Last Updated: September 2016
2 Information We Collect
2.1 We collect information from a visitor when she or he accesses or interacts with the Website or Application. We collect both personal information and non-personal information depending on the level of interaction of a visitor with the Website or Application. The manner in which this information is collected falls into two categories: (i) information that a visitor provides directly; and (ii) information that is automatically collected through a visitor’s use of the Website or Application.
2.2 Information you provide to us directly:
c. Electronic Communications: We may collect information that a visitor or Authorized User chooses to share with us via electronic communications, such as support or administrative requests. We use this information to understand and respond to a visitor’s questions and to improve our processes and customer experience.
d. Surveys and Questionnaires: We may invite visitors and Authorized Users to participate in surveys or to respond to a particular questionnaire. Participation in such surveys and questionnaires is voluntary, but may require that a visitor provide certain personal information, such as name, email address, or zip code. We will use this information for analytics purposes.
2.3 Information automatically collected through your use of the Service:
We automatically collect information from visitors who use the Website or Application in order to understand how the Website or Application is used, and how to improve them. The information we automatically collect through the Website or Application includes:
a. In general: We record a visitor’s and Authorized Users IP address, the time of the visit, and information regarding the browser and operating system of the device used. We collect certain information about a the use of the Website, including actions taken on the Website, webpages visited, and time spent on specific webpages, and the like.
b. Mobile Device Users: If a mobile device is used to access the Website or Application, we may collect, in addition to the general information above, the type of mobile device used and other technical information about the mobile device (e.g., the manufacturer of the mobile device, its location, and etc.).
2.4 Technology used to collect information through your use of the Service:
The technology we use to collect information automatically from visitors and Authorized Users includes the following:
a. Cookies: The information we collect using cookies allows us to monitor how many visitors are using our Website or Application and for what purposes. Cookies are also used to facilitate an Authorized User's log-in, as navigation aids, and as session timers. Cookies do not retain personal information about a visitor but do retain certain information about an Authorized User, such as to allow navigation from page to page in a restricted access area of the Website.
You may choose to block certain categories of cookies. Most browsers contain settings that allow you to control or delete cookies. These settings will typically be found in the “options” or “preferences” menu of your browser. Please note that blocking or disabling certain cookies may interfere with certain functionalities of our Service. Further, while disabling a cookie may prevent the future collection of information by that cookie, it does not prevent the use of the information collected prior to the cookie being disabled. For more general information about cookies you can visit http://www.allaboutcookies.org.
b. Embedded Scripts: Embedded scripts are used to collect information about a visitor’s and Authorized User’s interactions with the Website and Application, such as the links clicked. Embedded scripts are temporarily downloaded onto a visitor’s or Authorized User’s computer or mobile device and are deactivated or deleted when a visitor or Authorized User disconnects from the Website.
c. Third-Parties' Content and Widgets: Our Website may include third-party widgets and other content from third-parties. These third-parties may use their own cookies or web beacons to track the actions of visitors online over time and across different websites or platforms to deliver targeted electronic advertisements to a visitor. Please note that the Company does not have access to or control over the cookies and/or web beacons that third-parties may use. We are not responsible for the privacy practices of these third-parties. For more information about how tracking works for online advertising purposes you can visit http://www.aboutads.info/choices. In addition, some third-party advertising companies may provide a mechanism to opt-out of their tracking technologies. For more information about this opt-out process, you can visit the Network Advertising Initiative website, available at http://www.networkadvertising.org/choices/.
3 How We Use Information
a. Facilitate the use of the Website or Application;
b. Improve, test, and monitor the effectiveness of the Website or Application;
c. Develop Website or Application features that may be of interest;
d. Send electronic communications about the Service or to respond to inquiries or requests for information;
e. Maintain a record of contact information and correspondence;
f. Optimize our marketing efforts, for example to compile statistics regarding the use of the Website or Application, to identify usage trends, and to determine the effectiveness of our promotional campaigns;
g. Perform data analysis;
h. Conduct audits, and fraud monitoring and prevention;
i. Conduct other functions as otherwise described at the time when the information is collected; and
j. Perform any other function that we believe in good faith is necessary to protect the security or proper functioning of the Website or Application.
4 Sharing and Disclosure of Information
We may share certain information with third-parties in the following circumstances:
4.1 Employees, Third-Party Processors and Third-Party Service Providers: We will share information with our employees, contractors, affiliates, distributors, dealers, vendors, and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as operating and supporting the Website or Application, conducting data analytics, providing customer service, or performing marketing, or consulting services. These Service Providers will only have access to the information needed to perform the functions that we have requested them to carry out on our behalf.
4.2 In Connection with Business Transfers or Bankruptcy: We may disclose or transfer information to a third-party in the case of a sale, merger, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stocks, corporate restructuring or bankruptcy. This transfer or disclosure may occur both as part of these transactions, and as part of any due diligence process.
4.3 Responding to Legal Requests and Preventing Harm: There may be times when we use, share, or disclose information (a) if required to do so by law, or in response to a search warrant, subpoena, or a court order and we believe that such request is facially valid; (b) if we believe that disclosure is reasonably necessary to protect against suspected illegal or fraudulent activity, to protect the safety, property and other rights of the Company, our service providers, other visitors or Authorized Users or the public; and/or (c) to enforce our Legal Terms, or to defend against legal claims, or to allow us to pursue available remedies or limit the damages that we may sustain.
4.4 Aggregate Information: We may share, aggregate information relating to visitors or Authorized Users with third-parties for research, analytical, or strategic purposes.
5 Information Storage and Retention
We will retain information about visitors and Authorized Users as needed to provide the Service, or as necessary to comply with our legal obligations, resolve disputes and enforce our agreements unless a longer retention period is required or permitted under applicable law.
6 Information Security
We use reasonable technical, organizational and administrative measures to protect the information we collect and store against unauthorized or unlawful processing and against accidental loss, destruction and/or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody. However, as no method of transmission over the Internet, or method of electronic storage is 100% effective, we cannot guarantee and do no warrant the security of any information we may have collected.
7 Non-US Residents - Consent to Transfer of Information
7.1 The Website and the Application are directed to visitors and Authorized Users located in the United States. If you reside outside of the United States, and choose to use the Website or Application or to provide your information to us, please note that your information will be processed and maintained on servers or databases located in a country other than your country of residence (for example, in the United States) and that these countries may not provide the same level of protection of privacy and personal rights that you may enjoy in your country of residence.
>>If you do not want your information to be transferred to, or processed, or maintained outside your country of residence, you should not access or use the Website and/or Service.
8.1 Accessing, Changing, and Managing Your Information: If you are an Authorized User, you may update or correct the information you have provided by logging into your account and making the applicable changes.
8.2 Choices Regarding Marketing: You may opt-out of receiving marketing emails from us by following the opt-out instructions contained in those emails or by contacting us at email@example.com We will try to comply with your request as soon as is reasonably practicable. Please note that you cannot opt-out from receiving administrative email messages.
9 Third-Party Links and Third-Party Websites
9.1 The Website and/or Application may contain links to third-party websites that operate under different legal terms and Privacy Policies. We encourage you to read the legal terms and Privacy Policies for each such third-party website as these other legal terms and Privacy Policies will apply to you when you visit such third-party websites. We have no control over such third-party websites or services and we make no warranties or representations about their content, completeness, accuracy or quality.
9.2 The Company is not responsible or liable, directly or indirectly, for any damage caused or alleged to be caused by or in connection with use of, or reliance on any content and/ or service available on or through any such third-party website.
10 Children's Privacy
The Application and Services are provided only for users 18 years of age and older. We do not knowingly collect personal information from children under the age of 18. If we become aware that a child under the age of 18 has provided us with personal information without parental consent, that information will be deleted. Parents who have questions about personal information that may have been submitted by a child under the age of 18 should email us as set forth in the “How to Contact Us” section.
>>By accessing and/or using the Website or Application you represent that you are at least 18 years old.
11 California Residents – California Privacy Rights and Disclosures
11.1 We will not share any personal information about you with outside third-parties for their direct marketing purposes to the extent prohibited by California law, unless you agree otherwise as authorized by your prior written consent.
11.2 Do Not Track: Browsers provide the ability to inform operators of online services that a visitor does not want certain information about his/her online activities to be collected over time or across websites or online services. However, the Internet industry has not yet agreed on a definition of what “do not track” means, on how compliance with “do not track” would be measured or evaluated or on a common approach to responding to a “do not track” signal. Consequently, due to this lack of standardization, we have not yet developed features that would recognize or respond to browser-initiated “do not track” signals. To find out more about “do not track”, please visit http://www.allaboutdnt.com.
13 How to Contact Us
7115 Leesburg Pike Suite 208
Falls Church, VA 22043
ATTN: Privacy Team
By email: firstname.lastname@example.org