Effective Date: July 21, 2021
How and why we collect your Personal Information;
How your Personal Information is used and protected;
When and with whom we share your Personal Information; and
What choices you can make about how we collect, use, and share your Personal Information.
How we store, use, transfer, and retain your Personal Information.
Acknowledgement and Consent
We gather various types of Personal Information, and we use this Personal Information internally in connection with our Services, including to personalize and improve our Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and Services, to provide and improve the Services, and to analyze how you use the Services, all as explained in more detail below. In certain cases, we may also share some Personal Information with third parties, but only as described below.
Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).
Individuals under the Age of 13
As noted in the EULA, we do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 13 or knowingly allow such persons to register for our Services. If you are under 13, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. No one under age 13 should provide any Personal Information to or on the Services. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.
Information We Collect About You and How We Collect It
Information that you provide by filling in forms on our Mobile App. This includes information provided at the time of registering to use our Mobile App, subscribing to or purchasing our Services, e-newsletters, posting material where permitted or requesting further Services. We may also ask you for information when you report a problem with our Mobile App.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Your search queries on the Mobile App.
Information that you provide by filling in webforms on our Website. This includes information provided when creating an online account, purchasing our Products or Services, subscribing to our e-newsletters or other communications, requesting information from us, submitting or posting material (where permitted) on our forums, or interacting with customer support or service, report a problem with our Website, Products, or Services, or otherwise communicating with us.
Records and copies of your correspondence (including email addresses), if you contact us
Registering for an event
Your responses to surveys that we or our service providers might ask you to complete for research purposes
Your search queries on the Website
When communicating with customer service/support
Through participation in loyalty/rewards programs
Third party websites and mobile applications (e.g., websites that share information with us or advertising partners regarding online activities)
Data suppliers (e.g., companies that provide demographics and other information regarding consumers)
Joint marketing partners
Online advertising companies
Fulfillment and delivery service providers
Social media companies
Other service providers
Responding to employment opportunities
Details of your visits to our Mobile App, including, but not limited to, traffic data, geolocation data, logs and other communication data and the resources that you access and use on the Mobile App.
Information about your computer and internet connection, including your IP address, operating system, browser type, clickstream patters, the URL of the most recent website you visited before coming to our Mobile App, the amount of time you spent on our Mobile App, and the pages you viewed while on our Mobile App.
We also may use these technologies to collect information about your online activities over time using the Mobile App (behavioral tracking). For more information on how to opt-out of third-party advertiser tracking mechanisms, please click here.
Estimate our audience/visitor size and usage patterns.
Store information about your preferences, allowing us to customize and improve our Website.
Speed up your searches.
Recognize you when you return to the Mobile App.
We may collect information that others provide about you when they use the Website, or obtain information from other sources and combine that with information we collect through the Website. If you link, connect, or login to your account with a third party social media service (e.g., Facebook, WeChat), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Google AdSense Advertising. We use Google AdSense Advertising (or other search engine or display network advertising) on our website. Google’s advertising requirements and principles are available here. They are put in place to provide a positive experience for users. We have implemented the following: (a) Remarketing with Google AdSense and (b) Google Display Network Impression Reporting.
We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website.
Google reCAPTCHA. We use Google reCAPTCHA, which identifies bots by collecting hardware and software information and sending that data to Google for analysis. More about Google reCAPTCHA is available here and here.
We may post content on our Mobile App you post to our Facebook or other social media account pages.
How We Use Your Information
Direct Voice Feature.
We do not monitor Direct Voice chat rooms. A conversation incident may be reported to us by clicking the “Report” button. If an incident is reported, we will review it and we will investigate and take action where appropriate, including, but not limited to, suspending or banning a user from a chat room or from use of the Mobile App.
Social Media Plugins
We integrate social media application program interfaces or plug-ins (Plug-ins) from social networks, including Facebook, Google+, LinkedIn, Xing, Twitter, Instagram, Tumblr, Pinterest and/or possibly other companies, into the Website. In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site (SMS) login.
For example, when you visit our Website, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Website with your IP address. If you click the Facebook “Like” button while you are logged on to your Facebook account, you can link the contents of our Website to your Facebook profile. This allows Facebook to assign your visit to our Website to your user account. Please note that as provider of the Website, we receive no notification about the contents of the transmitted data or their use by Facebook. If you do not want Facebook to assign your visit to our Website to your Facebook user account, please log out of your Facebook user account.
How We Share Your Information
Broadly stated, we may disclose, rent, or sell your Personal Information, in whole or in part, with third parties for the purpose of providing or improving the Services to you, who perform services on our behalf, or for marketing purposes. We disclose Personal Information to the following types of third parties, and for the following purposes:
Hosting providers for the secure storage and transmission of your data
Learning technology and online event providers for the delivery and improvement of web events and learning programs and the tracking of your progress
Identity management providers for authentication purposes
Database software providers for the management and tracking of your data
Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
Marketing providers who send communications on our behalf regarding our products and Services
Payment solution providers for the secure processing of payments you provide to us
Third parties who develop products on our behalf
Technology providers who assist in the development and management of our Mobile App
Outbound call center providers, who may perform outreach on our behalf regarding our products and Services
Fulfillment and shipping vendors for the fulfillment of our products and Services
Survey and research providers who perform studies on our behalf
Advertising partners, including social media providers, for the delivery of targeted advertisements
Unrelated third-party list renters for one-time mail or email approved by us
Marketing providers who may sell mailing lists
Disclosures to Service Providers. We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, data analysis, credit checks, screening checks, collection services, marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, providing search results and links (including paid listings and links), processing credit card payments, or managing our conferences and other events. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).
De-Identified Personal Information: We may share De-Identified Personal Information (such as anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services.
Event-Related Disclosures: From time to time, we may run contests, special offers, or other events or activities (“Events”), possibly together with a third party Service Provider. If you provide information to such Service Providers, you give them permission to use it for the purpose of that Event and any other use to which you consent. We cannot control such third parties’ use of your information. If you do not want your information to be collected by or shared with such third parties, you can choose not to participate in these Events.
Your Consent to Disclosure/Transfer of Your Personal Information
You consent to our disclosure of your Personal Information, De-Identified Personal Information, and other information you provide to us (“Transferred Information”) to a potential or actual buyer or acquirer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) as part of a Transfer, of any or all of our rights, in whole or in part, in or to Transferred Information and your consents, with or without notice to you and without your further consent. We cannot make any representations regarding the use or transfer of Transferred Information that we may have in the c of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. By providing any Personal Information, you expressly agree and consent to the use and/or transfer of Transferred Information or other information in connection with a Transfer. Furthermore, except as required by law, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the Transferred Information that is disclosed to us
Data Transfer/Access Outside of the United States
We have our headquarters in the United States. The Personal Information we collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the European Economic Area (“EEA”) or Switzerland, we provide adequate protection for the transfer of Personal Information to countries outside of the EEA or Switzerland. We may also need to transfer your information to other group companies or service providers in countries outside the EEA. This may happen if our servers or suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area.
If you are a resident of country other than the United States, you acknowledge and consent to our collecting, transmitting, and storing your Personal Information out of the country in which you reside.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.
Your Personal Information is contained behind secured networks and a firewall and is only accessible by a limited number of persons and service providers who have special access rights to such systems, and are required to keep the information confidential.
Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information. We do not receive or have access to your full credit card number.
Our Mobile App is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Mobile App safer.
We may store, retrieve, access, and transmit your Personal Information in the US or in other countries.
The safety and security of your information also depends on you. You should maintain good internet security practices. Where we have given you (or where you have chosen) a password for access to certain parts of the Mobile App or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained in the Mobile App or used with our Services.
The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will keep your Personal Information for as long as your account is active, or as long as you are a registered subscriber or account holder or user of the Mobile App or our Services or for as long as we have another business purpose to do so and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
What Information You Can Access, Change, or Delete
Through your account settings, you may access and, in some cases, edit or delete certain information you’ve provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Mobile App and our Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.
California Online Privacy Protection Act (CalOPPA”)
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us annually for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties with whom the business has shared such information during the immediately preceding calendar year. See more at the CalOPPA website. To obtain information under CalOPPA from us, please contact us. Please note that not all information sharing is covered by CalOPPA, and we will only include in our response information relating to our sharing practices for covered information. See more at the CalOPPA website.
Notices; Opting Out
By providing us with your email address (including by “following,” “liking,” linking your account to our Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity on the Service to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.
The Follow Provisions Apply Only to Citizens and Residents of the United Kingdom, EEA, and Switzerland:
Our Legal Basis for Processing Personal Data (UK, EEA, and Swiss Visitors Only)
If you are a visitor using our Website from the UK, EEA or Switzerland, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we need the Personal Data to perform Services for you for which you have contracted with us, or where the processing is in our legitimate interests or rely upon your consent where we are legally required to do so and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person. Your Data Rights Under GDPR
Relevant data protection laws provide you certain rights regarding the protection of your data, including: