Last updated March 13, 2020
1. Information We Collect
We have constructed the Site so that you may review information about our services, without revealing your identity or volunteering any personally identifying information. If you choose to contact us, request information, inquire about a service or subscribe to our newsletter, we will collect personally identifiable information (“PII”) from you, such as that indicated below, and this information may be combined, to provide you with information or service you request and to ensure that we maintain complete, current and accurate personal information.
In order to receive information from the Site, you may be required to provide us with certain information, including, for example, your name, e-mail address and phone number. Failure to provide such data may make it impossible for us to provide you with the requested information or service.
We use Google Analytics which is a web analytics tool that helps us understand how users engage with our Site. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our Site. This information is used to compile reports and to help us improve our Site. The reports disclose website trends without identifying individual visitors.
3. Use of Information We Collect
We may use PII or aggregate and/or de-identified data about Users (“Aggregate Information,” or “AI”) for various purposes, including:
- responding to questions and comments from Users;
- enabling Users to receive newsletters, updates, and other materials related to us;
- monitoring and analyzing the Site (including, but not limited to, measuring Users’ interest in, and use of, various areas of the Site);
- improving the functionality, design and quality of the Site;
- performing the technical administration of the Site;
- investigating cases of suspected abuse or fraud;
- preparing statistical and other summary analyses of our Users’ behavior; and
- any other purpose that we determine at our discretion is related to the use, advertising, marketing, promotion or other of our, or the Site’s legitimate purposes
(Collectively, “Our Purposes”).
Information You Provide Through the Site
We do not collect or maintain PII for resale purposes or share your information with any other company or organization, except as indicated herein or to the extent such other company or organization is acting as our agent for purposes of communicating with you by mail, e-mail, or otherwise. In addition, we will not send promotional materials to Users who indicate that they do not wish to receive such messages.
4. Disclosure of Personal Information
We may share your personal information with our carefully selected vendors, third party service providers and agents where it is necessary for Our Purposes. These parties may include web analytics service providers, such as Google Analytics for web analysis purposes.
We will provide these companies only with the information they need to deliver the service we have requested, and they are prohibited from using that information for any other purpose.
We may also share PII when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may, without providing notice to you, disclose any information about Users, including PII, to government or law enforcement officials or private parties where we are required to do so by law, including, but not limited to, in response to a court order or subpoena. We may also, without providing notice to you, disclose PII in response to a request by a law enforcement agency or other public agency or if we believe such disclosure may prevent or mitigate the threat of crime or harm to Users or others, facilitate an investigation related to a User’s safety or public safety, protect the security or integrity of our Site, or enable us to take precautions against liability;
- Maintain the security of our Site, products and services
Service providers and other third parties
We may also share PII with third parties when you give us consent to do so.
Processing the data collected through the Site is carried out using computers and/or IT enabled tools, following organizational procedures and modes related to Our Purposes. We may employ third party companies and individuals to facilitate the operation of the Site, and to perform services related to administration of the Site (including, but not limited to, maintenance, hosting and database management services, web analytics and administration and legal services). These third parties have access to Users’ PII and other personal data only to perform these tasks on our behalf. We may share AI, and reports based on AI, with third parties for industry analysis, demographic profiling, other commercial purposes, or to deliver targeted advertising about other products and services. No such AI that we provide to third parties will contain PII.
In connection with a sale of all or part of our operations, or sale or transfer of assets, or a merger, reorganization, or in the event of bankruptcy, we may transfer PII to a third party as part of the transaction, to the extent permitted by applicable law.
5. Your Privacy Choices
If a User becomes aware that PII we maintain about them is inaccurate, incomplete, misleading, irrelevant or out of date, or if an individual would like to access, update or review their information, the individual is solely responsible for updating such information, and may do so by contacting us using the contact information below. We will attempt to provide the requested information or make requested changes to the extent allowable by applicable privacy laws. In any event, we will respond to you as soon as reasonably possible to advise you of the outcome of your request. You may request the removal of previously provided PII at any time using the contact information below. The deletion of such data, however, may affect our ability to provide you with our services. We reserve the right to verify the identity of any person making an opt-out or correct/update request but shall have no liability whatsoever resulting from false or erroneous requests. You may update your PII, communications preferences, or opt out from receiving promotional materials at any time by contacting us at email@example.com
We retain PII for the period necessary to fulfil Our Purposes. In some cases, we retain PII for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
Please note that any information you share with us via email or via the internet is not completely secure. We take reasonable steps to protect the PII provided via the Site from loss, misuse and unauthorized access or disclosure, however, no internet or e-mail transmission is ever fully secure or error free. Due to the nature of the internet, there is a possibility that unsecured (unencrypted) email or internet transmissions could be intercepted and read by third parties. We assume no responsibility for interception of confidential information or personal information that you send in an unsecured (unencrypted) email message or other internet transmission to and from the Site. Therefore, you should take special care in deciding what information you send to us via the Site, e-mail or via another internet transmission.
You acknowledge and accept that, despite our efforts, there may be times or situations when your PII is inadvertently disclosed by us or by a third party to whom we have disclosed your PII. You hereby accept that risk and waive any and all claims, causes of action, damages and liability against us in the event of such inadvertent or negligent disclosure of PII.
9. Links to Third Party Sites
10. Your Choices and Opt-Outs
You can opt out of receiving marketing emails from us at any time. You can opt out of our marketing emails by clicking the ‘unsubscribe’ link at the bottom of our marketing messages.
Also, all opt out requests can be made by emailing us at: firstname.lastname@example.org. Please note that it may take up to sixty (60) days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make a request. However, we may inform you via email of extending such period from time to time.
11. Cross Border Transfers
This site is intended for use by persons and businesses located and operating in the United States. If you visit the Site from a country other than the United States, your communications will likely result in the transfer of your PII across national borders. Our servers or offices may be located in countries other than the country from which you access the Site, also resulting in the transfer of your PII across international borders. If you provide your PII when visiting the Site from outside of the United States, you acknowledge and agree that this data may be transferred from your then current location to our offices and servers and to those of our affiliates, agents, and service providers located in the United States and in other countries. The United States and such other countries may not have the same level of data protection as those that apply in the jurisdiction where you live.
12. Other Terms and Conditions
1 Pier 8
Charlestown, MA 02129
Attention: Yahira Llavona, Controller