Effective Date: April 25, 2022
Individuals under the Age of 16
As noted in the Terms, we do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 16 or knowingly allow such persons to register for our Services unless parental consent is first obtained. If you are under 16, 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 16 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 16 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.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see the section below entitled “Privacy Notice for California Residents” for more information.
Personal Information We Collect
We collect several categories of Personal Information from and about you as summarized in the following list:
- First and last name, user name (which may include first and last name), email address, postal address, age; unique personal identifier, e.g., IP address, customer/account name or number, phone number, cookies, beacons, pixel tags, mobile ad identifiers
Internet or other electronic network activity
- Your interaction with a website, app, or advertisement; website session information
Audio, electronic, visual, thermal, olfactory, or similar information
- Voice and/or video recording
Professional or employment information
- Email address
- Credit and debit card numbers
How We Collect Personal Information and from What Sources
Information You Provide Us. In many cases, we, our business partners, and/or service providers collect Personal Information directly from you when you are interacting with us, our business partners and/or service providers. For example, we may collect:
- Contact information (such as name, email address, postal address and phone numbers) when you make an inquiry or contact us in person or through the Site;
- Contact information (such as name, email address, phone numbers and mailing address), gender, date of birth, emergency contact information and academic history and other education information when you register for or use our Services (e.g. in-person or online tutoring);
- Contact information (such as name, email address, phone numbers and mailing address) and employment information when you apply for an employee position with Hodis Learning & Music; and
- Communications preferences and correspondence you send to us.
Information You Provide Us Directly. You can visit this Site without telling us who you are or revealing any personal information about yourself; however, you may choose to give us your personal information by completing the “Contact Us” form. The “Contact Us” form collects your name, address, phone number, and e-mail address.
Video/Audio Recordings. We may collect Personal Information through audio or video recordings of Hodis Learning & Music sessions. We will never record a session without your consent.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Site, including, but not limited to, traffic data, geolocation data, logs, and other communication data and the resources that you access and use on the Site.
- Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Site, the amount of time you spent on our Site, and the pages you viewed while on our Site.
- Behavioral Tracking. We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including, but not limited to, by enabling us to: (a) estimate our audience/visitor size and usage patterns; (b) store information about your preferences, allowing us to customize and improve our Site; (c) speed up your searches; and/or, (d) recognize you when you return to our Site.
The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.
Cookies (or browser cookies)
A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer or mobile device (Internet Explorer, Firefox, Safari or Google Chrome).
Different types of cookies which have different purposes are used on our Site.
These cookies are essential to allow you to browse our Site and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.
These cookies collect information on the use of our Site, such as which pages are consulted most often. This information enables us to optimize our Site and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Sites from their site and whether your visit has led to the use or purchase of a product or Service from our Site, including the references for the product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.
These cookies enable our Site to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Site corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Site. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
It is possible that you will come across third-party cookies on some pages of sites that are not under our control.
Local Storage Cookies. Certain features of our Site may use local stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. Local storage cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Pixel Tracking. In addition to using Cookies, the Site may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Site from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Site. If you visit our Site, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.
GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
IP Address. Our servers automatically record certain log file information reported from your browser when you access the Services. These server logs may include information such as which pages of the Service you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Services. These log files are generally deleted periodically.
Information We Collect from Third Parties
We may collect information that others provide about you when you use the Site, or obtain information from other sources and combine that with information we collect through the Site.
- Third Party Services. If you link, connect, or login to your account with a third party social media service (e.g., Facebook, Google, Instagram, Yelp, etc.), 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.
- Employment and Background Information. For job applicants in the United States, to the extent permitted by applicable laws, we may obtain reports from public records of criminal convictions or sex offender registrations. For applicants outside of the United States, to the extent permitted by applicable laws, we may obtain the local version of background or checks. You agree to and do hereby consent to our use of your information, including your full name and date of birth, to obtain such reports. If someone has written a reference for you, it will be published on your public profile page.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Site through partnerships, or about your experiences and interactions from our partner ad networks.
Some content or applications, including advertisements, on the Site are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information on how to opt-out of third-party advertiser tracking mechanisms, please click here.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.
You also may submit information, such as comments, reviews, testimonials, etc., to be published or displayed (“posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “Content”). Your Content is posted and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons. By posting any Content you agree to and do hereby grant us and our licensors, affiliates, partners, successors and assigns, a nonexclusive, perpetual, irrevocable, worldwide, sublicensable, transferrable, royalty-free right and license to use, store, display, publish, transmit, transfer, distribute, reproduce, rearrange, edit, modify, aggregate, summarize, create derivative works of and publicly perform the Content that you post or otherwise submit to us for any purpose, in any form, medium, or technology now known or later developed (“Right to Use”). The Right to Use you grant us also extends to any Content that you have posted to our Facebook or other social media account pages, or on other websites, e.g., Google, Yelp, Trip Advisor, Instagram, etc. The term “Use” includes, but is not limited to, use, reproduce, modify, publish, list information regarding, edit, delete, translate, distribute, publicly display, publicly perform, and make derivative works of the content.
By posting any Content, or submitting content for posting, you agree to with the following “User Content Posting Guidelines”:
To the extent our Website contains areas where you can post or submit to be posted such as comments, product reviews, testimonials, etc., you agree to post Content that is proper and related to the general theme of the Website. Content also includes that which you send to us by email, text, mail, or other means. You agree not to post any Content that:
- Is off-topic, false, inaccurate, misleading, defamatory, libelous, stalking, threatening, obscene, pornographic, indecent, vulgar, offensive, which contains unlawful material or information, or which otherwise violate the legal rights (such as rights of privacy and publicity) of others;
- Harasses, degrades, intimidates, or is hateful toward an individual or group of individuals on the basis of religion, gender, sexual orientation or identity, race, ethnicity, age, or disability;
- Is not your own original creation or that you do not have permission to use or that infringes the copyright, trademark, patent, or other proprietary right of any person or that is used without the permission of the owner;
- Is intended to provide professional advice, including but not limited to, the provision of medical treatment, or legal, financial or investment advice;
- Promotes or provides instructional information about illegal or illicit activities;
- Purports to be from any person or entity, including but not limited to one of our employees, or falsely states or otherwise misrepresents your affiliation with a person or entity;
- Includes personal or identifying information about another person without that person’s explicit consent, or is doxxing;
- Contains software code of any kind, including, but not limited to, code that contain viruses, corrupted files, or any other similar software or programs designed to or that may interrupt, lock up, destroy, damage or limit the operation of another person’s computer or network or telecommunications equipment;
- Disrupts the normal flow of dialogue with an excessive number of messages (flooding attack) to the Website, or that otherwise negatively affects the ability of others to use the Website; or,
- Advertises or offers to sell any goods or services, or engage in surveys, contests, chain letters, or for any commercial purpose.
You may not attempt to gain unauthorized access to our computer systems or those of any our service providers or third parties, or engage in any activity that disrupts, diminishes the quality of, interferes with the performance of, or impairs the functionality of, the Website or our services. We reserve the right, but do not undertake the obligation, to refuse to post or remove any posted Content from our Website for violation of these rules or for any other reason, and to refuse to accept any future postings by you.
How We Use Information You Provide
We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:
- To present our Site and its contents to you.
- To provide you with information and respond to your questions on products or Services that you request from us and information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you.
- To provide you with the services that you have requested.
- To process transaction payments, including, but not limited to, product and/or service fees, subscription fees, professional fees, membership dues, registration fees, and payments, refunds and reimbursements for any products or services that you choose to purchase from us.
- To provide you with notices about your account, including expiration and renewal notices.
- To notify you about information regarding or changes to our Site, our policies, terms, or any products or Services we offer or provide, or regarding your account.
- To process your account application and any changes to your account information.
- To process Personal Information or other information that you submit through to us.
- To allow you to participate in interactive features on our Site.
- To provide statistics about the usage levels of the Site and other related information to reputable third parties, but these statistics will not include information which will allow you to be identified.
- To notify you of data privacy incidents or provide you with legally required information.
- To fulfill any other purpose for which you provide it.
- In any other way we may describe and for which we obtain your consent when you provide the information and you give your consent.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
We may use audio or video recordings of Hodis Learning & Music sessions to protect the safety and security of our students and instructors, to ensure the quality of our sessions and for our internal education and training purposes. We will never access or use video or audio recordings of sessions for any other purpose.
We use the information we collect about you to deliver the services we offer, and to operate and improve our Site. Our services may include a Short Message Service (“SMS”) which may deliver up to two messages per day to your wireless device and the display of personalized content and advertising. We may use your information to contact you about Site updates, conduct surveys, or informational and service-related communications, including important security updates. You may remove your information by replying “STOP” to the SMS text message you received. Alternatively, you may submit your request by email to us, including the email address and phone number you registered with us.
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 Site. 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 login.
For example, when you visit our Site, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Site 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 Site to your Facebook profile. This allows Facebook to assign your visit to our Site to your user account. Please note that as provider of the Site, 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 Site to your Facebook user account, please log out of your Facebook user account.
SHARING OF YOUR INFORMATION
We may or do disclose Personal Information to the following types of third parties, and for one or more the following purposes:
- Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
- Payment solution providers for the secure processing of payments you provide to us
- Technology providers who assist in the development and management of our Site
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, analyze data, 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, analyzing data, providing search results and links (including paid listings and links), and processing credit card payments. 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).
We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Site, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
We do not disclose or share your Personal Information with any third parties for which we receive any monetary or other valuable consideration. In other words, we do not sell* your Personal Information, period. (*as “sell” is defined in CCPA).
Disclosure of De-Identified Personal Information: We may share De-Identified Personal Information with third parties for any purpose. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Site. It may be utilized to measure the number of visits to our Site, average time spent, number of pages viewed and to monitor various other Site statistics. This monitoring helps us evaluate how visitors use and navigate our Site so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose. We may disclose, sell, rent, etc., your De-Identified Personal Information to third parties and we may receive valuable consideration for doing so.
Your Consent to Disclosure/Transfer/Sale of Your Personal Information: You consent to our disclosure of your Personal Information and other information to a potential or actual buyer 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, 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) of any or all of our rights to your Personal Information and your consents, in whole or in part, and other information, with or without notice to you and without your further consent.
Data Transfer/Access Outside of the United States
We have our headquarters in the United States. The Personal Information we or our service providers 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, and certain information may be accessible by persons or companies outside of the United States who provide services for us. 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 UK, European Economic Area (“EEA”), or Switzerland, we provide adequate protection for the transfer of Personal Information to countries outside of the UK, EEA, or Switzerland through a series of intercompany agreements based on the Standard Contractual Clauses. 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 UK, EEA, or Switzerland, or if you use our services and products while visiting countries outside this area.
If you are a resident of a 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 our personnel and by a limited number of service providers who have special access rights to our systems, and who are required to keep the information confidential. Our Site is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Site safer.
Payment transactions may be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information. All sensitive credit card information you supply to us is encrypted via Secure Socket Layer (SSL) technology and stored in a segregated secure database.
Privacy Notice for California Residents
The following section applies only to California residents.
California Online Privacy Protection Act (“CalOPPA”; Calif. Bus. & Prof. Code § 22575-22578, available here ):
CalOPPA applies only to companies which collect Personal Information of California residents.
How We Respond to Do Not Track Signals.
CalOPPA requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
Visitors can visit our Site anonymously by adjusting the settings in your browser.
Third-Party Behavioral Tracking. We allow third-party behavioral tracking (such as by Google) of Personal Information, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
California Consumer Privacy Act of 2018 (“CCPA”, available here ): If you are a California resident (occasionally referred to herein as “Consumer”), California law provides you with additional rights regarding our use of your Personal Information.
This “Privacy Notice for California Residents” section does not apply (at least until January 1, 2021) to the Personal Information of California residents that we collect:
- which is reflecting a written or verbal communication or a transaction between us and you, where you are acting as an employee, owner, director, officer, or contractor of a company or government agency and whose communications or transaction with us occurs solely within the context of our conducting due diligence regarding, or providing or receiving a product or service to or from such company or government agency; or,
- in the course of your acting as a job applicant to or an employee of our company to the extent that your Personal Information is collected and used by us solely within the context of your role or former role as a job applicant to, an employee of our company.
Starting January 1, 2020, California residents have the right to (a) access a copy of their Personal Information held by us, (b) request deletion of their Personal Information held by us, and (c) opt-out of the sale of their Personal Information (but which is inapplicable to us because we do not sell your Personal Information). These rights can be exercised by completing and submitting a request.
No Sale of Personal Information
WE DO NOT SELL (AS THAT TERM IS DEFINED IN THE CCPA) YOUR PERSONAL INFORMATION, PERIOD.
Right To Access to Specific Information
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 or commercial purpose for collecting 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 (also called a data portability request).
- If we disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Right
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 (as described below).
As permitted by CCPA we may delete your Personal Information by (a) permanently and completely erasing the Personal Information on our existing systems with the exception of archived or back-up systems; (b) de-identifying the Personal Information; or, (c) aggregating the Personal Information.
We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal, regulatory or law enforcement obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable Consumer request to us (see the contact information below). Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Consumer request related to your Personal Information. You may also make a verifiable Consumer request on behalf of your minor child. You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. The verifiable Consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and,
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable Consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.
Email Verification Method: Upon receiving a data access or deletion request from you we will send an email to you at the email address we have for you on file. The email will ask you to respond to verify you as the Consumer making the request. Upon receipt of your verification we will match your information to that which is in our file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above).
Response Timing and Format
We will confirm receipt of your request within ten (10) days of receiving it. We will respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Please note that this right does not apply to business-to-business customers, employment applicants, or independent contractors to us, or if the disclosure of Personal Information is for purposes consistent with the California resident’s reasonable expectations, when considering the submission’s circumstances.
We will not discriminate against you simply for your exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including by refusing to gran discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or,
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- 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 by email, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding the Site 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.
GDPR: 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 Site 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
If you are subject to GDPR, your rights include the following:
- The right to access – Upon request, we will confirm any processing of your Personal Information and, and provide you with a copy of that Personal Information in an acceptable machine-readable format.
- The right to rectification – You have the right to have us correct any inaccurate Personal Information or to have us complete any incomplete Personal Information.
- The right to erasure – You may ask us to delete or remove your Personal Information and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion).
- The right to restrict processing – You have the right to ask us to suppress the processing of your Personal Information but we may still store your Personal Information. See below for more information.
- The right to object to processing – You have the right to object to your Personal Information used in the following manners: (a) processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); (b) direct marketing (including profiling); and, (c) processing for purposes of scientific/historical research and statistics. See below for more information.
- The right to data portability – You have the right to obtain your Personal Information from us that you consented to give us or that is necessary to perform fulfillment of member benefits with you. We will give you your Personal Information in a structured, commonly used and machine-readable format.
- The right to complaint to a supervisory authority – You have the right to file a complaint with a supervisory authority, in particular in the European member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of Personal Information relating to you infringes upon your rights.
- The right to withdraw consent – We rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
HOW TO CONTACT US
Collecting Personal Information. In connection with our recruiting and job application process, you may provide personal information to us. We ask for certain data, including (unless prohibited by applicable law) educational and employment background, contact information and preferences, job qualifications, and jobs for which you would like to submit an application. You also may choose to provide us additional information, such as your CV, resume, and/or transcripts; employment references and related information; and compensation requests. In addition, we may collect information from third parties, for example, in connection with a background or employment check and/or an employment reference (as permitted by applicable law).
Sensitive Personal Information. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. If you have a disability and would like us to consider any accommodation, you may provide that information during the recruiting process.
Voluntary Disclosure. Your provision of personal information in connection with recruiting or job application process is voluntary, and you determine the extent of information you provide to us. Please note that if you decide not to provide certain required information, it may affect our ability to consider you for employment.
Use of Personal Information. The information you provide may be used to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements.
We may employ security procedures at our facilities and on our computer systems to monitor and maintain security, including the use of closed circuit television. Any monitoring of our facilities, systems or assets is performed in accordance with applicable law.
Retention and Access. We may retain your information to consider you for other job opportunities. To the extent permitted or required by law, we may delete data at any time; accordingly, you should retain your own copy of any information you submit to us.
Your Responsibilities. You are responsible for the information you provide or make available to us, and you must ensure it is honest, truthful, accurate and not misleading in any way. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable.