Personal Information We May Collect
“Personal Information” is information that identifies you as an individual or relates to an identifiable person, including:
We 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.
How We Collect Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
Use of Personal Information
We and our service providers use Personal Information for our legitimate business purposes, including the following:
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
We will engage in this activity with your consent.
We provide personalized services either with your consent or because we have a legitimate interest.
We use your Personal Information in this context to manage our contractual relationship with you.
We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Disclosure of Personal Information
We disclose Personal Information:
Other Uses and Disclosures
We also use and disclose your Personal Information as we believe to be necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
How We Collect Other Information
We and our service providers collect Other Information in a variety of ways, including:
Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services 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.
We do not respond to browser do-not-track signals at this time.
IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). 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.
From you: Information such as your preferred means of communication is collected when you voluntarily disclose it.
By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
How We Use and Disclose Other Information
We 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 (such as combining your name with your location). 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 designed 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 (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
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 you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by clicking on the “Unsubscribe” link provided in each such email.
Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you prefer that we not share your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by e-mailing Privacy@combe.com. 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 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 in accordance with the “Contacting Us” section below. 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 recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.
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 understand that your information will be transferred 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.
If you are located in the EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission] to protect your Personal Information. You may obtain a copy of these measures by contacting us at email@example.com.
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.
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
If you are located in the EEA, you may lodge a complaint with a data protection authority competent for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.