations to keep PII confidential and only use it for the purpose for which we disclose it to them.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To comply with any court order, law, legal process, to respond to any government or regulatory request, and/or to protect or defend our interests or the interests of users of our Websites.
- If we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some of all of our assets, whether as a going concern or as part of a bankruptcy proceeding, liquidation, or similar proceeding, in which the information, if any, that we hold about the users of our Websites is among the assets transferred.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may use the anonymized information we collect through cookies (e.g., anonymized web browser, operating systems, pages visited) to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
DATA SECURITY AND RETENTION
We have implemented physical, technical, and administrative safeguards to protect the security of the PII that you submit to us through our Websites from accidental loss and unauthorized access, use, alteration, and disclosure. We will only retain PII for the length of time necessary to fulfill the purpose for which the PII was submitted or longer, if required by law.
The security of the information we collect about you also depends on you. For example you are responsible for keeping any passwords related to all of these Websites confidential. The transmission of information via the Internet is not completely secure. We cannot guarantee the security of your PII when it is being transmitted to the Websites. Any information which you transmit to the Websites is at your own risk. We are not responsible for circumvention of any privacy setting or security measures contained on the Websites.
CHILDREN UNDER THE AGE OF 13
These Websites are not intended for children under 13 years of age. No one under age 13 may provide any personal information on the Websites. We do not knowingly collect personal information from children under 13 years of age. If you are under 13 years of age, do not use or provide any information on the Websites or on or through any of the features on the Websites or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name. If we learn that we have collected or received personal information from a child less than 13 years of age without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child less than 13 years of age, please contact our Chief Compliance Officer as follows:
CALIFORNIA PRIVACY RIGHTS
Pursuant to the California “Shine the Light” law, California residents may request certain information regarding businesses’ disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.
Pursuant to the California “Consumer Right to Privacy Act of 2018,” California residents may request the following information from us by contacting us as indicated below:
- The categories of personal information we have collected about the consumer.
- The categories of sources from which we collected personal information.
- Our business or commercial purpose for collecting or selling the information.
- The categories of third parties with whom we share personal information.
- The specific pieces of personal information we collected about the consumer.
California residents may also request that we delete any personal information about them which we have collected from the consumer except information collected in certain situations, such as, for example, to complete the transaction for which the information was provided; provide a good or service requested by the consumer; detect security incidents and protect against malicious, deceptive fraudulent, or illegal activity; comply with a legal obligation; and otherwise use the personal information internally in a lawful manner that is compatible with the context in which the consumer provided the information or the consumer’s expectations based on the consumer’s relationship with us.
CANADIAN PRIVACY RIGHTS
Pursuant to the Personal Information Protection and Electronic Documents Act, Canadian visitors to our Websites may also request an accounting of the third parties to whom personal information about them has been disclosed and the uses that have been made of their information.
LINKS TO THIRD-PARTY WEBSITES
We seek to protect the integrity of our site and welcome any feedback about the third-party website links included on our Websites. You may provide such feedback via the Contact Us link on the homepages of our Websites.
HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA)