Privacy Policy
HIPER Global Ltd. (collectively with its subsidiaries and affiliated companies, “Company”, “we”, “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.
Please read this Privacy Policy (or “Policy”) carefully to understand our policies and practices regarding your information. This Policy applies to the information we may collect from you, or that you may provide to us, when you access or use our Website available here, (“Website”), including when you communicate with us electronically through the Website, register for an account on the Website, post a review to the Website, or otherwise access or use any of the features or functionality offered on or through the Website (collectively, our “Services”), as well as when you request technical support or customer support concerning the Website or respond to our invitations and marketing communications, such as emails and SMS/text messages. This Policy also describes our practices for collecting, using, maintaining, protecting, and disclosing that information, as well as your choices and rights regarding your Personal Data.
By accessing or using this Website or responding to our marketing communications (other than to opt out), you agree to our Processing your Personal Data as described in this Policy. If you do not agree with our policies and practices, do not use this Website, respond to our marketing communications (other than to opt out), or provide us with any Personal Data.
The Website is not intended for access or use by anyone under the age of 18 years or under the age of majority in your jurisdiction. If you are not a legal adult, you are not authorized to use the Website or provide us with information, and you should not do so.
This Policy may change from time to time. Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
This Privacy Policy is an integral part of any other agreement between us about your use of the Website (“Terms”). Any capitalized terms not defined herein shall have the meanings ascribed to them in the Terms, or under the applicable privacy laws.
This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below), as required under relevant privacy regulation, including without limitation and where applicable: the EU General Data Protection Regulation (“GDPR”), relevant U.S. Privacy Laws (as such terms is defined below), and the Israeli Privacy Protection Law, 1981. In addition, any reference to the GDPR (as defined below) shall also include the UK Data Protection Act 2018 (UK-GDPR).
This Privacy Policy does not pertain to Personal Data relating to our employees, contractors and other staff as part of their employment or engagement with us. This Policy also does not apply to information collected by us offline, unless otherwise stated herein, or to information collected from third parties, including any third-party websites that may be accessible on or through this Website.
If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us at [email protected].
Table of Contents
- Definitions
- Policy Amendments
- Contact Information and Data Controller Information
- Data Sets We Collect and for What Purpose
- How We Collect Your Information
- Cookies
- Data Sharing
- Data Retention
- Security Measures
- International Data Transfer
- Your Rights
- Third Party Websites
- Eligibility and Children’s Privacy
1. Definitions
The following capitalized terms apply throughout this Policy. Capitalized terms used in this Policy not included below are defined elsewhere in the Policy.
- “Aggregated Data” is information about groups or categories of individuals, which does not identify and cannot reasonably be used to identify an individual.
- “Individual” or “consumer” means a living natural person.
- “Legitimate Interest” is when we have a business or commercial reason to use your information, so long as your own rights and interests do not override this.
- “Non-Personal Data” is any information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual, household, or device.
- “Personal Data” is any information that can identify, relate to, describe, or be linked with a consumer or their household.
- “Process,” “Processing,” or “Processed” means any operation or set of operations performed on Personal Data, including through automated means.
- “Sensitive Personal Data” is Personal Data that reveals a consumer’s (a) social security, Driver’s license, state identification card, or passport number; (b) account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email and text messages, unless the business is the intended recipient of the communication; (f) genetic data; (g) the Processing of biometric information for uniquely identifying a consumer; (h) Personal Data collected and analyzed concerning a consumer’s health; or (i) Personal Data collected and analyzed concerning a consumer’s sex life or sexual orientation.
2. Policy Amendments
We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the Website. The updated date of the Policy will be reflected in the “Last Modified” heading. Any amendments to the Policy will take effect immediately unless we notify you otherwise. If we materially change the way we process your previously collected Personal Data, we will provide you with prior notice or, where legally required, request your consent before implementing such changes. We strongly encourage you to review this Policy periodically to ensure that you understand our most updated privacy practices.
3. Contact Information and Data Controller Information
HIPER Global Ltd. is the Data Controller (as such term is defined under the GDPR or equivalent privacy legislation) of your Personal Data collected from you as a visitor of our Website. You may contact us as follows:
HIPER Global Israel
- Email: [email protected]
- Address: 10 Hamelacha Street, Park Afek, Rosh Haayin, Israel
HIPER Global UK
- Email: [email protected]
- Address: Unit 5 Millars Business Centre, Wokingham, RG41 2TZ, UK
HIPER Global U.S.
- Email: [email protected]
- Address: 1616 Osgood Street, North Andover, MA 01845, USA
4. Data Sets We Collect and for What Purpose
Below you can find information about the purposes for which we process your personal data, our lawful basis for processing, the definitions of “personal” and “non-personal” data, and how we process it technically.
Non-Personal Data
During your interaction with the services, we may collect aggregated, non-personal, non-identifiable information. We are not aware of the identity of the user from whom the Non-Personal Data is collected. We collect Non-Personal Data regarding your use of the services, such as the scope, frequency, latency, pages accessed and viewed, time and date stamp, interactions with content and materials displayed through our services, language preference, and other technical information regarding the device used to access the services, for example type of device, type of browser, operating system, etc.
We may sometimes process and anonymize or aggregate Personal Data and identifiable information in a manner that creates a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified natural person. Non-Personal Data may be used by us without limitation and for any purpose.
If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data.
Personal Data
We may also collect from you, directly or indirectly, during your access to or interaction with the services, individually identifiable information, namely information that identifies an individual or that, with reasonable effort, may be used to identify an individual. The types of Personal Data we collect, the purposes for processing and the lawfulness are specified in the table below.
As part of our Services, we do not knowingly collect or process any Sensitive Personal Data, including that constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health or data concerning a person’s sex life or sexual orientation Additionally, we do not knowingly collect, process or use any of your Sensitive Personal Data as such term is defined under “U.S. Privacy Laws”, which include states that have enacted a comprehensive consumer privacy statute as amended or superseded from time to time and including any implementing regulations and amendments thereto.
The table below details the processing of Personal Data, the purpose, the lawful basis, and the processing operations pursuant to the GDPR.
| Data Set | Purpose and Operations | Lawful Basis per GDPR / UK-GDPR |
| Contact Information | ||
| If you voluntarily contact us, e.g., through the “contact us” form on our Website, you may be required to provide us with certain Personal Data, such as your full name, job title, organization, email address, phone number, country, region, topic, and any additional information you decide to share with us.
We do not collect your signature, Social Security number, Driver’s License number, passport number, physical characteristics or description, state identification card number, insurance notice number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. |
We will use this data to respond to your inquiry.
The correspondence with you may be processed and stored by us to improve our internal operations and, if we reasonably determine it is needed, for future assistance or to handle any dispute you might have with us. We may retain and manage such information using external services and platforms such as CRM systems. |
We process such Contact Information subject to our Legitimate Interest. |
| Online Identifiers and Advertising and Targeting Data | ||
| When you interact with the Website and its services, we may collect online identifiers, such as your Internet Protocol address (IP), Cookie ID, etc. and other information related to your activity through the Website, such as pages viewed, clickstream data, login time and date stamp, etc. This data might be collected directly by us or through our use of third-party cookies and advertising platforms, and it may be shared with our third-party business partners.
Similarly, we may collect Ad calls, which are codes shared with advertisers, including zip code, advertiser ID, the webpage you came from, IP address and approximate location, to help the advertiser determine which ads to place. The ad call will also include your preference regarding interest-based advertisements, as further explained herein. |
Collection of device identifiers is needed for the following purposes:
|
Our lawful basis for processing this data for technical and security purposes is based upon our Legitimate Interest. If we process your Personal Data for analytics and advertising purposes, and to the extent required under applicable laws (e.g., when using third-party cookies), we will obtain your consent for such processing. In any such case, you may withdraw consent or change your preferences at any time by using the cookie settings tool available on our Website. |
| Newsletter and Updates | ||
| In the event you sign up to receive our promotional materials, or where we are permitted to use your details for such purposes under applicable law, you will be requested to provide your contact details, such as your email address. | We will use the information you provide to add you to our mailing list and send you the materials you have signed up for. If you have provided us with your phone number, we may also use it for SMS delivery, always in accordance with applicable law, and you may opt out where required under such law. | Our lawful basis for the processing of this data is your consent. In other cases, we may use your contact details for marketing purposes without obtaining your explicit consent as permitted by applicable law.
You may withdraw your consent at any time by clicking the “unsubscribe” link, which will be included in the email we will send you. You may also contact us via the above contact methods to request to unsubscribe. Please note that even after unsubscribing from any marketing content, you may still receive operational and other emails, in accordance with applicable law. |
| Recruitment Data | ||
| If you wish to apply for a job, you may voluntarily submit your CV through our communication channels. | We will use your CV and the information you provide to process your job application for recruitment purposes and assess your suitability. | We will process basic recruitment data subject to our Legitimate Interests to consider your application and respond.
If we move forward with you in the recruitment process, or if you have initiated the recruitment application, at an advanced stage of the negotiations, we will process your data as part of our contractual relationship with you. |
Please note that the actual processing operation for each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the Data Transfer Section below, is based on the same lawful basis as stipulated in the table above.
In the twelve (12) months before the “last updated” date of this Policy, and pursuant to the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”), we have collected the following categories of Personal Data from individuals.
| Category | Examples of Information Collected | |
| Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
We do not collect Social Security numbers, Driver’s license numbers, or passport numbers. |
|
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, address, telephone number, employment and employment history (i.e. your company name, title, and contact information), bank account number, credit card number, or any other financial information for payment purposes.
We do not collect your signature, Social Security number, Driver’s License number, passport number, physical characteristics or description, state identification card number, insurance notice number, medical information, or health insurance information. |
|
| Protected classification characteristics under California or federal law | We do not collect this information, for example, age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | |
| Biometric information | We do not collect this information, for example, genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | |
| Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | |
| Geolocation data | We may collect general physical location or movement data only within a 25-mile radius, and only if you have enabled and consented to the collection of location information.
We do not collect precise geolocation information. |
|
| Sensory data | We do not collect this information, for example, audio, electronic, visual, thermal, olfactory, or similar information. | |
| Professional or employment-related information | We may collect information regarding your current job, such as your company name, title, and contact information.
We do not collect other employment-related information, for example, performance evaluations. |
|
| Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | We do not collect this information, for example, education records directly related to a student that are maintained by an educational institution or a party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | |
| Inferences drawn from other Personal Information | We do not collect this information, for example, a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
However, our Website may be affiliated with third parties that collect this information. |
|
| Account access information | We do not collect this information, for example, Login, Account, or Financial Card Number, in combination with the required Access Code. |
In addition, we may use certain Personal Data to comply with professional or regulatory obligations or to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity theft, and any other misuse of the services and to enforce the Terms, as well as to protect the security or integrity of our databases, services, and the Website, and to take precautions against legal liability. Such processing is based on our Legitimate Interests.
We may also use certain Personal Data:
- To fulfill or meet the reason you provided the information.
- To provide, support, personalize, and further develop our Website, products, and/or Services. This includes sharing your Personal Data, browser activity, and device information with internet service providers, data analytics providers, social networks, and operating systems and platforms.
- To process your requests.
- To support you and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To send you our promotional materials or those of our affiliates, business partners, service providers, and advertising networks.
- To enforce or apply our policies and other agreements, including for billing and collection purposes.
- To personalize your website experience and to deliver content relevant to your interests, and via email or text message (with your consent, where required by law).
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Data.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Website users is among the assets transferred.
- Where you consent.
5. How We Collect Your Information
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:
- Automatically – we may use cookies (as elaborated in the section below) or similar tracking technologies (such as pixels, tags, agents, etc.) to gather some information automatically, including
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
- Information about the types of marketing communications that you open and/or to which you respond.
- Page URLs and referrers.
- Provided by you or about you voluntarily – we will collect information if and when you choose to provide us with the information, such as through the Contact Us form or otherwise through the Website, sign-up for offers, updates, and other communications, complete forms on or through the Website, create or update an account, submit reviews and other content to the Website, or participate in surveys, sweepstakes, contests, or promotions offered on or through the Website.
- Provided from third parties – where permitted under applicable law and provided with your consent for cookie usage, we may enrich the Personal Data collected about you with data provided by third parties.
6. Cookies
When you access or use the Website, we use “cookies” or similar tracking technologies that store certain information on your device (i.e., locally). The use of cookies is standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. We use cookies for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical, analytical and advertising purposes. You can find more information about our use of cookies at www.allaboutcookies.org.
There are several types of cookies, including, without limitation:
- Essential, Functionality, Operation & Security Cookies: These cookies are essential for enabling visitors to navigate the Website, for the Website to function properly, and for security purposes (i.e., to authenticate visitors, prevent fraudulent use, and protect visitor data from unauthorized parties). This category of cookies cannot be disabled, or if disabled, certain features of the Website may not work.
- Analytic, Measurement & Performance Cookies: These cookies are used to collect information about how visitors use our Website to improve our Website, content, and the way we deliver them, as well as to assess the performance of content and marketing campaigns. These cookies, for example, enable us to assess the number of visitors who have viewed a certain page, as well as their country of origin. It enables our Website to remember information that changes the way it behaves or looks, such as your preferred language.
- Preference, Targeting & Advertising Cookies: These cookies are used to advertise across the internet and to display relevant ads tailored to visitors based on the parts of the Website they have visited (e.g., a cookie will indicate that you have visited a certain webpage and will show you ads related to that webpage).
We use first-party and third-party cookies on the Website. We use essential, functional, analytics, and targeting/advertising purposes on the Website.
You may find more information about the cookies we use, as well as opt out of cookies or change your preferences at any time by using the cookie settings tool available on the footer of our Website and in the Your Rights section below.
If you wish to restrict or disable cookies, please follow the browser-specific instructions on www.aboutcookies.org, which provides information about preventing the use of cookies across a variety of browsers, or review the instructions provided by your browser. You may also opt out of certain non-essential cookies through our Website banners. Keep in mind that these settings may apply to all websites you visit and may affect their functionality.
For mobile devices, you may need to refer to the specific instructions for your device.
Where we use third-party advertising cookies, such third-parties may receive and independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies, and we are not responsible for their privacy practices.
Although we do not sell your Personal Data in exchange for money, we do engage in targeted advertising on the Website. This type of advertising activity may be considered a “sale” of Personal Data under certain U.S. Privacy Laws and may also be referred to as “targeted advertising”. Please note that even if you opt out, you may still see personalized ads based on information other companies and ad networks have collected about you through third-party cookies that we do not control, if you have not opted out of sharing with them.
For IBA opt-out options on desktop and mobile websites, please visit:
- Digital Advertising Alliance (U.S.)
- Digital Advertising Alliance (Canada)
- Digital Advertising Alliance (EU)
- Network Advertising Initiative
We also honor browser-based opt-out signals, such as the Global Privacy Control (GPC) and Universal Opt-Out Mechanisms (UOOM), by automatically disabling non-essential cookies when such signals are detected.
7. Data Sharing
We share your data with third parties, including our partners or service providers that help us operate and make the most of the Website. You can find here information about the categories of such third-party recipients.
| Categories of Participants | Additional Information |
| Our Affiliated Companies | We may share Personal Data with our affiliated companies and subsidiaries to provide joint services, such as marketing and service improvement. |
| Our Service Providers | We share your Personal Data with our trusted service providers and business partners that perform business operations for us on our behalf (as data processors) and pursuant to our instructions. This includes the following categories of service providers:
|
| Legal and Law Enforcement | We may disclose certain Personal Data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other visitor to legal liability, and solely to the extent necessary to comply with such purpose. |
| Corporate Transactions | In the event of a corporate transaction (e.g., the sale of a substantial part of our business, a merger, a consolidation, or an asset sale), we will share the Personal Data we store with our acquiring company.
In any such case, we will oblige the acquiring company to assume the rights and obligations as described in our Privacy Policy. |
Pursuant to CCPA/CPRA, in the twelve (12) months prior to the “last updated” date of this Policy, we have disclosed the Personal Information detailed in the chart found in Data Sets We Collect And For What Purpose for a business purpose to the categories of third parties indicated in the chart below.
| Category | Disclosed To |
| Identifiers | Service Providers, Advertisers |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
Service Providers, Advertisers |
| Commercial information | Service Providers, Advertisers |
| Internet or other similar network activity | Service Providers, Advertisers |
| Geolocation data | Service Providers, Advertisers |
| Professional or employment-related information | Service Providers |
When we share information with service providers, we ensure they have access only to information strictly necessary for us to operate the Website, as disclosed in this Policy. These parties are required to secure the data they receive and to use the data for pre-agreed purposes, while ensuring compliance with all applicable data protection regulations (however, such service providers may use certain data for their own benefit, subject to separate terms agreed upon with you or per your consent, as well as in the case of using merely Non-Personal Data).
8. Data Retention
In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, in accordance with applicable regulations, or, where applicable, until you express your preference to opt out.
The circumstances in which we will retain your Personal Data include:
- Where we are required to do so in accordance with legal requirements.
- For us to have an accurate record of your interaction with us in the event of any inquiries or contact requests.
- If we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that, except as required by applicable law, we will not be obliged to retain your data for a particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.
9. Security Measures
We take great care in implementing physical, technical, and administrative security measures for the Website and services, which we believe comply with applicable regulations and industry standards, to prevent your information from being accessed without proper authorization, improperly used or disclosed, unlawfully destroyed, or accidentally lost.
If you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data, please contact us at our email.
10. International Data Transfer
Due to our global business operations, we may store or process your Personal Data in several territories, including, for example, Israel, the UK, the EU, the U.S., or other countries (whether directly or indirectly through our vendors). Thus, your Personal Data may be transferred to and processed in countries other than the country from which you accessed our Website or otherwise the country of your jurisdiction. We will take appropriate measures to ensure that your Personal Data is afforded an adequate level of protection upon transfer, in accordance with applicable law.
Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has determined provides adequate protection), it shall be transferred under the standard contractual clauses approved by the European Union. If you would like to learn more about these arrangements and your rights in connection therewith, please contact us via email.
In addition, some third parties used for cookie management on our Website may store and process data globally, including in the U.S. (e.g., Google Analytics servers). By granting consent to such cookies, you hereby acknowledge and approve the cross-border transfer of your data in accordance with the third party’s privacy practices.
11. Your Rights
You can exercise certain controls and choices regarding our collection, use and sharing of your Personal Data. In accordance with the laws that may apply to you, your controls and choices may include:
Right to Know/Right To Access
You have the right to know what Personal Data we collect about you. Upon receipt of your request and confirmation of your identity, we will disclose to you:
- The categories and specific pieces of Personal Data that we have collected about you in the past 12 months.
- The sources from which we have collected that information.
- Our business or commercial purpose for collecting such information.
- The categories and specific pieces of Personal Data that we have disclosed to third parties for a business purpose during the past twelve months.
- The categories and specific pieces of Personal Data that we have sold to third parties during the past twelve months.
- The third parties to whom we have disclosed or sold such Personal Data.
In most cases, you may request this information up to two times each year.
Right to Data Portability
You have the right to request a copy of the Personal Data we have about you. We will provide it in a format of our choosing that you can reasonably transfer to a third party.
Right to Correction/Right to Rectification
You have the right to request that we correct any inaccurate Personal Data that we may maintain about you, subject to applicable legal exceptions. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or render the information incorrect.
Right to Delete/Right to Erasure
You have the right to request that we delete your Personal Data, subject to applicable legal exceptions. If you submit this request, we will review it and attempt to confirm your identity. Once we confirm your identity, and assuming no exception applies that requires or allows us to retain your Personal Data, we will delete it and direct our service providers to do the same.
We may deny your deletion request in certain instances, including if, for example, retaining the Personal Data is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with any international, national, federal, state, or local laws, rules or regulations, applicable to us or to your Personal Data.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation or other lawful uses.
Right to Opt Out of Targeted Marketing and Profiling
We engage in targeted advertising and profiling. You (or your authorized representative) have the right to opt out of targeted advertising and profiling, and can do so by completing the Data Subject Request Form (“DSR”) available here and sending it to [email protected].
Right to Opt Out of Sale or Sharing of Personal Data
You have the right to “opt out” of the “sale” or “sharing” of your Personal Data to or with “third parties” (as those terms are defined by applicable law). There may be situations in which we cannot fulfill your requests if you opt out of such sharing; we will notify you if this applies.
To opt out of the sale or sharing of your Personal Data, you or your authorized representative can fill out the DSR available here and send it to our email at [email protected].
Right of No Discrimination or Retaliation
We will not discriminate against you for exercising any of your privacy rights.
Exercising Your Rights
You may fill out the DSR available here and send it to our email at [email protected]. You may also complete the DSR form if you do not want us to share your Personal Data with unaffiliated or non-agent third parties for promotional purposes.
Once you request to exercise your data privacy rights, we will wait at least twelve (12) months before asking you to reauthorize Personal Data sales or sharing. However, you may change your mind and opt back in to our use of your Personal Data by contacting us as provided in the Contact Information and Data Controller Information section. You do not need to create an account with us to exercise your privacy rights. We will use the Personal Data provided in your privacy rights request only to review and comply with it.
We do not control third parties’ methods for collecting or using your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI website.
When you contact us to exercise your rights regarding your Personal Data, we will require certain information from you to verify your identity and locate your data. The process of locating and deleting the data may take a reasonable amount of time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
In certain circumstances, and subject to applicable U.S. Privacy Laws, you may permit an authorized agent to submit requests on your behalf. For more information, please refer to our DSR form.
You have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with how we handled your complaint.
Your U.S. Jurisdictional Privacy Rights
Residents of the following states may have the privacy rights set out above: California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia.
California Shine the Light Act
We may share visitors’ Personal Data with third parties for those parties’ direct marketing use. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Data by the company to third parties for the third parties’ direct marketing purposes. Residents who wish to exercise this sale opt-out right may do so as provided for in this section.
Nevada
Nevada provides its residents with a limited right to opt out of certain sales of Personal Data. Residents who wish to exercise this sale opt-out right may do so as provided for in this section.
You should check the laws of your state of residence to determine whether these rights apply to you. The exact scope of these rights may vary by state. Data privacy laws are constantly evolving, and the list of states with data privacy laws herein may not be all-inclusive.
Responding to Your Data Rights Request
For U.S. residents exercising data privacy rights, we endeavor to confirm receipt of all requests within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us using the Contact Information and Data Controller Information to ensure we have received your request.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt, or as otherwise required by U.S. Privacy Laws. If we require more time (up to an additional 45 days), we will inform you in writing of the reason and the extension period.
The information in our response will cover the 12 months preceding our receipt of your request. If we cannot comply with your request, in whole or in part, our response will explain the reasons.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will explain why and provide a cost estimate before completing your request.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm that the Personal Information relates to you.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. You do not need to create an account with us to exercise your privacy rights.
Appeals
If we decline to take action on your request, we will inform you within 45 days (Colorado residents) or 60 days (all other U.S. jurisdictions) of receipt. Our response will include a justification for the decision and an explanation about your right to appeal. If you wish to do so, please send your appeal request, including a summary of the request and the decision you want to appeal, to [email protected].
If you are not happy with our response, depending on your jurisdiction, you may have the right to lodge a complaint against us with the relevant State’s Attorney General.
- Colorado Attorney General
- Connecticut Attorney General
- Delaware Attorney General
- Iowa Attorney General
- Oregon Attorney General
- Montana Attorney General
- Nebraska Attorney General
- New Hampshire Attorney General
- New Jersey Attorney General
- Oregon Attorney General
- Tennessee Attorney General
- Texas Attorney General
- Utah Attorney General
- Virginia Attorney General
If you do not have your Attorney General’s contact information, please contact us at [email protected], and we will endeavor to provide the relevant information to you.
12. Third Party Websites
Our Privacy Policy only addresses the use and disclosure of Personal Data we collect from you. To the extent that you disclose your Personal Data to other parties via the Website (e.g., by clicking on a link to any other website or location), different rules may apply to their use or disclosure of the Personal Data you disclose to them. This Privacy Policy does not apply to any such third-party products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.
13. Eligibility and Children’s Privacy
Our Services are not directed nor intended for use by children, and we do not knowingly process, sell or share children’s information. We will delete any information we receive from a user who is considered a “child” immediately upon discovering that such a user shared information with us. Please contact us at [email protected] if you have reason to believe that a child has shared any information with us.
