Last Updated: 17 July 2019
"Personal Information" is information that identifies you as an individual or relates to an identifiable individual, including:
• Postal Address
• Telephone number
• Email address
• Payment information
• Profile picture
• Social media account ID
We may need to collect and process these types of Personal Information in order to provide the requested Services to you or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide you with the requested Services.
We may also receive your Personal Information from other sources, such as data companies, public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties. For example, we may use such third-party information to confirm contact or financial information or to better understand your interests by associating demographic information with the information you have provided. In addition, if you elect to connect your social media account to your website account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends’ profiles.
Use of Personal Information
We may use Personal Information to perform our contractual relationship with you (as a user of the Services), to comply with our legal duties, and for our legitimate business interests, including the following:
• To respond to your inquiries and fulfill your requests, complete your transactions, and provide you with related customer service;
• To send administrative information to you, such as changes to our terms, conditions, and policies, as well as marketing communications that we believe may be of interest;
• To personalize your experience on the Services by presenting products and offers tailored to you; and
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
Disclosure of Personal Information
Your Personal Information may be disclosed:
• To our third-party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services; and
• To third parties, to permit them to send you marketing communications, consistent with your choices.
Other Uses and Disclosures
We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
In addition, we may use, disclose or transfer your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
• Browser and device information;
• Information collected through cookies, pixel tags, and/or other technologies;
• Demographic information and other information provided by you that does not reveal your specific identity; and
• Information that has been aggregated in a manner that it no longer reveals your specific identity.
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
• Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Services function properly.
• Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals.
• Using pixel tags and other similar technologies: Pixel tags (also known as “web beacons” and “clear GIFs”) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
• IP Address: Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes, such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP address.
• Physical Location: We may collect the physical location of your mobile device by, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with location-based services and content. You may be able to allow or deny such uses of your device’s location, but, if you do, we may not be able to provide you with the applicable services or content, the consequences of which you fully accept.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:
• Receiving electronic communications from us: If, going forward, you do not want to receive marketing-related emails from us, you may opt out by following the instructions contained in each such email.
• Our sharing of your Personal Information with affiliates for their direct marketing purposes: If, going forward, you would prefer that we not share your Personal Information with our affiliates for their direct marketing purposes, you may opt out of this sharing by visiting the Opt-out form below:
• Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes: If, going forward, you would prefer that we not share your Personal Information with unaffiliated third parties for their direct marketing purposes, you may opt out of this sharing by visiting the Opt-out form above.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change or suppress your Personal Information
If you would like to request to review, correct, update, suppress, restrict, or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at email@example.com We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under the age of thirteen (13).
JURISDICTION AND CROSS-BORDER TRANSFER
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
11091 Sunset Hills Rd, Suite 210
Reston, Virginia 20190
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.