Last Updated: April 26, 2018
If you are located in the European Union (EU), please note that we abide by the Safe Harbor framework agreed to by the U.S. Department of Commerce and the EU with respect to Personal Information collected by entities located in the European Economic Area and transferred to us in the United States. More information about the Safe Harbor framework can be found at http://www.export.gov/safeharbor/.
Some of our affiliated entities are UK based businesses and are registered under the UK Data Protection Act (see https://ico.org.uk/for-organisations/guide-to-data-protection/data-protection-principles) with the Information Commissioner and, as such, have committed to comply with the following eight principles of good information:
- process personal data fairly and lawfully;
- obtain personal data only for one or more specified and lawful purposes and to ensure that such data is not processed in a manner which is incompatible with the purpose or purposes for which it was obtained;
- ensure that personal data is adequate, relevant and not excessive for the purpose or purposes for which it is held;
- ensure that personal data is accurate and, where necessary, kept up to date;
- ensure that personal data is not kept for any longer than is necessary for the purpose for which it was obtained;
- process personal data in accordance with the rights of the individuals to whom the information relates;
- ensure that personal data is kept secure; and
- ensure that personal data is not transferred to a country outside the European Economic Area unless the country to which the information is to be sent ensures an adequate level of protection for the rights (in relation to the information) of the individuals to whom the personal data relates.
PERSONAL INFORMATION AND OTHER DATA WE COLLECT:
As you navigate through and interact with our Services, we may use certain technologies, including automatic data collection technologies, to collect information about your use of our Services, including, without limitation:
- Personal Information
- Information that identifies you, such as your email address, address, telephone phone number, passwords, etc.
- Other Data
- All other Information such as information about your computer and internet connection, including your IP address, URL, Browser type, domain name(s), Service usage data, including how you use the Services, server log files, information collected through cookies, pixel tags, and other technologies, access dates and times, operating system, Salesforce OrgID, Salesforce Username (not password), geographic location, demographic (including language type), page views, and user sessions.
HOW WE COLLECT INFORMATION:
We may collect the aforementioned information in a variety of ways, including:
- Through your browser or your device: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, device type (Windows or Macintosh), screen resolution, operating system version, Internet browser type and version and the type and version of the Service that you are using.
- Through server log files: An Internet Protocol (IP) address is a number that is automatically assigned to your device from which you are accessing the Service by your Internet Service Provider (ISP), and is identified and logged automatically in our server log files whenever you visit the Service, along with the time of the visit and the activity on the Service. We and our service providers use IP addresses for purposes such as calculating Service usage levels, helping diagnose server problems, administering the Service and determining your approximate geographic location.
- If your device stores Flash LSOs, and if you do not want Flash LSOs stored on your device through which you access the Service, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained using the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your device without you being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Service or our content. We expect our service providers and technology suppliers to honor any decision by you to restrict or limit Flash LSOs, but We cannot guarantee that they will do so.
- The use of these technologies allows our third-party vendors to deliver advertisements about our products and Services, and the products and services of third parties, when you use the Service or other applications or visit websites or web Services across the Internet. These vendors may place so-called “pixel tags,” “web beacons,” “clear GIFs” or similar technologies on the device through which you access the Service, and other applications or websites across the Internet, and also place or recognize third-party cookies when you use the Service, or other applications, websites or web Services. These vendors may use information about your visits to the Service, and other applications, websites or web Services (excluding your name, address, email address and telephone number) to provide advertisements for us and others about goods and services that may be of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit the Network Advertising Initiative at www.networkadvertising.org or the Digital Advertising Alliance at www.aboutads.info.
- By aggregating information: We may aggregate Personal Information so that the end-product does not personally identify you or any other user of the Service.
We may collect and/or use the Personal Information and/or Other Data as follows:
- To provide the Services you requested, fulfill your orders and requests (e.g. send newsletters or information about our products and Services) and for our own research and analysis to operate, troubleshoot, improve on, and deliver the Services and products that we deliver, as well as develop new services and products.
- We may share the aggregated non-personal information (Other Data) with third parties outside of Validity. Though, when we use third parties to assist us in the processing of your Personal Information, we require that they comply with our Privacy Policies, confidentiality and security measures.
- We may share information with third parties in limited circumstances when complying with legal process, preventing suspected fraud or imminent harm, and ensuring the security of our network and Services.
- We may use your postal and electronic address and selected credentials to send you items and/or information relevant to your use of our Services.
- We may conduct member and/or user surveys in order to improve our Services.
- As we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, or that of you or others; or (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Do not send us or disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise to us.
CHOICE AND ACCESS:
We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from receiving any of the following from us and our affiliates on an on-going basis:
- Receiving marketing-related emails;
- Receiving marketing-related SMS text messages;
- Subscribing to any email lists you are currently on; and/or
- Our sharing of your Personal Information with unaffiliated third parties for their marketing purposes.
At any time you would like to opt out of any of each case, please send a written request by physical mail or email to the following addresses, making clear in your correspondence what you are opting-out from:
- Written correspondence:
Attn: Legal Department
200 Clarendon Street
Boston, MA 02116
- Email: email@example.com
We will comply with your request(s) as soon as reasonably practicable.
Please note that, if you opt-out as described above, we will not be able to remove your Personal Information from the databases of unaffiliated third parties with which we have already shared your Personal Information as of the date that we implement your opt-out request. Please also note that, if you do opt-out from receiving marketing-related messages from us, we may still send administrative messages to you as well retain any communications you have sent us in order to process your requests an improve the quality of our Services.
Confirm OPT-IN: We provide confirm opt-in opportunities for any email list(s) that you choose to receive. We use your email address to confirm your subscription and validity of the provided email address. Your reply to this email is necessary for completing your subscription to any Validity email list or newsletter.
How you can access, change or suppress your Personal Information: If you would like to review, correct, update, suppress, delete or otherwise limit our use of your Personal Information that you have previously provided to us, you may contact us by emailing us at firstname.lastname@example.org.
In your request, please make clear what Personal Information you would like to have changed and what limitations (if any) you would like to place on our use of your Personal Information. We will comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records which will not be removed. We are not responsible for changing, removing or suppressing information from the databases of unaffiliated third parties with which we have already shared your Personal Information. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
SECURITY MANAGEMENT AND DATA SECURITY:
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Notwithstanding, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and be careful about the information you share in public areas that may be viewed by other users of the Services. We restrict access of personal data to authorized personnel of Validity, employees, contractors and agents who need to know that information in order to operate, innovate, and deliver our Services. Personal Information will only be disclosed to those partners of Validity for the purpose of administering our Services in accordance with the uses as outlined herein.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, We cannot guarantee the security of your personal information transmitted to our Services. Any transmission of Personal Information and Other Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures in connection with the Services.
YOUR CALIFORNIA PRIVACY RIGHTS:
California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to or write us at the addresses listed in the “Contact Us” section. Please notate in the subject line “Request for California Privacy Information.” We will provide the requested information to you at your e-mail address in response. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.
CHILDREN PRIVACY RIGHTS:
Our Services are not intended for children under thirteen (13) years of age. No one under age 13 may provide any information to or via the Services. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information via the Services or on or through any of its features/register on the Services, make any purchases through the Services, use any of the interactive or public comment features of the Servicess, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use]. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact Us at the addresses listed in the “Contact Us” section with “COPPA” in the subject line.
Parents may want to consider commercially available parental control protections to limit what minors can access online and/or monitor their minor children’s online activities. Examples include: www.netnanny.com; www.webwatcher.com and www.sentrypc.com. We do not endorse these or other services and are not responsible for them.
If you have any questions about this privacy statement, the practices of or your dealings with this web site, please contact us at:
- Written correspondence:
Attn: Legal Department
200 Clarendon Street
Boston, MA 02116
- Email: email@example.com