Effective: August 22, 2018
How We Use Information. We use collected information to make available and to improve our high standard of reliable services. We use such information to:
- respond to inquiries and monitor such responses;
- provide information about and market our products or services and third party services;
- analyze visitors’ access to and use of the Site and the Services;
- resolve problems; and
- improve and manage the Site and the Services.
If you have any questions regarding the foregoing, or our privacy practices, you may contact: [email protected]
Disclosure of Information. We do not sell or rent personally identifiable information to third parties who are not affiliates of the Company, except as described here. We may disclose personally identifiable information to appropriate affiliates of the Company, including strategic alliance affiliates and third party service providers, to respond to a request for service or to provide information about available products or services, including third party services and products. We are not limited in our use of non-personal information that does not permit direct association with any specific individual, or non-identifiable aggregate information about our users (such as the number of users of our services, the geographic distribution of our users, the amount of information located and/or removed, etc.). We disclose information that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activity. We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. We may disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you). We share information with companies that provide public relations and marketing services for us. As with any other business, it is possible that in the future we could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by us, including customer account information, but would continue to be bound by this Policy unless and until it is amended. We share your information with our parent, subsidiaries and joint ventures to help coordinate any service we provide to you, enforce our terms and conditions, and promote trust and safety. We may share aggregate (non-personally identifiable) information with certain third parties such as advertisers, national industry organizations, and prospective affiliates.
Choice and Opt-Out. We provide you the opportunity to “opt-out” of having your personally identifiable information used for certain purposes when we ask for this information. For example, if you do not wish to receive marketing material from us, you can indicate your preference by clicking a link to unsubscribe contained in such communications. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each communication.
General Data Protection Regulation (“GDPR”) Compliance. The Company’s Site and Services are operated in the United States. If you are a resident of or are located in the European Economic Area (“EEA”), you may also have certain rights under the GDPR regarding the use and transfer of your personal data. If you are located in the EEA or elsewhere outside the United States, any information that you provide, including your personal information, to the Company in connection with your use of the Site or the Services will be transferred to the United States. We may also transfer your personal information to third parties acting on our behalf for the purposes of data processing, storage, maintenance and improvements to the Site and Services. By providing any information to us, you consent to the transfer, processing and storage of such information in the United States. In general, under the GDPR, you may:
• request access to your personal data;
• have incomplete or incorrect data corrected;
• have your personal data deleted;
• suspend or restrict our use of your personal data, or withdraw your consent for us to use your personal data; and
• request a copy of your personal data.
Should you request a copy of your personal data, we will supply you with the first copy free of charge, but additional copies may be subject to a reasonable fee. Should you request the deletion of your personal data, we will take commercially reasonable steps to do so as soon as practicable, although your right to have your personal data deleted is subject to exceptions, such as, for example, compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
Data Security. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security. In the event of an inadvertent disclosure of your personal information we will take commercially reasonable steps to limit and remedy the disclosure as required by applicable law. If you have any questions about the security of our Site and the Services, you can contact us via email at [email protected]
Data Retention. We will retain personal information about you for the period necessary to perform the Services for you and for the purposes outlined in this Policy, unless a longer retention period is required by law and/or regulations. Notwithstanding this, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person.
Age Limitation. This Site and the Services are not directed to person under the age of 18. If you become aware that your child has provided us with personal information without your consent, please contact us at [email protected] We do not knowingly collect or solicit information from, market to or accept services from persons under 18 years old. If we become aware that a person under 18 has provided us with personal information, we take steps to remove such information.
Governing Law. This Policy is governed by the laws of the Commonwealth of Massachusetts, U.S.A. without giving effect to any principles of conflict of law.
Your California Privacy Rights. California Civil Code Section 1798.83 permits customers who are California residents and who have provided the Company with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this issue, please contact us at [email protected] or at Robert Calise & Associates, LLC, 31 St. James Avenue, 6th Floor, Boston, MA 02116.