Privacy Statement & Legal Notices
Note about Children: Our Services are intended for users above the age of thirteen. FIDM does not knowingly collect personally identifiable information from any child under the age of thirteen. When we do receive such information we delete it as soon as we discover it and do not use it or share it with third parties.
Information Sharing: Remember that if you create a Profile (as defined below) or participate in community forums and similar features on the Services, your information may be public. Note that we do not share your Personal Information with third parties for their marketing purposes without your consent; however, we may share your Personal Information under certain limited circumstances. For more details, please review the section below entitled "Will FIDM share any of the information it collects?"
Third Party Networks and Analytics Providers: FIDM does not currently host advertisements on the Services. However, we work with analytics service providers and other third parties to provide us with information regarding traffic on the Services, including the pages viewed and the actions users take when visiting the Services; to serve our advertisements on other web sites, within mobile Apps, and elsewhere online; and to provide us with information regarding the use of the Services and the effectiveness of our advertisements. For example, if you click on a FIDM advertisement, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement.
Our analytics service providers and other vendors may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you and your visits to and activity on the Services, as well as on other web sites or online services. Some of these parties may collect Personal Information when you visit the Services or other websites and services. Please review "Third Party Networks and Analytics Providers” for additional information.
Opting Out: Some of the companies who serve these targeted ads participate in a self-regulatory program that allows you to opt-out of having information about you used for this purpose, and you may access that opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads while online. Please review the section entitled “How can I opt-out of sharing, providing, or receiving certain information?” for more details on opting out generally.
Information Shared With Us
Registration and Other Information You Provide
The Services may collect "Personal Information" (which is information that can reasonably be used, alone or in combination with other reasonably available information, to identify or contact a specific individual). Personal Information includes, but is not limited to your name, social security number, email address, phone number, physical address or zip code, account information (such as a password or other information that helps us confirm that it is you accessing your account) and demographic or other information (such as your gender, age or birthdate), job or career information, and information about your interests and preferences. Any information combined with Personal Information will be treated as Personal Information. Please note that if you access the Services via Single Sign On through a university or other account, the Personal Information collected by FIDM may vary.
- IRS-related purposes
- For awards of financial aid and collected via the FAFSA
- Identification for unincorporated independent contractors
- Certain billing collection functions for students and responsible parties
- Publicly post or display the Social Security number in any manner;
- Print the Social Security number on any card required to access service;
- Require an individual to transmit his or her Social Security number over the internet unless the connection is secure or the number is encrypted;
- Require an individual to use his or her Social Security number to access an internet site unless a unique password or PIN is also required; or
- Print a Social Security number on any materials that are mailed unless required by a state or federal agency, unless state or federal law requires the Social Security number to be on the document to be mailed. Also, Social Security numbers may be included in applications and forms sent by mail, including documents sent as part of an application or enrollment process, or to establish, amend or terminate an account, contract or policy, or to confirm the accuracy of the Social Security number.
Your Profile, Community Forums and User Content
Your Profile: You may have the opportunity to create a profile, which consists of information about you ("Profile"). Some of the information in your Profile may be visible to third parties or to everyone. FIDM may also make the information contained in your Profile accessible through means other than the Services (such as through an app or an application programming interface (API)). We do not control how frequently third-party search engines update their indexes; consequently, their information may be outdated and still available for a period of time even if you discontinue use of the Service.
Third Party Services, Social Media Platforms, and Information Third Parties Provide About You
Third parties may provide us with information about you. For example, if you are on a third party web site, and you opt-in to receive information from us, that third party will forward information about you to us so that we may contact you as requested.
Additional Requirements Regarding Social Security Numbers
Permitted use of Social Security numbers
Social Security numbers may only be collected in the following circumstances or as otherwise required by law:
Additional security standards for Social Security numbers
Social Security numbers stored on FIDM systems must be encrypted or masked at rest and in transit.
Restricted use of Social Security numbers
It is against state law to:
Note that in order to provide services and opportunities to you, educational organizations, scholarship providers and other third parties may (to the extent permissible by law) be able to review certain information in your Profile for some of the Services, whether or not you have limited public access to that information. You may have the opportunity to control whether this information is shared, but some information may be shared automatically -- all as disclosed on the website or other service where you created your Profile. FIDM does not share your contact information (email, full postal address or phone number) with those third parties unless you request or agree to that sharing.
Community Forums: The Services may provide you the opportunity to participate and post content publicly in forums, through interactive features and through other communication functionality ("Community Forums"). You may choose, through such features or otherwise, to submit or post reviews, suggestions, ideas, questions, answers, comments, testimonials, feedback, messages, images, videos, text or other material ("User Content"). Your User Content may also be posted in your Profile. Please think carefully about what you post and before including Personal Information in your User Content. You may edit or remove your Profile information, but you may not be able to remove answers or postings or other uploaded User Content on some Services. To request removal of content you posted publicly on the Services, contact us via email by clicking here. We will honor removal requests received from registered users under the age of 18 or not yet enrolled in FIDM or where required by law. Other removal requests received, may, in our sole discretion, be honored or refused (except that all such requests will be considered in the context of all applicable laws and regulations). In some cases, we may remove only your Personal Information but maintain the rest of your User Content. Note that removal of public postings does not ensure complete or comprehensive removal of the content or information posted.
In addition, the Services may allow members to communicate and collaborate with each other, including some Services that allow members to engage in one-on-one communication using a video chat or text chat feature. If you create an account, participate in a Community Forum or choose to communicate with others through the Services, certain information about you may be disclosed in connection with your or others' use of the Services, including certain information about you and your network (such as your name and profile photo, the number of your connections, and the names and pictures of your connections). Our servers may record and we may retain records of the content of any such user-to-user communications.
You may also choose to participate in a third party application or feature through our Services (such as logging in through Facebook Connect or otherwise linking the Services with another web site or interactive service) or on a third party web site or service (such as one of our Facebook applications or a similar application or feature on a third party web site or service) through which you allow us to collect (or the third party to share) information about you, including Personal Information. Information about you, including your name and profile photo, may be shown to other users of the Services if you are logged in through the Services or through a third party web site or service. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected. When you choose to participate, you may be opting to link your activity on our Services with that third party web site or service, which may then collect information about your visits to our Services and may publish that activity as you request to your profile or similar feature with that third party. In some instances, we may require that you participate in the Services through a third party application or feature and, if you choose not to authorize or use the required third party application or feature, you will not be able to use the applicable Service.
Information We Collect Automatically
Like other web sites and online services, we and our analytics providers, vendors and other third party service providers may automatically collect certain "Usage Information" whenever you access and use the Services, including, without limitation, by viewing information about a course or school, exploring academic programs and co-curricular opportunities in a school, exploring career options, viewing information about potential employers, asking or answering questions, viewing another user's Profile, sending a message, searching for a person or information, or by clicking on an advertisement.
Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Services (if applicable), the search terms you entered into a search engine that lead you to our Services (if applicable), all of the areas within our Services that you visit (including information about any ads you may view), and the time of day you used the Services, among other information. We may use Usage Information for a variety of purposes, including to tell you about people or events nearby, to provide special offers, to serve advertisements, to select appropriate content to display to you, and to enhance or otherwise improve the Services and our products.
In addition, we automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone or other device (any, a "Device") you may use to access the Services. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the Device used to access a Service, internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data.. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.
Usage Information is collected via tracking technologies, including:
Cookies: Our Services utilize Cookies to improve your current and future experience by allowing us to understand your usage of our Services. A cookie is a text file that is placed on your hard disk by a web page server to help identify the user’s computer and can be used to help FIDM recall your information on subsequent website visits. Cookies cannot be used to run programs or deliver viruses to your computer. For example, cookies help our systems recognize you if you return to our Services shortly after exiting them. In order to use certain secure areas of the site, cookies must be enabled. If you have question about how to enable “cookie” settings please visit www.enablecookies.info.
Web Beacons: We, as well as our affiliate program partners, service providers, and other third parties, may employ a software technology called clear gifs (a.k.a. web beacons/web bugs), that help us better manage content on our Services by informing us of what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users for our affiliate program. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. This information is used to help improve the overall quality and experience of our Services. We tie the information gathered by clear gifs to our customers' Personal Information.
An Embedded Script: is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third party service provider and is deactivated or deleted when you disconnect from the Services.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
Flash & HTML5: We use Local Storage Objects (LSOs) such as HTML5 to store content, information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 & Flash to collect and store information.
Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here.
How We Respond To Do Not Track Signals:
Please note that your browser setting may allow you to automatically transmit a "Do Not Track" (DNT) signal to websites and online service you visit. DNT is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT. To find out more about "Do Not Track", please visit www.allaboutdnt.com.
We may use information about you, including Personal Information, the information you provide in your Profile, User Content, and Usage Information to:
- Provide educational services as requested upon submission of information.
- Communicate with you about the services, content, features or products you use or request.
- Customize and optimize the content or advertisements you receive when you use the Services, and otherwise improve your experience on our Service.
- Analyze and improve our services, which will include tracking traffic, usage and navigation patters related to your activities on the Service and the links we provide to third-party websites or advertisements.
- Secure your account and prevent fraud
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- Protect our own or third party rights or interests.
Note that we may create, facilitate or display social advertisements, whereby your name and profile photo may be used to advertise products and services to your network based on your use of the Services and your interactions with FIDM and third parties through the Services (a "Social Ad"). If we are utilizing Social Ads on one of our Services, you will be able to opt-out through your account settings for that Service.
Please note that information submitted on the Services via a "Contact Us" or other similar function may not receive a response. We will not use the information provided via these functions to contact you for marketing purposes unrelated to your request unless you agree otherwise.
FIDM does not share your Personal Information with third parties for their marketing purposes without your consent and in compliance with applicable laws. FIDM may share non-Personal Information, such as aggregate or de-identified user statistics, demographic information and Usage Information with third parties, including advertisers, content providers, and analytics providers; and third parties may collect non-Personal Information when you visit the Services.
Other Educational Institutions
We work with other colleges, universities, scholarship providers, foundations, benefactors and educational institutions ("Educational Institutions") to help guide students through the educational journey – exploring, learning, planning and collaborating, as well as extract insights from across various siloes. We do not share your contact information (email address, full postal address or phone number) with these Educational Institutions without your consent, but we may send you information on their behalf.
In addition, you may indicate that you would like to receive additional information from Educational Institutions or other third parties and we will then share your information with those parties so that they may contact you per your request. We are not responsible for the privacy policies and practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.
When You Request That We Share Your Information
This includes, without limitation, instances in which you use our Services to purchase products or services provided, in whole or part, by third parties. You also may request, sometimes through your use of an interactive feature, a widget or third party application, that we share information about you with a third party and we will typically do so under those circumstances.
We will share your Personal Information with third parties to provide services to us or you in connection with the Services, but subject to confidentiality obligations which limit their use and disclosure of such information. For example, we may provide your Personal Information to companies that provide services to help us with our business activities, sending our emails, or offering customer service. If you purchase any products or services, our billing partner will receive billing and financial information (e.g., credit card numbers) necessary to process your charges, including your postal and e-mail addresses, depending on your payment method.
Administrative, Legal Reasons & Academic Integrity Investigations
We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. These disclosures may be carried out without your consent or without notice to you.
Sweepstakes, Contests and Promotions
We may offer sweepstakes, contests, and other promotions ("Promotion") that may require registration. By participating in a Promotion, you are agreeing to governing terms, conditions or official rules, which may contain specific requirements of you, including allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information, such as your name and shipping address, may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.
We may display personal testimonials on our Services in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us via email by clicking here.
Third Party Networks and Analytics ProvidersWe work with analytics service providers and other vendors to provide us with information regarding traffic on the Services, including the pages viewed and the actions users take when visiting the Services; to serve our advertisements on other websites, within mobile apps, and elsewhere online; and to provide us with information regarding the use of the Services and the effectiveness of our advertisements. For example, if you click on a FIDM advertisement, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement. FIDM does not currently serve advertisements on or through the Services.
Some of the companies who serve these targeted ads participate in a self-regulatory program that allows you to opt-out of having information about you used for this purpose, and you may access that opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads while online. We may share Usage Information about visitors with analytics providers and other vendors. Our analytics service providers and other vendors may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you and your online browsing activities. Some of these third parties may collect Personal Information over time when you visit the Services or other web sites and services.
Third Party Content, Links to Other Sites, and FIDM Content Found Outside of the ServicesCertain content provided through the Services may be hosted and served by third parties, which may include third party widgets (such as those that allow you to "like" or "share" content with third party web sites and online services. In addition, the Services may link to third party web sites or content over which FIDM has no control and which are governed by the privacy policies and business practices of those third parties. In addition, third-party partners of FIDM from whom your order through the Services may have different privacy policies which apply to such partners use of your information. Please also note that FIDM content and widgets may be included on web pages and web sites that are not associated with us and over which we have no control. These third parties may independently collect data. FIDM is not responsible or liable for the privacy practices or business practices of any third party.
If you use the Services through a mobile device or one of our mobile applications, your mobile Device Identifier your mobile carrier, and your physical location may be transmitted to FIDM. You agree that FIDM may store and use that information for security purposes (for example, for user verification or authentication and to ensure that our APIs are being used appropriately). If you wish to no longer allow FIDM to track your physical locations you may turn this off within your device settings. You may be able to opt-in to receiving text messages from FIDM. You may always opt-out by replying "STOP" to one of the text messages received. You also acknowledge and agree that use of the Services through a mobile device may cause data to be displayed on and through your mobile device which may be viewed by your mobile carrier or other access provider.
Push Notification: We will send you push notifications if you agree to receive them. You may opt-out of receiving these at any time by going to the phone settings and turning them off.
FIDM takes data security very seriously. FIDM takes commercially reasonable technical, physical, and administrative security measures designed to protect the Personal Information submitted to us, both during transmission and once we receive it. Such measures vary depending on the sensitivity of the information at issue. FIDM secures your personal information on computer servers in a controlled, secure environment that is only accessible by a limited number of authorized persons. When highly confidential information (such as a credit card number) is transmitted over the Internet, it is protected with encryption.
Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means designed to protect your Personal Information, we cannot guarantee its absolute security.
How will FIDM handle a data breach or security incident?
In the event that FIDM becomes aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. For example, we may post a notice on our homepage or elsewhere on the Service, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
FIDM has procedures in place that are designed to stop threats that may expose personally identifiable information, restore Services to full functionality, document and take proactive steps to ensure the incident cannot be repeated. FIDM will also preserve necessary evidence for investigation by security professionals and law enforcement as appropriate. In the unlikely event of an unauthorized disclosure of records, FIDM will follow its Security Incident Response Procedure, which articulates how to report the problem to internal and external stakeholders. The notification process includes any information that can identify which customers and students may have been impacted, the data that may have been accessed, FIDM’s process to inform affected customers, and steps to prevent the incident from happening again as appropriate.
In the unlikely event of an unauthorized disclosure of Data, FIDM has implemented a process for responding to incidents and notifying affected individuals and, if applicable, law enforcement personnel.
If you have any questions about security on our Services, you can email us by clicking here.
Providing Personal Information: You can always decline to share personal information with us, or even block all cookies. However, it’s important to remember that many of FIDM’s features may not be accessible, or may not function properly - for example, we may not be able to remember your language preferences.
Objection to Marketing: At any time , you have the right to object to our processing of data about you , to which you have consented for the purposes of keeping you updated with the latest news about FIDM events, Educational opportunities and other services.
Targeted Advertisements: Some of the companies who serve targeted ads participate in a self-regulatory program that allows you to opt-out of having information about you used for this purpose, and you may access that opt-out by clicking firstname.lastname@example.org. Please note this does not opt you out of being served advertising. You will continue to receive generic ads while online.
Social Advertisements: If we are utilizing Social Ads on one of our Services, you will be able to opt-out through your account settings for that Service.
Mobile Use: If you wish to no longer allow FIDM to track your physical locations you may turn this off within your device settings. You may always opt-out of receiving text messages by replying "STOP" to one of the text messages received. You may opt-out of receiving push notifications at any time by going to the phone settings and turning them off.
Email Communication: You can opt-out of receiving further communications by visiting your account preferences page or clicking the unsubscribe button at the bottom of the email.
You may be able to review the information you provided to us on a Service and make any desired changes to the information by contacting us at email@example.com or 1.800.624.1200 and requesting to access your personal information. To process these requests you must supply us with the following information:
- Type of data request (Access, Portability, Correction, Erasure, Restriction or Objection)
- Your name
- Your email address
- Other details
To unsubscribe from any of our services send an email to firstname.lastname@example.org. In the body of the message, please include the following information:
- Name of service or mailing list from which you wish to unsubscribe
- Your name
- Your email address
Such requests will be handled in a timely manner.
FIDM sends a variety of communications via email, text message, and push notification. Such messages include academic and administrative information as well as marketing communications.
You may be able to limit the information you receive from us using the unsubscribe button at the bottom of the FIDM email. However, we reserve the right to send you information on our behalf and on behalf of third parties in connection with providing the Services. If you no longer want to receive information from us, you will need to close your account for that Service.
If you wish to close your account with one of our Services, please email email@example.com and we will remove your Personal Information and Profile, if applicable, from the active databases for the Service(s) you request. Please let us know which Service(s) you wish to close and send your request using an email account that you have registered with FIDM under your name. You typically will receive a response to a request sent to this account within five business days of our receiving it. Requests to unsubscribe from all emails may not be made through this email address, but rather must be submitted through one of the channels set out in the previous section.
If there are material changes to this Statement or in how FIDM will use your personal information, FIDM will prominently post such changes before implementing the change. FIDM encourages you to periodically review this statement to be informed of how FIDM is protecting your information.
If you are a resident of the state of California, you have certain data protection rights. FIDM aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. This section describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
In certain circumstances, you have the following data protection rights
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Opt-out of sales. We do not currently sell your Personal Information. If we plan to sell your Personal Information, you will be notified and you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
- Opt-in. We do not currently sell your Personal Information. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Services.
- Right to information, access and deletion. You can request to exercise your information, access and deletion rights.
- Right to opt-out of the “sale” of your personal information. We currently do not sell your Personal Information. If we plan to sell your information, you will be notified and you can request to opt-out out of this “sale” of your personal information.
How to Exercise Your Rights
You may exercise your California privacy rights described above as follows:
- You may contact us by email at firstname.lastname@example.org
- You may contact us by phone at 1.800.624.1200
- You may contact us by postal mail at the following address:
919 S. Grand Ave.
Los Angeles, CA 90015 USA
We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Personal Information That We Collect, Use and Share
[We have not sold your personal information in the preceding 12 months].
|Category of personal information (PI)||PI We Collect||Source of PI||Business/Commercial Purpose for Collection||Categories of Third Parties to Whom We "Disclose" PI for a Business Purpose||Categories of Third Parties to Whom We "Sell" PI|
|Internet or Network Information||
|Inferences||May be derived from you:
|Professional or Employment Information|
|Protected Classification Characteristics||We do not intentionally collect this information but it may be revealed in identity data or other information we collect|
Consent to Transfer
The Services are operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Data Protection Officer; Data Protection Authority
FIDM has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at email@example.com.
You may direct questions to the Data Protection Officer. You also have the right to (i) restrict FIDM’s use of information that constitutes your personal data, which will cause you to lose access to the Services and (ii) lodge a complaint with your local data protection authority.
Location of Data and Processing
Important Information for Users in the European Economic Area
The following information only applies to users in the European Economic Area (EEA), provided that we are the controller of their personal information as described below.
References to “personal information” in this policy are equivalent to “personal data” governed by European data protection legislation.
Legal Bases for Processing
We process your personal information on the following legal bases:
|Processing Purpose (including sharing for such purposes as described above)||Legal Basis|
|To provide the Services||Processing is necessary to provide the Services or to take steps that you request prior to requesting the Services.|
|To communicate with you about the Services
To improve your experience with the Services
To send you marketing communications and customize and optimize content or advertisements when you use the Services
For research and development
To create aggregated or anonymous data for analytics (including traffic, usage, and navigation patterns related to your activities on the Services and the links we provide to third party websites or advertisements)
For security, compliance, fraud prevention and safety
To protect our own or third party rights or interests
|These processing activities constitute our legitimate interests (including to enforce our rights arising from any contracts entered into between you and us, including billing and collection). We do not use your personal information for activities where your data protection interests override these legitimate interests (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with law||Processing is necessary to comply with our legal obligations.||
|With your consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated at the time consent is requested.|
Please note that we rely on legitimate interests as the basis for processing your data in the limited circumstances set out below:
- In situations where we obtain your personal data from a source other than you, we process your data on the basis of legitimate interests, until the earlier of (a) the point at which you provide your consent; or (b) the point at which you ask us to stop processing your data on the basis of our legitimate interests;
- We will archive information about your use of our services, even after you withdraw your consent to our processing of your data. This information will only be used in very limited circumstances, such as for defending legal claims relating to contracts we have with you or a third party and retention for audit purposes relating to commercial contracts; and
- We will use information relating to your use of our services for statistical analysis and research purposes, however we delete your name and email address from such information before we do so.
Cross-border Data Transfer
In the event that we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of protection for personal information, the transfer will be based on safeguards recognized by the European Commission as providing adequate protection, where required by EU data protection legislation. Please contact us to request further information on the specific mechanism used by us when transferring your personal information out of the EEA.
You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the legal basis of our processing your personal information, where that processing adversely impacts your legal rights.
You may send us these requests by emailing us at firstname.lastname@example.org. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to reject part or all of your request. If we reject your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described at email@example.com or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator at firstname.lastname@example.org.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.