Effective Date: August 15, 2012.
Last Updated: January 16, 2024
- We ask you for, and use technology to detect, information about you. Some of this information is shared with others.
- You consent to our practices detailed below. If you want to change your consent, terminate your account or stop using and/or uninstall the Site/App (defined below).
- Click here for an index of topics covered below. You may click on any topic to go to the details.
In addition, please review the Sites/Apps’ Terms of Service, which governs your use of the Sites/Apps.
Our representative for personal data purposes is Leonid Teytelman, you can contact our representative at the following address, 2120 University Avenue, Berkeley, CA 94703, or by email at email@example.com.
Table of Contents
- What Information Do The Sites/Apps Collect?
You may give us Personal Information and Demographic Information, such as when you register or contact us. More
Tracking Technologies collect Usage Information based on your Device Identifier. More
We may obtain information about you from third parties. More
You may give us information about others, such as when you send a friend a message. More
- How Do We Use The Information Collected?
We use your Personal Information, Demographic Information and Usage Information for a variety of purposes. More
- How and When Do We Disclose Information To Third Parties?
We provide your information under various circumstances. More. These include:
- Which Types of Third Party Content, Links and ADs are Used?
We are not responsible for your interaction with third party content or locations. More
We and third parties may send you targeted ads based on your location and behavior. If you object, stop using or uninstall our Sites/Apps or exercise choices some third parties may offer. More
- How Do I Change My Information And Communications Preferences?
You may change certain account information and preferences. More
- Data Transfer, Retention, and Deletion
- Your User rights
- What Should Parents Know About Children?
We do not intend to collect Personal Information from children. If you think we have, let us know. More
- What About Security?
No data security is absolute, but we take reasonable steps to secure data appropriately. More
1. What Information Do The Sites /Apps Collect?
a. Information You Provide To Us
b. Information We Collect or Store As You Access And Use The Sites/Apps
In addition to any Personal Information or other information that you choose to submit to us via our Sites/Apps, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Sites/Apps (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, laptop, tablet or mobile phone (a “Device”) whenever you visit or interact with our Sites/Apps. Usage Information may be non identifying or may be associated with you. Whenever we associate Usage Information with your Personal Information, we will treat it as Personal Information.
This Usage Information may include:
- our IP address or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Sites/Apps, and our computers identify your Device by its Device Identifier;
- your Device characteristics(e.g. Device type);
- your Device functionality (including browser, operating system, hardware, mobile network information);
- the URL that referred you to our Sites/Apps;
- the areas within our Sites/Apps that you visit and your activities there, including remembering you and your preferences;
- your Device location; and
- certain other Device data, including the time of day, among other information.
c. Cookies and Comparable Technologies Used for Data Collection
We may use various developed methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit the Sites/Apps. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s website www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our Sites/Apps may not function properly, and that when you revisit our Sites/Apps your ability to limit cookies is subject to your browser settings and limitations.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Sites/Apps’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Sites/Apps, to monitor how users navigate the Sites/Apps, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Sites/Apps, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Sites/Apps, and is deactivated or deleted thereafter.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and HTML5 cookies.
We may use Tracking Technologies for a variety of purposes, including:
Advertising Related. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our Sites/Apps and third party sites based on how you interact with our advertisements or content. This includes using Tracking Technologies to understand the usefulness to you of the advertisements that have been delivered to you. Further information on this is found in Section 5 below.
Where appropriate (especially when you are a user based in the EU, UK or Switzerland) we will ask for your consent to the usage of any Tracking Technologies exceeding the Strictly Necessary category.
d. Information Third Parties Provide About You
e. Information You Provide About a Third Party (Usage of Send-a-Friend Functionality)
You may send someone else a communication from the Sites/Apps, such as sending an invitation to a friend. If so, the information you provide (names, e-mail addresses, mobile number, etc.) is used to facilitate the communication with this third party and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Sites/Apps, your e-mail address, mobile number, name or user name and message may be included in the communication sent to your addressee(s). Some of these tools may be third party tools subject to 3rd party privacy policies.
There are separate third party privacy policies for some of the tools and systems we use:
Google Drive (for files collaboration) – https://www.google.com/policies/privacy/
2. How Do We Use The Information Collected?
Please note that information submitted to the Sites/Apps via a “contact us” or other similar function may not receive a response and we will not use that information so provided to contact you for marketing purposes unrelated to your inquiry unless you agree otherwise.
a. Legal Bases for Processing Information
We rely on the following legal grounds to process your personal information:
3. How and When Do We Disclose Information to Third Parties?
a. When You Agree To Receive Information From Third Parties
You may be presented with an option on our Sites/Apps to receive certain information and/or marketing offers directly from third parties. If you choose to do so, your Personal Information will be disclosed to such third parties and all information you disclose will be subject to the third party privacy policies and practices of such third parties. We are not responsible for such third party privacy policies and practices of such third parties and, therefore, you should review such third party privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communications from one of these third parties, you will need to contact that third party directly.
b. Third Parties Providing Services on Our Behalf
We may use third party vendors to perform certain services on behalf of us or the Sites/Apps, such as hosting the Sites/Apps, designing and/or operating the Sites/Apps’ features, tracking the Sites/Apps’ activities and analytics, and enabling us to send you special offers or perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Within the scope of our information sharing activities, your personal data may be transferred to other countries (including countries outside the European Economic Area (EEA)) which may have different data protection standards than your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavour to take the required measures to keep up an adequate level of data protection when sharing your personal data with recipients established in such countries.
Third party analytics service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them.
c. Administrative and Legal Reasons
We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information), including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Sites/Apps’ Terms of Service or other policies applicable to the Sites/Apps, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Sites/Apps or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
d. Business Transfer
We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Sites/Apps or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
4. Which Types of Third Party Content, Links and ADs are Used?
a. Do Third Party Content And Links To Third Party Sites Appear on The Sites/Apps?
The Sites/Apps may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Sites/Apps are served to you. In addition, when you are on the Sites/Apps you may be directed to other sites that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites. For example, if you “click” on a link, the “click” may take you off the Sites/Apps onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Sites/Apps and to review the third party privacy policies of all third party locations and exercise caution in connection with them.
b. Are There Third Party Ads Served On The Sites/Apps?
The Sites/Apps may use third parties such as network advertisers to serve advertisements on the Sites/Apps and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of the Sites/Apps and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your visits to the Sites/Apps and other apps and sites you have visited. Third party ad serving enables us to target advertisements to you for products and services in which you might be interested.
The Sites/Apps’ third party ad network providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies (including Flash cookies), web beacons and other Tracking Technologies on your Device and track certain behavioral Usage Information regarding users of your Device via a Device Identifier. These third party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities. Depending on the applicable law the usage of some or all of this technology may be subject to your prior consent, for more information see Section 1.c.
While we may use a variety of companies to serve advertisements on the Sites/Apps, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be able to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different Device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI’s web site accessible by the above link. You may also opt-out of receiving third party behavioral ads on this site by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices/#completed. Similar limitations may apply to the DAA opt-out.
5. How Do I Change My Information And Communications Preferences?
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Sites/Apps may allow you to review, correct or update Personal Information you have provided through the Sites/Apps’ registration forms or otherwise, and you may provide registration updates and changes by contacting us at: firstname.lastname@example.org. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. With respect to our mobile applications (i.e., when we are the application publisher), you can prospectively stop all collection of information by the application by uninstalling the application. You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Sites/Apps, information that you remove may persist internally for Company’s administrative purposes. You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Sites/Apps, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.
6. Data Transfer, Retention, and Deletion
a. Transfer and Processing of Data
For users within the United States, we process data in data centers located in the United States. We have adopted reasonable physical, technical, and organizational safeguards against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, use, or processing of user data in our possession. We comply with state and federal laws governing the protection of personal information.
For users within the European Union and Switzerland, we transfer data from the European Union to data centers located in the United States for processing. Such processing is performed in accordance with Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and free movement of such data, known as the General Data Protection Regulation (“GDPR”). This includes the imposition of required safeguards with respect to accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of data.
Transfers of European Union, or Swiss user data to processors in the United States are made in accordance with the EU-US Data Privacy Framework (DPF), and Swiss-US Privacy Shield Framework, as explained below.
For users in the UK, we transfer data from the UK to data centers located in the United STates for processing. Such processing is performed in accordance with the UK Data Protection Act 2018 (“DPA 2018”), the UK GDPR and the UK-U.S. Data Bridge decision of June 8, 2023, under Section 17A of the Data Protection Act 2018, to establish a data bridge with the United States of America through the UK Extension to the EU-US Data Privacy Framework.
b. Retention and Deletion
We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case it is no longer personal information.
It is our policy to retain personal information for three (3) months once such personal information is no longer necessary to deliver the Service and to delete such personal information thereafter. This means that, if you close your account with us, we will delete personal information associated with your account after three (3) months. Regarding other types of information we collect as described in this policy (Cookies, Log Files, Geo-Location Information, Device Identifiers), it is our policy to retain such personal information for three (3) months and to delete such personal information thereafter.
c. Users Located in the European Union, United Kingdom and Switzerland
6. Your User rights
Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights.
If you are a resident of the EU, UK, or Switzerland, have the right to:
- request an accounting of all personal information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
- request that we change any personal information that pertains to you.
- request that we delete any personal information that pertains to you.
- fully or partially withdraw your consent to the collection, processing, and/or transfer of your personal information.
To request an accounting of your personal information, a change to your personal information, deletion of your personal information, or to withdraw your consent to the collection, processing, and/or transfer of your personal information, contact email@example.com. Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
We commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the applicable framework( EU-US Data Privacy Framework, UK-U.S. Data Bridge or Swiss-US Privacy Shield Framework). EU, UK and Swiss residents with Privacy inquiries or complaints should first contact Leonid Teytelman at firstname.lastname@example.org.
We are committed to refer unresolved privacy complaints under the Data Privacy Framework to an independent dispute resolution mechanism, the BBB National Programs Data Privacy Framework Services, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Data Privacy Framework Annex 1 athttps://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
You also have a right to lodge a complaint with a national Data Protection Authority. Each European Union member nation has established its own Data Protection Authority; you can find out about the Data Protection Authority in your country here:http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
8. What Should Parents Know About Children?
The Sites/Apps are general audience web sites and we do not knowingly collect any personal information from children younger than the age of thirteen (13) as required by U.S. law. We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personal information to us, please contact us at email@example.com.
9. What About Security?
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.