1. Introduction and Overview.
If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.
2. Information Collection.
A. Information You Provide.
We collect information about you when you use the Service, including information you provide when you access our content, contact us, or apply for a job. The categories of information we collect include:
- Contact Data, including your first and last name, business contact information, email address, and phone number.
- Content, includingcontent within any messages you send to us (such as feedback or questions to customer support).
- Billing Data, includingyour payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
- Job Applicant Data, including your employment and education history, transcript, work samples, and references as necessary to consider your job application for open positions.
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
B. Information Collected Automatically.
In addition, we automatically collect information when you use the Service. The categories of information we automatically collect include:
- Service Use Data, including data about features you use, pages you visit, emails you view, services you view, the time of day you browse, and your referring and exiting pages.
- Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address.
- Location Data, including non-precise location data (such as location derived from an IP address or data that indicates a city or postal code level).
The types of tracking technologies we use to automatically collect this information include:
- Cookies, which are small data files stored on your browser that save data about your visit. Cookies often include a unique identifier (e.g., cookie #123). We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising. Persistent cookies may remain on your device for extended periods of time, and expire on a set expiration date or when they are deleted manually.
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.
C. Information from Our Clients.
For further information on your rights and choices regarding client data, see the “Your Rights and Choices” section below.
D. Information from Other Sources.
We also collect information from other sources. The categories of sources from which we collect information include:
- Social media platforms with which you interact.
- Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
- Publicly-available sources, including data in the public domain.
- Data brokers from which we purchase or license data to supplement the data we collect.
3. List of Information
- Providing the Service to you.
- Preventing and addressing fraud, breach of policies or terms, or threats or harm.
- Understanding trends, usage, and activities, including through tracking technologies or surveys, to make business and marketing decisions.
- Communicating with you about updates, security alerts, changes to policies, and other transactional messages.
- Personalizing your experience to show you content we believe you will find interesting.
- Engaging in direct marketing, promotional communications, and non-personalized advertising.
- Engaging in personalized advertising, including Interest-based Advertising.
- Fulfilling any purpose at your direction.
- Other purposes as applicable, with notice to you and your consent.
Notwithstanding the above, we may use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) for any purpose to the extent permitted by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
4. Disclosure of Information.
- Service Providers and Contractors. We disclose information to service providers and contractors that process information on our behalf. Service providers and contractors assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers and contractors from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law.
- Analytics and Advertising. We disclose information to vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
- Affiliates. We disclose information to our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
- Clients. We disclose information to our clients in connection with the services we provide to them. Our clients are independent entities and their processing of information is subject to their own privacy policies.
- Merger or Acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
- Security and Compelled Disclosure. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
- Facilitating Requests. We disclose information where you direct us to disclose the information.
- Consent. We disclose information with notice to you and your consent.
Notwithstanding the above, we may disclose publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law. For information on your rights and choices regarding how we disclose information about you, please see the “Your Rights and Choices” section below.
5. Other Parties.
6. Analytics and Advertising.
We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).
We also use audience matching services (which is a type of Interest-based Advertising) to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Service, and the ad partner matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may disclose your hashed email address to Facebook as part of our use of Facebook Custom Audiences.
For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
7. Your Rights and Choices.
A. Jurisdictional Rights.
B. Tracking Technology Management.
- Cookies. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.
C. Analytics and Interest-Based Advertising Management.
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.
The companies we work with to provide you with Interest-based Advertising may be participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To opt out of receiving Interest-based Advertising from the participating companies, please visit https://www.aboutads.info/choices and https://www.networkadvertising.org/choices/ for website opt outs and https://www.aboutads.info/appchoices for mobile opt outs. Note that opting out through these links only means that the selected participants should no longer deliver Interest-based Advertising to you, but does not mean that the participants will not process your information for Interest-based Advertising purposes or that you will no longer receive Interest-based Advertising from other companies.
Please note that the above opt outs only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of any opt outs offered by other entities.
- E-mails. You can unsubscribe from receiving promotional emails by following the unsubscribe instructions at the bottom of the email, or emailing us at firstname.lastname@example.org with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional messages.
Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions.
The Service is not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us at email@example.com. We will delete the personal information in accordance with COPPA.
9. Data Security.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
10. International Transfer.
12. Contact Us.
709 N. Main St.
Winston-Salem, NC 27101
California provides additional rights to California residents, including through the California Consumer Privacy Act as replaced by the California Privacy Rights Act (“CCPA”). This section addresses those rights and only applies to California residents.
We acknowledge that you may have rights under the CCPA in connection with the personal information we process on behalf of our clients. If personal information about you has been processed by us as a service provider on behalf of a client and you wish to exercise any rights you have with such personal information, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your personal information. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.
A. Notice of Collection.
We have collected the following categories of personal information (as described in the CCPA) in the past 12 months.
- Identifiers, including name, email address, account name, and online identifiers (such as IP address).
- Customer records, including phone number, billing address, and credit or debit card information.
- Commercial or transactions information, including records of products or services purchased, obtained, or considered.
- Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
- Non-precise geolocation data,including location derived from an IP address.
- Professional, employment, or education-related information.
- Inferences drawn from any of the information identified in this section.
For further details on the personal information we collect and the sources from which we obtain personal information, please review the “Information Collection” section above.
We collect and use this personal information for the business purposes set out in the “Use of Information” section above. We disclose this personal information to the categories of persons set out in the “Disclosure of Information” section above. Please visit those sections for further details.
We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the CCPA. A “sale” is broadly defined under the CCPA to include a disclosure for something of value, and a “share” is broadly defined under the CCPA to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, non-precise geolocation data, and inferences drawn. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. For details about your rights regarding sales and shares, please see the “Right to Opt-Out” section below.
We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.
We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
C. Right to Know, Correct, and Delete.
You have the right to know certain details about our data practices. In particular, you may request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold or shared;
- The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared;
- The business or commercial purpose for collecting or selling or sharing the personal information; and
- The specific pieces of personal information we have collected about you.
In addition, you have the right to correct or delete the personal information we have collected from you. These rights are subject to certain exceptions.
To exercise any of these rights, please email us at firstname.lastname@example.org. If you have an account with us, we may require you to use the account to submit the request. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 business days and respond to your request within 45 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
Please note these rights are subject to exceptions.
D. Right to Opt-Out of Sales and Sharing.
To the extent we “sell” or “share” your personal information as those terms are defined under the CCPA, you have the right to opt-out of the sale or sharing of your personal information by us to third parties at any time. You may exercise this right through our Do Not Sell or Share My Personal Information form or by turning on a recognized opt-out preference signal in your browser or extension. At this time, we recognize the Global Privacy Control signal.
When you submit an opt-out, except as provided below, your opt-out will only apply to sales and shares from the specific browser from which you sent the signal because the connection between your browser identifier and other personal information we have about you is not known to us.
E. Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and may verify your identity directly.
F. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
G. Shine the Light.
Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
Virginia provides additional rights to Virginia residents through the Virginia Consumer Data Protection Act (“VCDPA”). This section addresses those rights and applies only to Virginia residents.
You have the following rights under the VCDPA:
- To confirm whether or not we are processing your personal data
- To access your personal data
- To correct inaccuracies in your personal data
- To delete your personal data
- To obtain a copy of your personal data that you previously provided to us in a portable and readily usable format
- To opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you
To exercise any of these rights, please email us at email@example.com and specify which right you are seeking to exercise. We will respond to your request within 45 days. If you have an account with us, we may require you to use the account to submit the request. We may require specific information from you to help us confirm your identity and process your request. If personal data about you has been processed by us as a processor on behalf of a client and you wish to exercise any rights you have with such personal data, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your personal data. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.
If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at firstname.lastname@example.org and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.