Last modified: March 10, 2020
This Policy is divided into the following sections:
- Use and Disclosure
- Security and Retention
- Children’s Privacy
- Supplemental Information for California Residents
- Supplemental Information for Users Located in the EEA
- Contact Information
Information Collected Directly from You. We may collect personal information from you when you fill in online forms on our Site, such as when you correspond with us through the Contact Us form on our Site, sign up to receive INVIDI newsletters or alerts, or otherwise request information from us. The information we may collect includes:
- contact information, such as your name, email address, phone number, and postal address (“contact information“); and/or
- marketing and communications information, such as your preferences in receiving marketing messages, product and service offers, newsletters and alerts, and other communications from us (“marketing and communications information“).
Information Collected Automatically. As you navigate through and interact with our Site, your device or browser may automatically send us certain information, which may include:
- technical information, such as your IP address, browser type and version, information about your operating system, and information about the device you use to access the Site, such as device identification number and device type (“technical information“); and/or
- usage information, such as “clickstream” information and other information about how you use our Site (“usage information“).
2. Use and Disclosure
We may use your personal information to offer and provide you with our services and products, communicate with you, send you marketing messages or offers, send you newsletters or alerts, and/or to conduct other business operations. We may also use your personal information to administer and improve the Site, conduct internal operations, comply with applicable legal or other obligations, and to exercise or defend legal claims.
We may disclose the personal information we collect or you provide as described in this Policy:
- with any member of our corporate group, including our subsidiaries and affiliates, for internal purposes, such as internal administration and to provide you with certain services and offerings;
- with our business partners, suppliers, service providers, subcontractors, and other third parties we use to support our business, such as those that provide email services, fraud prevention, web hosting, or analytic services;
- in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which case we may disclose your personal information to the prospective seller or buyer of our business or assets;
We may also use and share personal information to fulfill any purpose for which you provide it, for any purpose that we disclose when you provide the data, and/or with your consent. We may use and share non-personal information without restriction.
- Essential cookies enable you to navigate our Site and to use our services and features. Without these cookies, our Site will not perform as smoothly for you as we would like, and we may not be able to provide certain core functions and features.
- Analytics cookies collect information about the use of our Site and enable us to improve the way it works. For example, analytics cookies show us the most frequently visited pages and analyze site traffic. We use them to look at overall patterns of usage on the site, rather than the usage of any particular individual.
- Marketing cookies track browsing habits and are used to deliver targeted (interest-based) advertising. You can opt out of receiving interest-based ads for web properties here (Digital Advertising Alliance’s WebChoices) and here (Network Advertising Initiative Opt-out).
Most browsers are set up to accept cookies automatically. You can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer. Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.
You can ask us to stop sending you marketing messages and other email publications, such as newsletters or alerts, by following the opt-out or unsubscribe links on any such communication sent to you or by contacting us at email@example.com. Please note that, if you opt out of receiving such messages, we may still send you emails about other services, products or offerings you have requested or received from us.
5. Security and Retention
We use reasonable security measures designed to protect personal information collected through our Site. Unfortunately, the transmission of information via the internet is not completely secure. As such, we cannot guarantee the security of your personal information transmitted to the Site.
We will retain your personal information in a manner consistent with our internal records management policies and procedures reflecting the purposes for which we collected the data and our obligations under any applicable legal, regulatory, tax, accounting or reporting requirements.
6. Children’s Privacy
We do not direct our Site to minors and we do not knowingly collect personal information from children under 13. If we learn that an under-13 user has volunteered personal information on the Site, we will delete such information from our active databases.
7. Supplemental Information for California Residents
This section applies to California residents (as defined under California law) consistent with the California Consumer Privacy Act of 2018 (Cal. Civ. Code § 1798.100 to 1798.199), as amended (CCPA).
Categories of Personal Information We Collect and How We Use and Share that Information
During the past twelve (12) months, we have collected, used, and shared the following categories of personal information:
- Identifiers, such as contact information;
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as contact information;
- Commercial information, such as information about services or products purchased, obtained, or considered; and
- Internet or other similar network activity, such as information about a consumer’s interaction with a website.
We may share this information with service providers who provide services to us or otherwise act on our behalf.
California Consumer Rights
If you are a resident of California, you have the following rights:
- Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business and commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Right to Delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. If so, we will notify you in our response than an exception applies and identify that exception.
- To exercise your Right to Know and Right to Delete, please submit a verifiable consumer request to us by emailing firstname.lastname@example.org. To verify your identity we may ask you for additional information, which may include asking you to confirm other personal information you have provided to us. We reserve the right to deny any requests for which identity cannot be verified. If you have authorized another person to make a request on your behalf, that person must provide to us your written authorization allowing them to make such a request on your behalf. We reserve the right to deny any request by an authorized agent if we are not reasonably able to confirm proper authorization.
- We will not discriminate against you for exercising any of your rights under California law. Unless permitted by California law, we will not:
- Deny you goods or services;
- Charge you a different price or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services;
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- The CCPA provides a right to opt-out of the sale of personal information as that sale is defined in the statute. We do not sell California consumer personal information for monetary consideration; however, we may share information with third parties to help us better advertise to you. You may opt-out of targeted advertising by following the instructions in the Cookies section above.
- We do not collect personal information of consumers we know are less than 16 years of age.
8.Supplemental Information for Users Located in the EEA
This section applies to data subjects, as that term is defined in the European General Data Protection Regulation (GDPR), accessing our Site from the European Economic Area.
Legal Basis for Processing Your Information
We will only process your information where we have a legal basis to do so. The legal basis will depend on the reason(s) we collected and need to use your personal information. The different legal bases we rely on are:
- Consent: Where you have told us you are happy for us to process your personal information for a specific purpose, such as when you request that we contact you with information about our products and services.
- Legitimate interests: Where the processing is necessary for us to conduct our business, but not where your interests are overridden by your rights or interests. This may include processing to inform you of changes to our services, or to provide you with information about other services we offer.
- Contractual necessity: Where the processing is necessary based on your purchase of a product or service from our Site.
- Legal claims: Where the processing of your personal information is necessary for the establishment, exercise, or defense of legal claims.
- Legal obligation: Where we are required to process your personal information by law.
Transfers of Personal Information
The Site is published in the United States and is governed by United States law. If you are located within the EEA, you should be aware that your personal information will be processed in the United States.
We may transfer your personal information outside the EEA:
- In order to store it.
- In order to enable us to provide services to and fulfill our contract with you.
- In order to facilitate the operation of our business, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
You have the right under certain circumstances:
- To be provided with a copy of your personal information held by us;
- To request the rectification or erasure of your personal information held by us;
- To request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);
- To object to the further processing of your personal information, including the right to object to marketing;
- To request that your provided personal information be moved to a third party.
Your right to withdraw consent
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us as set forth in the Contact Information section below. Such withdrawal will not affect the processing of your personal information prior to the withdrawal.
How to exercise your rights
You can also exercise the rights listed above at any time by contacting us at email@example.com. The exercise of the above rights might be subject to certain conditions and we might require further information from you before we can respond to your request.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.
10. Contact Information
If you have any questions about this Policy or our privacy practices, please contact us at firstname.lastname@example.org.