Telestream, LLC ("Telestream") values your privacy. In this Privacy Policy ("Policy"), we describe how we collect, use, and disclose personal information that we obtain about visitors to our websites including, but not limited to, telestream.net and other sites that link to this Policy (collectively, the "Site”) and our services (collectively, the "Services").
By visiting the Site, or using any of our Services, you acknowledge that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and the terms of use.
The information we collect through the Site and Services is controlled by Telestream LLC, which is headquartered in the United States at 848 Gold Flat Road, Nevada City, California 95959, USA. If you contract with one of our EU or UK affiliated entities, then that entity also will be a controller of your personal information and that contract governs the processing of personal information.
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WHAT PERSONAL INFORMATION DO WE COLLECT?
While the personal information we collect varies depend upon your use of our Site and Services and our interactions with you, we may collect personal information about you directly from you and from third parties, as well as automatically through your use of our Site or Services.
Personal Information We Collect Directly from You:
- Customer Service and Support. When you contact us for support or other customer service requests, we maintain support tickets and other records of your requests/ related communications.
- Account Services. When you register or create an account, we may collect your name, email address, address, phone number, business contact information, organization name, job title, account name and password.
- Communications. We collect the personal information you provide such as contact information and records of our communications including through our Services and our chatbot.
- Transaction and Billing Information. When you purchase a product or Service from us, we collect purchase information, including payment card information through a third-party processor.
- Surveys. When you fill out a survey, we collect your response, which depends on the type of survey, but may include contact information and your satisfaction with a product or Service.
- Events. We also collect personal data related to your registration for and participation in our events.
- Sweepstakes, Contests, and Promotions. If you participate in sweepstakes, contests, and promotions that we offer, we will collect your name, age, email address, and other registration information related to contests, sweepstakes, and promotions.
- Other Information. We may collect other personal data that you consent to or would reasonably expect based on the nature of the circumstances.
Personal Data Collected from Third Parties. We may collect personal information about you from third party sources such as public databases, including advisors and agents, affiliates and subsidiaries, Internet service providers, operating systems and platforms, data brokers and analytics providers, advertising network and marketing companies, business partners, clients, social media platforms, or other third parties.
When providing certain services to our corporate customers, to which you are related (e.g., if you are an employee, apprentice, trainee, end user, etc. of our corporate customers), we may process some personal information about you, including identification data; contact data and professional data. We process such personal information in the context of the provision of the Services to our corporate customers. Please note that in such situations, the corporate customer is the controller of your personal information, and you should refer to the corporate customer’s privacy notice to understand how your personal information is handled.
Personal Information We Collect Automatically. We and third parties may automatically collect the following information about your use of our Site or Services through cookies, web beacons, chatbots, and other technologies:
- Device and Browsing Information. When you visit our Sites and Services, we may collect information, which may be considered personal data under certain laws, such as your domain name; your browser type and operating system; web pages you view; links you click; your IP address; Internet service provider; language; the length of time you visit our Site and/or use our Services; unique IDs; and the referring and exiting URLs.
- Activities and Usage. We also collect activity information related to your use of the Site and Services, such as information about links clicked, searches conducted, features used, items viewed, time spent on certain pages, your interactions with us, log file information, and other activity and usage information.
We may combine this information, which may be considered personal information in some locations, with other information that we have collected about you, including, where applicable, your username, name, and other personal information. Please see the section Cookies and Other Tracking Mechanisms below for more information.
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HOW WE USE PERSONAL INFORMATION
We use personal information, for the following purposes:
- Services and Support. To provide our Site and Services to you, to communicate with you, to respond to your inquiries, to fulfill your orders, and for other operational and customer service purposes.
- Customization and Personalization. To tailor the content and information that we may send or display to you, to offer customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services.
- Marketing and Promotional Purposes. For example, we may use your personal information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Services on third party websites.
- Analytics and Improvement. To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.
- Planning and Managing Events. For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
- Research and Surveys. To administer surveys and questionnaires, such as for market research or customer satisfaction purposes.
- Sweepstakes, Contests and Promotions. To facilitate your participation in sweepstakes, contests and promotions including to communicate with you about your involvement in the sweepstake, contest, or promotion.
- To administer our corporate customer contracts. For example, we will use a customer’s employee’s contact information to send our invoices or to send service communications to. The personal information we collect from our business customers is governed by the contract we have in place with our business customers and not this Policy.
- To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
- To protect the safety, rights, property, or security of Telestream, our services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that Telestream, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; to conduct audits; and to enforce this Policy or our Terms of Service.
- General Business and Operational Support. Related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.
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HOW WE SHARE PERSONAL INFORMATION
We may share your personal information, as follows:
- Telestream Users. Your username and any information that you post to any area on our Site such as reviews, comments, and text will be available to, and searchable by, all users of that area of our Site.
- Corporate Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
- Processors and Service Providers. We may disclose the personal information we collect from you to service providers, contractors or agents who perform functions on our behalf.
- Third Parties, Platforms, and Services. We may disclose or make available personal information to third-party platforms and providers or as necessary to respond to your requests.
- Advertising Networks & Analytics Companies. We may share information you provide us with advertising networks, search engines, social media platforms, sponsors and/or traffic measurement services, who use this data to improve and measure the effectiveness of our ads and to serve targeted ads to you on third-party websites and platforms. For more information, including how to opt out of interest-based advertising, see Cookies and Other Tracking Mechanisms and Your Privacy Choices below.
- Business Transfers. If we are acquired by or merged with another company, if some or substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the personal information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others. We also may disclose the personal information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence.
- Other Disclosures. We may disclose your personal information for other purposes, which we will notify you of and/or obtain your consent when required.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or other purposes.
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COOKIES AND OTHER TRACKING MECHANISMS
Our Site and Services use cookies and other trackers to distinguish you from other users of our Site and Services. This helps us provide you with a good experience when you browse our Sites and also allows us to improve our Sites.
Your Consent. By continuing to use our Sites, you are agreeing to the placement of cookies, chatbots and other trackers on your device and/or browser by us and our service providers.
If you do not wish to accept cookies in connection with your use of our Sites, you must stop using our Sites, disable cookies via your browser settings (see below), or disable cookies individually. Please note that disabling cookies will affect the functionality of our Sites and may prevent you from being able to access certain features on our Sites.
If you wish to withdraw your consent at any time, you will need to delete your cookies using your internet browser settings, and disable cookies. Please note that disabling cookies will affect the functionality of our Sites and may prevent you from being able to access certain features on our Sites. For further information about deleting or blocking cookies, please visit:
www.aboutcookies.org and
What Choices Do I Have Regarding My Personal Information? below.
What is a Cookie? A cookie is a small file of letters and numbers that we store on your browser and/or your device. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit one of our Sites. Clear GIFs are tiny graphics with a unique identifier that are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags), in connection with our Sites and Services to, among other things, track the activities of visitors, help manage content, and compile statistics about Site usage. We and third parties use clear GIFs in emails to help track email response rates, identify when emails are viewed, and track whether our emails are forwarded.
Some cookies collect the personal information entered into a form on our Sites and your IP address, the duration of your browsing session, your browser type and your operating system.
We use cookies, chatbots, tracking technology and the personal information they collect for the following reasons: to remember browsing preferences such as local language; to remember details about your previous visits to a Site in order to personalize and improve your browsing experience; to administer and organize a Site; to analyze use of the Site in order to make improvements to the Site; and to compile statistics, and understand and improve the usage of our Site.
First and third-party cookies: whether a cookie is 'first' or 'third' party refers to the domain placing the cookie.
First-party cookies are those set by a website that is being visited by the user at the time (e.g., cookies placed by
www.telestream.net).
Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie.
Persistent cookies: these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies: these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
How to delete and block our cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of our Sites or Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit one of our Sites or Service.
Changing your cookie settings. Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. Otherwise, you should use the 'Help' option in your internet browser for more details.
What cookies do we use and why?
Generally, our Sites use cookies to distinguish you from other users of our Sites. This helps us to provide you with a good experience when you browse our Sites and also allows us to improve our Sites. The cookies used on our Sites are categorized as follows:
Strictly Necessary cookies let you move around the Sites and use essential features like secure areas. Without these cookies, we cannot provide the requested Services. We use these Strictly Necessary cookies to: Identify you as being logged in to one of our Sites and to authenticate you; Make sure you connect to the right service on a Site when we make any changes to the way a Site works and for security purposes. Accepting these cookies is a condition of using our Sites.
Performance cookies collect information about how you use our Sites, such as which pages you visit, and if you experience any errors. These cookies are used to help us improve how our Sites work, understand what interests our users, and measure the effectiveness of our advertising.
We use performance cookies to: Carry out web analytics: Provide statistics on how our Sites are used; Perform affiliate tracking: Provide feedback to affiliated entities that one of our visitors also visited their website; Obtain data on the number of Site users that have viewed a product; Help us improve a Site by measuring any errors that occur; and Test different designs for a Site.
Functionality cookies are used to provide services or to remember settings to improve your visit.
We use functionality cookies for such purposes as: Remember settings you've applied such as layout, text size, language, preferences and colors; Remember if we've already asked you if you want to fill in a survey; Remember if you have engaged with a particular component or product list on a Site so that don’t show it again; Show you when you're logged in to a Site; and To provide and show embedded video content.
Targeting cookies are used to track your visit to our Sites and other websites, including the pages you have visited and the links you have followed, which allows third parties to display targeted ads to you on the websites you visit.
We and third parties use targeting cookies to: Link to social networks, like Facebook, that may subsequently use information about your visit to our website in order to provide advertising or other offers that may be of interest to you when you visit other websites, and Provide third parties with information on your visit so that they can present you with advertisements or other offers that may be of interest to you.
In some cases such as in the EU or UK, we will require your opt-in consent to deploy cookies, pixel tags and other similar tracking mechanisms on your device. Where this is required, we will present you with a consent request and further information on how we use such technologies.
Third Party Analytics. We and third parties, such as Google Analytics, use automated devices and applications, and other analytic means to evaluate and improve our Sites and Services, performance, and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at
https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at
https://tools.google.com/dlpage/gaoptout/.
Third Party Ad Networks. We work with third party companies such as Google, Facebook and others who use tracking technologies to customize, measure and serve advertisements and other content. These companies may collect personal information about your online interaction with us, including advertising. Network advertisers are third parties that display advertisements based on your visits to our Site as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your usage of our Site and our services, as well as aggregated, deidentified and personal information about visitors to our Site and users of our service.
Cross-Device Tracking. We and third parties may use the information we collect about you within our Sites and on other third-party websites and services to help us and these third parties identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.) to interact or engage with us or the Sites.
User Generated Content. We invite you to post content on our Site (where applicable), including your comments, pictures, and any other information that you would like to be available on our Site. If you post content to publicly available areas of our Site, all of the information that you post will be available to all visitors to our Site users. If you post content to areas that require a log-in, all of the information that you post will be available to registered users of that area. If you post your own content on our Site or Services, your posting may become public and Telestream cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.
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THIRD PARTY LINKS AND APIs
Our Site and Services may contain links to third party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites. We use Third Party APIs including ScreenFlow, Wirecast, and Wirecast GO that make use of the YouTube API Services. Please see the Google Privacy Policy at
https://policies.google.com/privacy#infochoices for more information about how Google and YouTube use personal information and your choices. Users can revoke access to their data via the Google security settings page at by logging into your Gmail account at:
https://security.google.com/settings/security/permissions. These APIs make use of the following API functions: View and manage your videos and playlists; View and manage your YouTube activity, including posting public comments; and See, edit and delete your videos, playlists and subscriptions, rate videos, as well as post, edit or delete your comments and captions.
Security. We have implemented measures designed to protect certain personal information that we collect. Please be aware that despite our efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust and unique password for each account that nobody else knows or can easily guess, and keeping your username and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
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WHAT CHOICES DO I HAVE REGARDING PERSONAL INFORMATION?
We may send periodic promotional or informational emails to you in accordance with applicable law. You may opt-out of such communications by following the opt-out instructions contained in the email. We may still send you emails about your account or any Services you have requested or received from us.
You may modify personal information that you have submitted by logging into your account and updating your information or by contacting us using the contact information provided below. Please note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of the Site for a period of time.
Industry ad choice programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Sites and those of third parties, in order to display more relevant targeted advertising to you.
Opting out from one or more companies listed on the industry ad choice programs will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the industry websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info.
Custom Lists and Matching. Unless you have opted out, we may share certain hashed customer list information (such as your name, email address and other contact information) with third parties so that we can better target ads and content to our users and others with similar interests within third party sites, platforms and services. For further information on how to opt out or exercise your preferences, please visit
https://www.telestream.net/company/opt-out.htm.
If you are a resident of the European Union or United Kingdom, please see the Information for EU/UK Individuals section below for additional information on accessing your information and other legal rights available to you.
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CHILDREN
Our Services are not designed for children. If we discover that a child has provided us with personal information, we will delete such information from our systems in accordance with applicable law.
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INFORMATION FOR EU/UK INDIVIDUALS
When we act as Data Controller. If we process your personal information in our capacity as a data controller, the following applies:
We collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
- Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (for example when you choose to purchase software from us);
- Our use of your personal information is in our legitimate interest as a commercial organization (for example in order to make improvements to our products and services and to provide you with information you request); you have a right to object to processing as explained in the section below titled Your Legal Rights;
- Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court); or
- Our use of your personal information is in accordance with your consent (for example, when your consent to the receipt of marketing communications is required by local law).
If you would like to find out more about the legal bases on which we process personal information, please contact us using the details below.
Your Legal Rights. Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, EU/UK individuals have certain rights in relation to your personal information:
Right to access, correct, and delete your personal information: You have the right to request access to the personal information that we hold about you and (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
You also have the right to request that we delete your information. We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or deference of legal claims.
Right to restrict the processing of your personal information: You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data.
We can continue to use your personal information following a request for restriction, where: (i) we have your consent; (ii) to establish, exercise or defend legal claims; or (iii) to protect the rights of another natural or legal person.
Right to data portability: To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.
Right to object to the processing of your personal information: You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction: You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EEA/UK.
Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
How to Exercise Your Rights: If you would like to exercise any of the rights described above, please send us a request to gdpr@telestream.net. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
If we process your personal information as a data processor: For certain activities where we provide services to our customers, we act only on the instruction of those corporate customers. In those situations, the corporate customer is the Data Controller for that purpose. Where we process your data in our capacity as a data processor on behalf of the Data Controller, the processing of your data will not be governed by this Policy, but you can contact the corporate customer directly to learn about their processing of your personal information and to exercise your rights, or we will forward your request directly to our corporate customers.
International Transfer of Information. We may transfer personal information to service providers and other recipients who are outside your location, where the level of data protection may not be equivalent to the level at your location.
Telestream generally maintains servers and systems in the United States hosted by service providers. We also may subcontract the processing of your personal information to, or otherwise share your personal information with, other third parties in the United States or countries other than your country of residence. Where required by applicable laws, we will take steps to ensure that any transfer of personal information outside of the originating jurisdiction is managed to protect your privacy rights and to will ensure that adequate safeguards are in place. As a result, where the personal information that we collect through the Site, Services, or in connection with providing services to or administering our relationship with a corporate customer is transferred to and processed in the United States or anywhere else outside the European Economic Area (EEA) or UK for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA or UK, including entering into data transfer agreements, using Standard Contractual Clauses, or by relying on other valid transfer mechanisms.
Where applicable, you are entitled to receive a copy of the contractual safeguards implemented to protect your personal data during such transfer. You can obtain a copy by contacting us using the information in the Contact Us section. However, please note that we may redact data transfer agreements to protect our commercial position or prevent a security risk.
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NOTICE AT COLLECTION AND IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include publicly available data as defined by the CCPA. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments, deidentified or aggregated information, or other personal information that is subject to an exemption under the CCPA. This section also does not apply to personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of Telestream or any affiliated entities.
Categories of Personal Information That We Collect. The list below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect. We may disclose each of these categories of personal information to our service providers, who are not permitted to use your personal information except as necessary for performing services on our behalf. We collect these categories of personal information from the sources described in the
What Personal Information Do We Collect? section above, and for the purposes described in the
How We Use Personal Information section above. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident.
- Identifiers. Such as a name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
- Customer Records. Such as your account and profile information and paper and electronic customer records containing personal information, such as name, account name, signature, physical characteristics or description, address, telephone number, email, address, and other contact information, account credentials, communications preferences, financial or payment information, customer service and support tickets and records, and other information you provide in order to use our Site or Services.
- Commercial Information. Such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or Other Electronic Network Activity Information. Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other activity information on the Sites and Services.
- Audio, Electronic, Visual, or Similar Information. Audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV and video footage, photographs, and call recordings and other audio recordings (e.g., recorded meetings and webinars).
- Inferences. Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, and behavior.
- Sensitive Personal information. Social security number, driver’s license number, state identification or passport number.
Sale and Sharing of Personal Information. Additionally, the CCPA defines "sale" as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third party for purposes of cross-contextual behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose the following categories of personal information: identifiers, profiles and inferences, and internet or other electric network activity information to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.
Sources of Personal Information. As further described in
What Personal Information Do We Collect?, we collect personal information from the following sources: directly from you; from public databases; advertising networks and marketing companies; data analytics providers; data brokers; vendors and service providers; social networks; internet service providers; operating systems and platforms; affiliated and subsidiary entities; business partners; advisors and agents; clients; and government entities.
Disclosure of Personal Information to Third Parties. The categories of personal information we have disclosed for a business purpose in the preceding twelve (12) months include: identifiers, customer records, commercial information, Internet or other electronic network activity information, audio, video, and other electronic data, and inferences. The categories of third parties and other recipients to whom we may disclose personal information for a business purpose may include: affiliates, subsidiaries, and business partners; advisors and agents; clients; vendors and service providers; acquirers of business assets; advertising networks; internet service providers; data analytics providers; data brokers; government entities; operating systems and platforms; and social networks.
Retention. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. We also retain personal information as necessary to comply with our tax, accounting and recordkeeping obligations, to provide you with the services you have requested, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations. In some cases, rather than delete your personal information, we may deidentify or aggregate it and use it in compliance with the CCPA. We agree not to reidentify deidentified data except as permitted by applicable law.
Purposes for Collecting, Using, Disclosing, and Processing Personal Information. As more fully described in
How We Use Personal Information section above, we collect, use, and otherwise process the following categories of personal information for the following business and commercial purposes: to provide Services and support; communications; analytics and improvement; customization and personalization; marketing and promotional purposes; planning and managing events; research and surveys; sweepstakes, contests, and promotions; to protect the safety, rights, property, or security; legal proceedings and obligations; to administer corporate customer contracts; and general business and operational support.
Sensitive Personal Information. Notwithstanding the purposes described above, we do not collect, use, or disclose “sensitive personal information” beyond the purposes authorized by the CCPA.
California Consumer Rights. California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below. These rights only apply to personal information we collect and process under this Policy as a business or controller. For personal information we process on behalf of our business clients in our capacity as a service provider or processor, please submit your request directly to the business client with whom you have a relationship, and we will provide reasonable assistance to that business client as necessary to enable them to respond to your requests to exercise your privacy rights. With some exceptions, California consumers have the right to request the following:
Right to Opt-out of Sale and Sharing of Personal Information. California residents have the right to opt-out of our sale and sharing of their personal information. To exercise your right to opt-out of the “sale” or “sharing” of your Personal Information, please see below in the
Submitting Requests section or click on the Do Not Sell or Share My Personal Information link at the footer of our Site. Please note that submitting an opt out request will only opt you out of disclosures that are considered “sales” or “sharing” under the CCPA and will not opt you out of other disclosures, such as to our service providers.
You also have the right to opt-out of “sales” and “sharing” of your Personal Information through the use of an opt-out preference signal. If we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your Personal Information. If you come to our Site or use our Services from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well.
Right to Limit Use of Sensitive Personal Information. We do not engage in uses or disclosures of “Sensitive Personal Information” that would trigger the right to limit use of Sensitive Personal Information under the CCPA.
Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see
Submitting Requests below for instructions about how to exercise your rights:
Deletion: the right to request deletion of personal information that we have collected about you, subject to certain exemptions.
Copy: the right to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months.
Correction: the right to correct any inaccuracies in your personal information.
Right to Know (Collection): Where we have collected personal information about you, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of sources from which the personal information is collected; business and/or commercial purposes for collecting and selling your personal information; and the categories of third parties/with whom we have disclosed or shared your personal information.
Right to Know (Disclosure): Where we have sold or disclosed for a business purpose your personal information, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party; categories of third parties to whom personal information has been disclosed; and the categories personal information that we have disclosed or shared with a third party for a business purpose.
Submitting Requests. You can exercise your right by:
When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you have created an account, we may ask you to sign into your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request where we are satisfied that we have verified your identity to an appropriate degree of certainty. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
Authorized Agents. You may designate someone as an authorized agent to submit requests and to act on your behalf. Authorized agents will be required to provide proof of their authorization, and we may also require that the relevant consumer directly verify the identity and the authority of the authorized agent.
Discrimination. We will not discriminate against California consumers for exercising their rights under the CCPA.
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CONTACT US
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us:
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CHANGES TO THIS POLICY
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on this Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.
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