To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
1. What information Does the Site Collect?
We collect and receive certain information about you as you interact with our Site, explained further in this Section.
a. Information You Provide Us
b. Information Collected and Stored As You Access and Use the Site
In addition to any Personal Information or other information that you choose to submit to us via our Site, 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 Site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Site, we will treat it as Personal Information.
This Usage Information may include:
We may use various 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 used on the Site, 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 Site. 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 http://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 Site may not function properly, and that when you revisit our Site 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 “1×1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email 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 Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, 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 Site, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
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/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
We may use Tracking Technologies for a variety of purposes, including:
Targeting-Related. We may use Tracking Technologies to deliver content, including ads relevant to your interests on our Site and third-party services based on how you interact with our advertisements and/or content. This includes using Tracking Technologies to understand the usefulness to you of the content and ads that have been delivered to you.
c. Location-Based Information
Our Site may use location-based services in order to locate you so we may verify your location, deliver you relevant content and ads based on your location as well as to share your location with our vendors as part of the location-based services we offer. You may be able to change the settings on your Device to prevent it from providing us with such information. You should consider the risks involved in disclosing your location information to other people.
d. Information Third Parties Provide About You
e. Interactions with Third-Party Services
f. California / Delaware Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
g. Information You Provide About a Third Party
You may send someone else a communication from the Site, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, etc.) is used to facilitate the communication 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 Site, your contact information, name or username and message may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies.
b. Use of Information for Recruitment Purposes. Where you have provided us with Personal Information or Demographic Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this Personal Information or Demographic Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.
3. How and When Do We Share Information with Third Parties?
a. When You Request Information From or Provide Information to Third Parties. You may be presented with an option on our Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may 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. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools, apps or ads on our Site or link to them from our Site. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. We are not responsible for the 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 requesting information from or otherwise interacting with them.
b. Third Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Site, such as: (i) to assist us in Site operations; (ii) to manage a database of customer information; (iii) hosting the Site; (iv) designing and/or operating the Site’s features; (v) tracking the Site’s activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; (vii) to provide credit report information; and (viii) other services designed to assist us in maximizing our business potential. 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. Third-party analytics and other 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. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
d. Affiliates and 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 Site 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.
e. Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Site that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
f. Your California Privacy Rights. We may elect to share information about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of personal information shared by us and the names and addresses of all third parties that received personal information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2017 will receive information about 2016 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to: email@example.com with “California Privacy Rights” as the subject line or mail us a letter to: IdentityForce, 111 Speen Street, Suite 304, Framingham, MA 01701. You must include your full name, email address, and postal address in your request.
g. Your Connecticut Privacy Rights. Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.
4. Ads and Information About You
We and third parties such as network advertisers and ad exchanges may serve advertisements across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party sites and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your activities across the Internet and mobile media (“Behavioral Ads”). Behavioral Ads enable us to target advertisements to you for products and services in which we believe you might be interested. If you object to receiving Behavioral Ads from us on third party sites, you can learn more about your ability to limit Behavioral Ads below. Our third party ad network and exchange providers, the advertisers and/or traffic measurement services may themselves set and access their own technologies on your Device and track certain behavioral Usage Information via a Device Identifier. These third party 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; and (c) understand the usefulness of the advertisements that have been delivered to you. You acknowledge and agree 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.
We may use third-party advertising companies to target advertisements to you on our Site, across the web, on your mobile Device and on any of your other Devices, based on the information we have collected from and about you, as well as information relating to your and other users’ visits to this and other websites and online services (also referred to as “cross-device” tracking). To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags) or recognize an identifier associated with your mobile device. These companies may also use these technologies, along with personal information they or we collect on the different devices you use, to recognize you across the Devices you use, such as a mobile device and a laptop or other computer.
Some third parties may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. Further, while sites use a variety of companies to serve advertisements, 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 allowed under their own rules to deliver Behavioral Ads to you, 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. You may also opt-out of receiving Behavioral Ads on participating sites and services on desktop and mobile web browsers by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices. Similar limitations may apply to the DAA opt-out. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in mobile apps. You may also click on the informational icon contained within each interest based ad. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options or programs.
5. Does Third-Party Content, Links to Third-Party Sites, and/or Third-Party Apps Appear on the Site?
The Site may contain content, links or apps that are supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you for their own commercial purposes. In addition, when you are on the Site you may be directed to other sites and apps 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 or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the Site onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Site and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.
6. 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 account registration. The Site may allow you to review, correct or update Personal Information you have provided through the Site’s registration forms or otherwise by updating your Site account through the “Manage Account” tab on your account dashboard. You also may write to us directly if you wish to: (a) update or delete your contact information; or (b) request that we cease sending you any form of communication. We may require you to provide additional documentation regarding your request for verification purposes before changing your information. Such written requests should be sent to us by regular mail at: IdentityForce, 111 Speen Street, Suite 304, Framingham, MA 01701 (Attn: Chief Privacy Officer). If you update your information, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). 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 Site, information that you remove may persist internally for IdentityForce’s administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails 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 Site, such as administrative and Site announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.
7. What About the Transfer of Information to the United States?
Our Site is operated in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.
8. What Should Parents Know About Children?
We understand the importance of protecting children’s privacy in the interactive world. We are a general audience Site and do not use the Site to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. If you are a child under thirteen (13) years of age, you are not permitted to use the Site and should not send any information about yourself to us through the Site.
In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us at firstname.lastname@example.org.
9. What About Security?
We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.
The following third parties that collect information from you on the Site have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:
|Party||Service||For More Information||Use of Tracking Technologies||Privacy Choices|
|Google Adwords||Advertising||View here.||Yes||View here.|
|Google Analytics||Analytics||View here.||Yes||View here.|
|Doubleclick||Advertising||View here.||Yes||View here.|
|Kissmetrics||Analytics||View here.||Yes||View here.|
|Lucky Orange||Analytics||View here.||Yes||View here.|
|Optimizely||Analytics||View here.||Yes||View here.|
|Bing Ads||Advertising||View here.||Yes||View here.|
|ScoreCard||Analytics||View here.||Yes||View here.|
|Marketo||Inbound Marketing||View here.||Yes||View here.|
|Hubspot||Inbound Marketing||View here.||No||View here.|
|AdRoll||Advertising||View here.||No||View here.|
|Rubicon||Advertising||View here.||No||View here.|
|OpenX||Advertising||View here.||No||View here.|
|Pubmatic||Advertising||View here.||No||View here.|
|Quantcast||Advertising||View here.||No||View here.|
|Yahoo Ad Exchange||Advertising||View here.||No||View here.|
PLEASE NOTE: We are not responsible for third-party policies or practices. We try to keep this information current, and will add to and subtract from the chart above as appropriate, but it is provided as a courtesy and may not be current or accurate. Please contact the relevant third parties regarding their privacy and data security policies and practices.