- “Personal Data,” which refers to information that can be used to identify you directly or indirectly; and
- “Anonymous Data,” which refers to information that cannot be used to identify you.
II. Legal Basis for Processing
We collect and use the Personal Data and Anonymous Data described below in order to provide this Site to you. We also collect and use Personal Data and Anonymous Data:
- For our legitimate business needs.
- To fulfill our contractual obligations to you and our clients.
- To comply with our other legal obligations.
III. Information We Collect & How We Collect It
We collect Personal Data and Anonymous Data in the following ways:
- When you voluntarily give us information. For example, you may provide us information by filling in forms on our Sites, or by corresponding with us by telephone, email or otherwise. This includes information you provide when you register for a newsletter, participate in social media functions on our Sites, take part in a survey or promotion, or report a problem with our Site or Partner Sites. We may ask for Personal Data such as your name, email address, phone number, company name, and date of birth when you visit our Sites.
- When you use our Site and/or Services. We automatically collect information about how you interact with some of our Sites, including:
- Device information, such as your hardware and operating system;
- Log information, or information that our servers automatically generate when you use our Sites. Log information includes information like your search queries, your IP address, browser type, hardware settings, browser language, and cookies that uniquely identify your browser, plugins, time zone settings.
- Visit information, such as the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Through our clients and service providers. We have contracts with clients and service providers who may, in the course of services, supply us information about you like your IP address, location, email address, browser type, and hardware. Our service providers who provide information to us include products like Google Analytics and Facebook Pixel, which provide information about how users interact with our Sites.
- Through publicly available data. To assist our clients, we may collect and use Personal Data and Anonymous Data from publicly available platforms in which you participate. For example, we may collect and synthesize information regarding public social-media interactions with our clients’ profiles.
- Through cookies and similar technologies. We and our service providers may use various technologies that place small pieces of data on your device to identify your browser or device and distinguish you from other users of our Sites. This helps to provide you with a good experience when you browse our Site or use our Services and allows us to improve our Site and Services.
What are Cookies
Cookies are small data files stored on your hardware that help us remember you and your settings and to collect general, anonymous information about how users use our Sites. Cookies can be “persistent” or “session” cookies. We use persistent cookies and session cookies.
A persistent cookie is stored on a user’s device in between browser sessions which allows the preferences or actions of a user across the Site or Services (or in some cases across different websites) to be remembered. We use persistent cookies to save your login information for future visits to our Sites and to remember your settings for following visits to our Sites.
A session cookie allows the Site to link your actions during a browser session. We use session cookies to enable certain features of our Sites, to better understand how you interact with our Sites and to monitor aggregate usage by users and web traffic routing on our Sites. Unlike persistent cookies, session cookies are deleted from your device when you log off from our Sites and then close your browser.
Options and More Information
You can set up your browser options to stop your device accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use certain functionalities of our Sites.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org, www.allaboutcookies.org, and http://optout.aboutads.info/.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. To modify your settings for Facebook ad tracking you can visit https://www.facebook.com/ads/preferences/.
V. How We Use Your Information
We use your Personal Data to provide you with access to our Sites, content, and information and to help us understand who is visiting our Sites. We may also use Personal Data to:
- Provide technical administration and customer support.
- Respond to your inquiries.
- Send important notices, such as communications about changes to our terms, conditions, and policies.
- Process payment for purchases you make.
- Provide you with the information, products and services that you request from us.
- Make it easier for you to log back into our Sites.
- Verify your eligibility and deliver prizes in connection with contests and sweepstakes.
- Notify you about changes to our Sites.
- Ensure that content from our Sites is presented in the most effective manner for you and for your computer.
VI. Disclosure of Your Information
EI is not in the business of sharing or selling your Personal Data. We consider this information to be a vital part of our relationship with you. However, in addition to specific requests by you, there are certain circumstances in which we may share your Personal Data with third parties without further notice to you, as set forth below:
- Business Transfers. As we develop our business, we may buy, sell or reorganize businesses or assets. In the event of such sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
- Agents, Consultants and Service Providers. EI, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function, and we only allow them to process that information for the purposes the information was collected.
- Credit Card Processing. We use third-party service providers to manage billing and credit card processing for our Partner Sites. We generally do not have direct access to this type of data, but we may in a limited capacity serve as an intermediary that passes such data from you to the payment processor.
- Site Optimization. We use analytics and search engine providers to assist us in the improvement and optimization of our Site and provide information to providers such as Google for these purposes.
- Legal Requirements. EI may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation; (ii) enforce, protect or defend the rights or property of EI, our clients, or others; (iii) act in urgent circumstances to protect the personal safety of users of our Sites or the public; or (iv) protect against legal liability; (v) for fraud prevention; or (vi) credit risk reduction.
VII. Special Notification for California Residents – Your Privacy Rights
Individuals who are residents of California and have provided their Personal Data to us may request information regarding our disclosures, if any, of their Personal Data to third parties for direct marketing purposes. Such requests must be submitted to our Privacy Officer in writing at firstname.lastname@example.org or:
Attention: Privacy Officer
646 Dean Street, 3B
Brooklyn, NY 11238
Such requests must include the reference “Request for California Privacy Information” in the subject line and in the body of the message and must include the e-mail address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted to us if not submitted pursuant to the terms set forth above.
VIII. Storage of Personal Data
Our Services are global and your information (including Personal Data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer your information to countries outside of your country of residence, which may have data protection rules that are different from those of your country of residence. If you live in the European Economic Area (the “EEA”), the Personal Data that we collect from you may therefore be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or partners. By submitting your Personal Data, you agree to this transfer, storing or processing outside of the EEA.
IX. Protection of Your Information
All information you provide to us is stored on our secure servers. Any credit card information or payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site or Services, you are responsible for keeping this password confidential. We ask you not to share any password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavour to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Sites. Please be advised that no communication over the Internet is 100% secure, and any data transmission over the Internet is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
X. Links to Other Websites
Our Sites may, from time to time, contain links to and from the websites of our partner networks, clients, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
XI. Data Retention
We retain Personal Data for as long as necessary for the relevant activity for which it was provided or collected. This will be for as long as we provide access to the Sites to you. However, we may keep some data after your account is closed or you cease using our Sites for the purposes set out below.
After you have closed your account or ceased using our Sites we usually delete Personal Data, however we may retain Personal Data where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our contracts, or fulfil your request to “unsubscribe” from further messages from us.
We may retain Anonymous Data indefinitely.
XII. Customer Support
646 Dean Street, Apt 3Bt
Brooklyn, NY 11238