Information We Collect
When you visit the Sites, request information, publications or newsletters, or when you email or write to us or telephone us, you may provide (and we may collect) information such as your name, email address, postal mailing address, home/mobile telephone number or other personal information (hereinafter “Personal Information”) when using the Sites, such as when you register with us to receive information or subscribe to our services. Below is a brief, general description of the types of information we collect through the Sites:
When you visit our Sites, we and third parties may collect certain information by automated means, using technologies such as cookies, web server logs and web beacons. Cookies are small files that websites and email servers place and access on your computer or other Internet-connected device to uniquely identify your browser or device or to store information or settings in your device. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict, disable or delete certain cookies. You may opt-out, but please note that without certain cookies, you may not be able to use all of the features of our Sites. For example, we may use certain essential cookies that are set when you enter our Sites to assist with navigation during your visit or when you complete certain forms. Blocking these cookies or deleting them earlier than their normal expiration date will cause problems.
Automatically Collected Information
Our web servers may log information such as your device and operating system type, browser type, domain, device ID, Internet Protocol (“IP”) address and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs also may record information such as the address of the web page that referred you to our Sites and the IP address of the device you use to connect to the Internet.
In addition, our Sites may record and track user activity and access to resources. To control which web servers place and access cookies and collect information by automated means, we may place tags on our web pages called “web beacons,” which are small files that allow us to understand the actions of visitors to our Sites. We may use similar technology in email we send, which may enable the placing or accessing of cookies and also enable us to know if you received the email, if the email was opened and if you clicked on any links in the email.
In addition, we collect information you provide to us when you perform site searches, or acquire services, edit information in your profile, or communicate with us by phone, e-mail, text services or any other method.
Third Party Data Collection
Third parties may collect Personal Information about your online activities over time when you use our Sites. You may choose whether to have your information collected for that purpose but not allowing that collection may result in you may not being able to use all of the features of our Sites.
How We Use the Information We Collect
We may use the information we obtain about you when you visit the Sites for various purposes, including to:
- Verify your identity;
- Process, evaluate, and respond to your requests and inquiries;
- Create, administer, and communicate with you about our services;
- Contact you with direct marketing communications;
- Process data to enable us to provide the services;
- Contact you as necessary to enforce the Terms;
- Give you access to your user profile;
- To aggregate and remove personally identifiable aspects of such data in order to perform data analytics services provided you have given your consent or processing is allowed by law. This may include the creation of pseudonymized and anonymized data;
- Operate, evaluate, and improve our business (including developing new products and services; managing our communications; performing market research and data analytics; determining and managing the effectiveness of our advertising and marketing; analyzing and customizing our services, Sites and communications; administering our Sites; and performing accounting, auditing, billing, reconciliation, and collection activities provided you have given your consent or processing is allowed by law);
- Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
- Comply with and enforce applicable legal requirements, industry standards and our policies and terms, such as our Terms;
- To monitor site usage metrics such as total number of visitors and pages viewed;
- Provide personalization and tracking services;
- To comply with and fulfill the obligations under any commercial agreement we have with you or the entity with which you are employed or contracted.
We retain Personal Information only for so long as it is necessary or relevant to fulfill the above-mentioned purposes or comply with applicable law, resolve disputes, troubleshoot problems or assist with investigations. After it is no longer necessary for us to retain Personal Information, we dispose of it in accordance with our data retention and disposal policies.
Data Transfers/Transfers to Third Party Suppliers
We may use third party payment processing services, and your Personal Information may be disclosed to such providers in connection with payment processing.
We will only transfer such information to third parties that contractually agree to protect such data in a manner that is no less restrictive than our own standards for the protection of our own Personal Information.
Transfers Outside of Geographic Point of Collection
Transfers Required by Law
Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
If you would like to update or modify your information or preferences, you may contact us as described in the “Contact Us” section below. On certain Sites, you may be able to make these choices directly. Changes made to your profile will be effective once saved into our systems in accordance with our standard procedures for implementing user questions regarding your Personal Information.
Depending on the data protection law of your country, you may have a legal right to obtain access to Personal Information we maintain about you. In addition, if you believe the Personal Information is inaccurate, you may have the legal right to request that we correct or amend the information. To make these requests, or to object to our processing of your Personal Information or withdraw consent to such processing (rights provided by the laws of certain countries), you may contact us as described in the Contact Us section below.
Opt-Out (for third party transfers)
We disclose Personal Information to our third party partners as described in the Data Transfer section. If you wish to limit or restrict the disclosure of your Personal Information to third parties, you may opt-out of such third party disclosures by changing your preferences in your profile or sending us a notice via email. If you have previously granted an ‘opt-in’ for certain collection and use practices with respect to Personal Information, you may issue a subsequent ‘opt-out’ by changing your preferences in your profile or sending us a notice via email. Our contact information is below.
How We Respond To Do Not Track Signals
Your web browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.
How We Protect Personal Information
The security of your Personal Information is important to us, but despite our efforts, we cannot promise that our security program will always eliminate all possible security risks, and our liability is limited as set forth in the Terms.
We use commercially reasonable efforts to safeguard and protect the security of all data, inclusive of any Personal Information collected by us from you through the Sites. We maintain certain administrative, technical and physical safeguards in an effort to protect the security of the Personal Information we collect on the Sites. Personal Information and other data are stored in hosted and secured environments which utilize accepted industry standards for data security. We use commercially reasonable efforts to partner with third party service providers that meet accepted industry standards to support the collection, storage, hosting, processing and retention of data, inclusive of Personal Information.
Notwithstanding the foregoing, we cannot, however, ensure, warrant or guarantee that the information collected by us will not be accessed, disclosed, altered, or destroyed by system malfunction or circumvention of our safeguards.
It is also important for you to comply with the access controls (e.g., username/password management) and other applicable provisions of the Terms to protect against unauthorized access to your account and to the devices you use to access the Sites.
Links to Other Third Party Websites; Third Party Activity
Our Sites may provide links to other websites for your convenience and information. Those websites may be operated by companies not affiliated with us. Linked websites may have their own privacy policies, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with us, any use of those websites, or the privacy practices of those websites.
Should you have any complaints regarding the use of Personal Information by us, you may contact us at the address below.
Disputes will be governed in accordance with the Terms.
Mergers, Acquisitions & Reorganizations
- Legal Basis for Processing
- To perform our contract with you when you subscribe to our services;
- To comply with our legal obligations, including those laid down in accounting, tax and company laws;
- To pursue our or a third party’s (such as our service providers, agents or delegates) legitimate interests which do not override your interest or fundamental rights and freedoms, such as (i) mitigating business and operational risks; (ii) complying with internal policies; (iii) investigating, detecting and preventing fraud and other crime; (iv) ensuring network and information security; (v) purchasing services from third parties which support us in providing our services to you and in complying with our legal obligations; (vi) developing, improving and informing you about our services and other products and services that may be of interest to you; (vii) maintaining the relationship and otherwise interacting with you; (viii) protecting our interests, including the establishing, exercising and defending of legal rights and claims; (ix) recovering debts owed by you to us; (x) ensuring that our service providers, agents and delegates can also comply with their legal and regulatory obligations; and (xi) undertaking business analysis and market research relevant to our business. When evaluating whether legitimate interest can be relied on as a legal basis for the processing activities described above, a balancing test is carried out to ascertain whether the use of your personal information would be overridden by your interests or fundamental rights and freedoms
Our legal bases for collecting and using your Personal Information will also include in certain circumstances and subject to applicable laws, your consent; however we will make this clear to you at the time of collection of your personal data, and you will have the right to withdraw your consent at any time.
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
- Transfers Outside the EU
As an EU resident, you will, at any time, have the right to opt-out or withdraw consent to the collection or use of your data. If you withdraw consent, please be advised that it may inhibit or limit our ability to provide you with certain services and to perform certain functions.
As an EU resident, you may also request (by email utilizing the contact information below) to view and change your data preferences, security settings, and consent preferences.
Additionally, as an EU resident, you have the following rights:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to the processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You have the right to make a complaint at any time to the data protection supervisory authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact our Privacy Manager in the first instance.
California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To request a copy of this information or to opt out of these disclosures, please contact us as indicated below.
920 Cassatt Road
Berwyn, Pennsylvania 19312
LAST UPDATED May 25, 2018