MEISTERLABS – PRIVACY NOTICE
Last Updated: November 2023
This Privacy Notice explains how MeisterLabs, Inc. (“Meister”, “we,” “us” or “our”) collects, uses, discloses, and otherwise processes personal data in connection with our websites (the “sites”), our community platform (the “platform”) and our other services and web and mobile applications that link to this Privacy Notice (collectively, with the sites and the platform, the “services”).
We may provide additional or supplemental privacy policies to individuals for specific promotions, products, or services that we offer, at the time that we collect any additional personal data. These supplemental privacy policies will govern how we may process the information in the context of the specific promotion, product, or service.
What is Personal Data?
When we use the term “personal data” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a person or household. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to a person.
Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (or the why and the how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to contractual restrictions.
As part of our business relationship with our customers we are often asked to receive, gather, store, analyze, or otherwise process information, which may include personal data, on behalf of our customers. We refer to this type of information and personal data as “customer data.” When we process customer data, we generally act as a processor. This means we process customer data on behalf of our customers subject to restrictions set forth in our contracts with them.
This Privacy Notice does not cover or address how we or our customers process customer data in connection with our role as our customers’ processor. Instead, this Privacy Notice only covers our processing of personal data in our capacity as a controller. In addition, we are generally not permitted to respond to individual requests relating to customer data. As a result, we recommend referring to the privacy notice of the business with which you have a relationship for information on how they engage processors, like us, to process customer data on their behalf.
1. OUR COLLECTION OF PERSONAL DATA
We collect personal data directly from individuals or when they interact with us through our services. We also collect personal data automatically when an individual interacts with our services. At times, we may also collect personal data about an individual from other sources and third parties, even before our first direct interaction with that individual.
Personal Data Provided By Individuals
We collect the following categories of personal data individuals provide to us in connection with our services:
- Contact Information, including first and last name, email address, phone number, and communication preferences. We use this information to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences. We also use contact information to send our newsletters to individuals who sign up for them.
- Account Information, including first and last name, email address, user ID and password, profile information, affiliations, job title, account balances, payment and purchase history information, and any other information individuals provide to us. We use this information to primarily administer an individual’s account, provide individuals with the relevant service and information, communicate with individuals regarding their account and their use of the services, and for customer support purposes.
- User Content, including user-created projects, tasks, mindmaps, comments and notes in combination with profile information (name, username, e-mail address, avatar). Tasks, mindmaps and notes may contain comments, uploaded files (e.g., text files, videos, images) and may be published publicly. If a user participates in our community forum, we also collect any information published. We use this information primarily to provide individuals with relevant services and allow individuals to interact with our services and platform.
- Webinar and Demo Information. If individuals register for a webinar or demo, we collect information from individuals such as name, email address, username, job title, organization, phone number, region/country, IP address, preferred language, attendance, comments posted during the webinar or demo, and any other information an individual provides to us. We use this information to primarily administer and facilitate the services, to conduct market research, to inform our marketing and advertising activities, to improve and grow our business, and to facilitate the related webinar or demo.
- Feedback Information. We may also collect feedback, survey responses, and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, to inform our marketing and advertising activities, and to improve and grow our business.
- Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.
- Inquiry and Communications Information, including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users, and to manage and grow our organization.
If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.
Personal Data Automatically Collected
As is true of many digital platforms, we collect certain data automatically when individuals use our services or otherwise interact with us:
- Log Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our services, and any errors that may occur during the visit to our services). Log data may overlap with the other categories of data below.
- Analytics Data, Including the electronic path taken to our services, through our services and when exiting our services, as well as usage and activity on our services, such as the links and content individuals view or engage with, platform features used, and people or accounts interacted with.
- Location Data, such as general geographic location that we or our third-party providers may derive from your IP address.
Personal Data from Third Parties and Other Sources
We also obtain personal data from other sources, which we often combine with personal data we collect either automatically or directly from an individual.
We may receive the same categories of personal data as described above from the following sources and third parties:
- Our Affiliates: We may receive personal data from other companies and brands owned or controlled by Meister, and other companies owned by or under common ownership with Meister.
- Your Employer / Company: If you interact with our services through your employer or company, we may receive your information from your employer or company, including another representative of your employer or company. We use this information to operate, maintain, and provide to you the features and functionality of the services.
- Other Users or Individuals who Interact with our Services: We may receive your information from other users or other individuals who interact with our services. For example, if you engage in one of our communications hosted on third-party platforms, we will be able to see any public communications made within that platform.
- Social Media: When an individual interacts with our services through various social media networks, such as when someone follows us or shares our content on social networks, we may receive some information about that individual that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, name, external user ID, avatar URL, access tokens, profile picture, username, and any other information the individual permits the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to primarily operate, maintain, and provide to you the features and functionality of the services, as well as to communicate directly with you, such as to send you messages about products and services that may be of interest to you.
- Advertisers and Publishers: We engage in advertising both on our platform and through third-party services. Advertisers and publishers may share personal data with us in connection with our advertising efforts. For example, we may obtain information about whether an advertisement on our platform led to a successful engagement between an individual and a third-party advertiser.
- Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal data and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your account. We may use this information to administer and facilitate our services, your account, and our marketing activities.
- Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services on our services. We may use this information to administer and facilitate our services, your account, and our marketing activities.
- Single Sign-On: We allow users to sign into our services through certain third-party accounts the user maintains. When you use single sign-on services to access our services, we do not receive your login credentials for the relevant third-party service. Instead, we receive tokens from the single sign-on service to help identify you in our system (such as by your username) and confirms you successfully authenticated with the single sign-on services. This information allows us to more easily provide access to our services.
- Other Sources: We may also collect personal data about individuals through other sources, such as publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.
2. OUR USE OF PERSONAL DATA
We use personal data we collect to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations or, to deliver the services individuals have requested and to process transactions;
- Manage our organization and its day-to-day operations;
- Communicate with you including via email, in-app messaging, social media, and/or telephone calls;
- Request individuals to provide us feedback about our service offerings;
- Address inquiries or complaints made by or about an individual in connection with our services;
- Create and maintain accounts for our users;
- Verify an individual’s identity and entitlement to our products or services;
- Register individuals for and provide them access to events, sweepstakes, surveys, and webinars;
- Request individuals to complete surveys about our organization, organizations we partner with, and our services;
- Market our services to individuals;
- Administer, improve and personalize our services, including by recognizing an individual and remembering their information when they return to our services;
- Develop, operate, improve, maintain, protect, and provide the features and functionality of our services;
- Process payment for our services;
- Facilitate customer benefits and services, including customer support through Zendesk;
- Identify and analyze how individuals use our services;
- Conduct research and analytics on our customer and user base and our services, including to better understand the demographics of our users;
- Test, enhance, update and monitor the services, or diagnose or fix technology problems;
- Help maintain and enhance the safety, security and integrity of our property and services, technology assets, and business;
- Defend, protect or enforce our rights or applicable contracts and agreement (including our Terms of Service);
- Detect, prevent, investigate, or provide notice of malicious, deceptive, fraudulent, unlawful, or criminal activity;
- Facilitate business transactions and reorganizations impacting the structure of our business; and
- Comply with legal obligations.
Additional Limits on Use of Google Information
Our services use certain Google services, including allowing users to log in using their Google account.. Users can connect their Google account using OAuth authentication, a secure mechanism to give Meister access to their Google account data without letting it know a user’s password. Notwithstanding anything else in this Privacy Notice to the contrary, if a user provides Meister access to their Google account data, Meister’s use of that Google account data will be subject to the following additional restrictions:
- The services will only use access to read, write, modify, or control email messages, metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails.
- The services will not transfer this Google data to others unless doing so is necessary (i) to provide and improve the features of the Services we provide to you, (ii) to comply with applicable law, or (iii) as part of a merger, acquisition, or sale of assets.
- We will not use or share this Google data for serving advertising, including retargeting, personalized, or interest-based advertising.
- We will not allow humans to read this data unless:
- we have your affirmative agreement for specific messages,
- doing so is necessary for security purposes (such as investigating a bug or abuse),
- it is necessary to comply with applicable law,
- the data has been aggregated and anonymized and is used only for our own internal operations purposes.
Our services’ use of information received, and the services’ transfer of information to any other app, from Google APIs will adhere to Google’s Limited Use Requirements.
3. OUR DISCLOSURE OF PERSONAL DATA
We disclose personal data in the following ways:
- Our Affiliates: We may share personal data with other companies owned or controlled by Meister, and other companies owned by or under common ownership as Meister, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries they own, particularly when we collaborate in providing the services.
- Your Employer / Company: If you interact with our services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
- Marketing Providers: We coordinate and share personal data with our marketing providers in order to communicate with individuals about the services we make available.
- Customer Service and Communication Providers: We share personal data with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- Service Providers: We engage third parties that perform certain functions on our behalf in connection with the uses of personal data described in the sections above. Our service providers may process personal data on our behalf or have access to personal data while performing functions on our behalf.
- Survey Providers: We share personal data with third parties who assist us in delivering our survey offerings and processing the responses.
- Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see our Cookie Notice for more information.
- Business Partners: From time to time, we may share personal data with our business partners, or we may allow our business partners to collect personal data. Our business partners may use personal data for their own business and commercial purposes, including to send individuals information about their products or services that may be of interest to such individuals.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal data to a third party during negotiation of, in connection with, or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect the rights and property of us, our agents, customers and others, including to enforce our agreements, policies, and Terms of Service;
- to detect, suppress, or prevent fraud;
- to reduce credit risk and collect debts owed to us;
- to protect the health and safety of us, our customers or any person; or
- as otherwise required by applicable law.
- Otherwise with Consent or Direction: We may disclose personal data about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction, we may post their testimonial on our services.
4. COOKIES AND RELATED TECHNOLOGIES
We and our third-party partners and providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect certain personal data when an individual visits or interacts with our platform and other services. For more information on cookies and any choices individuals have regarding cookies, please see our Cookie Notice.
5. CHOICES AND CONTROLS OVER PERSONAL DATA
Individuals may control how their personal data is used or shared in the following ways:
- Modify and Delete Information. If an individual has an account with us, they may update their account information and adjust their account settings by logging into their account.
- Email Preferences. An individual can stop receiving promotional email communications from us at any time by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. Individuals may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the service, technical and security notices).
- Phone Calls. We may use personal data we collect to communicate with individuals via telephone calls, including (with your consent) to market to you or offer you information and updates on products or services we think you may be interested in. For more information, please see our Terms of Service.
- Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.
- Cookies. Please refer to our Cookie Notice to learn more about the choices individuals have when it comes to cookies and related technologies.
- Online Advertising and Tracking. Please refer to our Cookie Notice to learn more about how we work with third-party partners to collect data through tracking technologies for a variety of purposes, including analytics and advertising, and to understand the choices when it comes to these technologies.
6. CHILDREN’S PERSONAL DATA
Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.
7. LINKS TO THIRD-PARTY WEBSITES AND SERVICES
Our services may include links to third-party websites, plug-ins, applications, and other services. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal data practices of third-party websites and online services or the practices of other third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices.
8. UPDATES TO THIS PRIVACY NOTICE
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominently posting on our services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
9. CONTACT US
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to [email protected].
ADDITIONAL U.S.-STATE SPECIFIC PRIVACY DISCLOSURES
Last Updated: November 2023
1. SCOPE OF DISCLOSURES
For Nevada residents: Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at [email protected]. For all U.S. residents: If you are a resident of certain states in the United States, these additional U.S.-State Specific Privacy Disclosures (the “U.S. Privacy Disclosures”) supplement the information contained in our Privacy Notice.
Unless otherwise expressly stated, all terms in these U.S. Privacy Disclosures have the same meaning as defined in our Privacy Notice.
2. PERSONAL DATA DISCLOSURES
We collect various categories and types of personal data from a variety of sources and for a variety of purposes. We also disclose personal data to a number of recipients. Please review the Our Collection of Personal Data, Our Use of Personal Data, and Our Disclosure of Personal Data sections of our Privacy Notice to learn more. We may sell personal data, or we may sell or share personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”).
The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):
- Account name and password;
- Credit/debit card number plus expiration date and security code (CVV);
- As described in our Privacy Notice, we use account name and password, as well as payment card information, to provide certain of our products and services.
We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.
We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
3. U.S. PRIVACY RIGHTS
Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
|The Right to Know||The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you, including:The categories of personal data collected;The categories of sources of the personal data;The purposes for which the personal data were collected;The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed;The categories of personal data sold (if any), and the categories of third parties to whom the personal data were sold; andThe categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes.|
|The Right to Access & Portability||The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.|
|The Right to Correction||The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.|
|The Right to Request Deletion||The right to request the deletion of personal data that we maintain about you, subject to certain exceptions.|
|The Right to Opt-Out of Sales||The right to direct us not to sell personal data.|
|The Right to Opt Out of Sales or Sharing for Targeted Advertising Purposes||The right to direct us not to sell or share personal data for certain targeted or cross-context behavioral advertising purposes.|
|The Right to Control Over Sensitive Information||The right to exercise control over our collection and processing of certain sensitive information.|
|The Right to Control Over Automated Decision-Making / Profiling||The right to direct us not to use automated decision-making or profiling for certain purposes.|
|The Right to Non-Discrimination||The right not to receive retaliatory or discriminatory treatment for exercising any of the rights described above.However, please note that if the exercise of the rights described above limits our ability to process personal data (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.|
In addition, the exercise of the rights described above may result in a different price, rate, or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
4. HOW TO EXERCISE THE PRIVACY RIGHTS
To Exercise the Privacy Rights
Please submit a request by:
- Emailing [email protected] with the subject line, “U.S. Data Subject Request.”
We will need to verify your identity and confirm you are a resident of a state that offers the request right(s) before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include name, email address, and state of residency. Although we try to limit the personal data collected in connection with a request to exercise any of the above rights, certain requests may require us to obtain additional personal data from you. In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.
To Exercise the Right to Opt Out of the Selling or Sharing of Personal Data for Targeted Advertising Purposes
The CCPA defines “selling” and “sharing” broadly to include not only traditional selling of data for monetary consideration, but also data sharing arrangements where the recipient can use the personal information that they receive for the recipient’s own business purposes. While we do not “sell” your Personal Information for monetary consideration, we do disclose certain Personal Information to third party ad tech companies to provide more relevant ads and content which can constitute “selling” or “sharing” under the CCPA.
We may sell or share personal data (including Identifiers, Commercial Information, Internet/Network Information, and Inferences) to certain third-party ad networks, social networks and advertising partners to deliver targeted advertising (also known as “cross-context behavioral advertising”) and personalized content to you on our services, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
The third parties to whom we sell or share personal data may use such information for their own purposes, in accordance with their own privacy statements, which may include reselling or sharing this information to additional third parties.
Please note these cookie options may be unchecked or opted out by default. In addition, this opt-out tool is device and browser specific, so you will need to change your preferences on each device and browser you use to interact with the services you are visiting.
You can also opt out of cookie-based sales by businesses that participate in the DAA’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/. In addition, you may follow the other steps set forth in our Cookie Notice to further exercise control over cookies and related technologies. Lastly, you may exercise your non-cookie-related rights by following the instructions provided at the beginning of this “How to Exercise Your Privacy Rights” section.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by emailing us at [email protected] with the subject line, “Privacy Request Appeal.”
5. CALIFORNIA-SPECIFIC PRIVACY DISCLOSURES
The following disclosures only apply to residents of the State of California:
Personal Data Collection
In the last 12 months, we may have collected the following categories of personal data:
- Identifiers, such as name, email address, telephone number, address, zip code, account username and password, or other similar identifiers.
- California Customer Records (Cal. Civ. Code § 1798.80(e)), such as credit/debit card information or other payment information.
- Protected Classification Characteristics, such as age.
- Commercial Information, such information about products or services purchased or considered and information about your use of the services.
- Internet/Network Information, such as your browsing history, log and analytics data, search history and information regarding your interaction with our services.
- Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address.
- Sensory Information, such as pictures you provide or upload in connection with the services, and the content and audio recordings of phone calls between individuals and Meister and/or individuals and our service providers, that we record where permitted by law.
- Professional/Employment Information, such as job title, department, employer, or business.
- Other Personal Data, such as information and content you upload or post to the services and other information you submit to us, including inquiry, feedback, and communication information when you contact us, and your profile information.
- Inferences, including information generated from your use of the services reflecting predictions about your interests and preferences.
For more information about our collection of personal data, the sources of personal data, and how we use this information, please see the Our Collection of Personal Data and Our Use of Personal Data sections of our Privacy Notice.
Disclosure of Personal Data
As described in the Our Disclosure of Personal Data section of our Privacy Notice, we disclose personal data with a variety of third parties for business purposes or we may sell or share your personal data to third parties for targeted advertising purposes, subject to your right to opt out of selling or sharing (see “Your Privacy Rights” above).
In the previous 12 months, we have sold or shared for targeted advertising purposes all of the categories of personal data we collect, explained above, to third parties.
We retain personal data only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.
To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.
Therefore, we retain personal data for as long as the individual continues to use our services for the purposes explained in the Our Use of Personal Data section in our Privacy Notice. When an individual discontinues the use of our services, we will retain their personal data for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices they have made, such as to receive marketing communications. In particular, we will retain call recordings, the personal data supplied when joining our services, including complaints, claims (for insurance products) and any other personal data supplied during the duration of an individual’s contract with us for the services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise or defense of legal claims.
Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.
Notice of Financial Incentives
We offer various programs, promotions and other financial incentives that may result in differences in our prices or services offered to consumers. For example:
- Discounts, coupons or other access to exclusive content, research, and insights for customers who sign up to receive our marketing emails or text messages; and
- Discounts, coupons or other benefits in connection with a contest or sweepstakes or similar promotion.
To obtain access to certain of these programs and other offerings, we may collect and retain personal data, such as name, username, userID, e-mail address, competition content (e.g. mindmap), date of participation in a sweepstake, answers/information provided to us in a survey. We have determined that the value of these programs and other incentives are reasonably related to the value of the personal data we receive and otherwise process in connection with these programs and offerings, based on our reasonable but sole determination. We estimate the value of the personal data we receive and otherwise process in connection with these programs and offerings by considering the expense we incur in collecting and processing the personal data, as well as the expenses related to facilitating the program or offering.
The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer. Participating in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions or contact us using the contact information below. Participating individuals may also opt out of receiving marketing communications by following the instructions set forth in the Choices and Controls Over Information section of our Privacy Notice.
6. UPDATES TO THESE U.S. PRIVACY DISCLOSURES
We will update these U.S. Privacy Disclosures from time to time. When we make changes to these U.S. Privacy Disclosures, we will change the “Last Updated” date at the beginning of these U.S. Privacy Disclosures. If we make material changes to these U.S. Privacy Disclosures, we will notify you by email to your registered email address, by prominently posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
7. CONTACT US
If you have any questions or requests in connection with these U.S. Privacy Disclosures or other privacy-related matters, please send an email to [email protected]