Política de Privacidad
Last Updated: 08/06/2018
This Policy applies to all Company’s operating divisions, subsidiaries, affiliates, and branches, and any additional subsidiary, affiliate, or branch of Company that we may subsequently form.
3. TRANSPARENCY/NOTICE—Personal Information Company Collects and How We Use It
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Company and the requirements of applicable law. Some of the ways that Company may collect Personal Information include:
- You may provide Personal Information directly to Company through interacting with the Service, participating in surveys, during events such as sweepstakes, and requesting services, or information.
- As you navigate the Service, certain passive information may also be automatically collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
1. Personal Information Company Collects
Company collects Personal Information regarding its current, prospective, and former clients, customers, Users, visitors, guests, and Employees (collectively “Individuals”).
- User Provided Information . Any time you enter information into a form or other data entry field available on the Service, Company collects and stores any Personal Information you include. When you use the Service or engage in certain activities, such as registering for an account, responding to surveys, requesting our Service or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
- Communications with Us . We may collect Personal Information from you such as your name, email address, gender, physical address, telephone number, and credit card number, as well as a variety of other information that we associate with you such as information about your demographic profile and interests when you choose to request information about our Service, register for our newsletter, request to receive customer or technical support, or otherwise communicate with us.
- Surveys . From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Site and/or Service and in any manner consistent with the policies provided herein.
- Posting on the Site . Company may now or in the future permit User Submissions through publicly accessible blogs, private messages, or forums. You should be aware that, when you disclose information about yourself through User Submissions on or in Company blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit User Submissions to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
- Registration for Sweepstakes or Contests . Occasionally, Company may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt out of any communications that are not related to awarding prizes.
- Automatic Data Collection . When you visit the Site, open one of our HTML emails, our otherwise interact with our Service, we may collect certain information automatically through our Service or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, web browser type and language, geo-location information, hardware type, operating system, Internet service provider, the web pages or sites that you visit just before and just after the Service, the pages you view and links you click within the Service, the dates and times that you use the Service, the amount of time you spend on each page, and other actions taken through use of the Service such as preferences.
- Information Submitted Via Service . You agree that Company is free to use User Submissions submitted by you via the Service, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or the Service. Company will not release your name or otherwise publicize the fact that you submitted User Submissions to us unless: (a) you grant us permission to do so; (b) we first send notice to you that your User Submissions will be published or otherwise used with your name on it; or (c) we are required to do so by law.
2. The Way Company Uses Information
We acquire, hold, use, and Process Personal Information for a variety of business purposes, including those described below:
- Providing and Supporting the Service . Company may use information that we collect to provide you all of the features and services found on the Service, and to fulfill requests for the Service or information, including information about potential or future services, including to:
- Generally manage Individual information and accounts;
- Respond to your questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of the Service;
- Contact you to answer requests for customer support or technical support.
- Administrative Purposes . Company may use Personal Information about you for its administrative purposes, including to:
- Measure interest in Company’s Service;
- Develop new products and services;
- Ensure internal quality control;
- Verify Individual identity;
- Communicate about accounts and activities on Company’s Service and systems, and, in Company’s discretion, notify you of major Service updates or changes to any Company policy;
- Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities;
- Enforce our Terms.
- Marketing the Service . Company may use Personal Information such as your email address to send promotional or marketing messages relating to the Service that may be of interest, including new content or services. Company may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide the Service to you and our sponsors;
- For other purposes disclosed at the time that Individuals provide Personal Information; or
- Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
- Improving the Service . Company may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources to help us to understand usage trends and preferences, to improve the way the Service works and looks, to improve our marketing and promotional efforts, and to create new features and functionality. From time to time, Company may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Service, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
- Direct Mail, Email and Outbound Telemarketing . Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Company’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
- Anonymous and Aggregated Information Use . Aggregate data is data we collect about a group or category of features, services or Individuals, from which Individual identities have been removed. For example, information about how you use a feature may be collected and combined with information about how others use the same feature, without any Personal Information included in the resulting data. Anonymized or aggregate data may include de-identified demographic information, de-identified location information, information about the computer or device from which you access Company’s Service, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Service. Anonymized or aggregated information is not Personal Information, and Company may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Company and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Sharing Content with Friends or Colleagues . Company’s Service may offer various tools and functionalities. For example, Company may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Service. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Company or any other Third Parties for any other purpose.
- Other Uses . Company may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3. Automatically Collected Information and Interest-Based Advertising
- Cookies . When you use the Service, we may send one or more cookies—small text files containing a string of alphanumeric characters—to your computer. Company uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. By using these cookies, we can “remember” what you have done on the Service before and personalize our site for you. These persistent types of cookies can be removed, but each web browser is a little different, so please look through your browser "Help" file to learn the correct way to modify your cookies set-up. Please note that disabling cookies may prevent you from accessing some of the functionality available via the Service.
- Pixel Tags/Web Beacons . A pixel tag (also known as a web beacon or a clear gif) is a piece of code embedded on the Site that collects information about Users’ engagement on that web page. The use of a pixel allows us to record, for example, that a User has visited a particular web page or clicked on a particular advertisement.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related . We may use first-party or Third-Party cookies and web beacons to provide custom, personalized advertisements, content, and information, on our sites or on Third-Party sites. This includes using Technologies to monitor the effectiveness of our marketing campaigns and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our Site, Service, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
4. Third-Party Websites, Social Media Platforms, and ADVERTISING
The Service may contain links to other websites and other websites may reference or link to our Service. We do not have control over the privacy or security practices and policies of Third Parties, and Company does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our Users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Company’s Service may include publicly accessible blogs, forums, or private messaging features. The Service may also contain links and interactive features with various social media platforms (e.g., buttons or widgets). If you already use these platforms, their cookies may be set on your device when using our Service. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes.
5. ADVERTISING AND SDKS
You should be aware that advertisers may target advertisements to Users based on a certain audience or audience segment. If you respond to this type of targeted advertisement, the advertiser or ad-server may conclude that you fit the description of the audience they were trying to reach.
4. Human Resources Data
Company collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of Third Parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
- Workflow management, including assigning, managing and administering projects;
- Human Resources administration and communication;
- Payroll and the provision of benefits;
- Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
- Job grading activities;
- Performance and Employee development management;
- Organizational development and succession planning;
- Benefits and personnel administration;
- Absence management;
- Helpdesk and IT support services;
- Regulatory compliance;
- Internal and/or external or governmental compliance investigations;
- Internal or external audits;
- Litigation evaluation, prosecution, and defense;
- Diversity and inclusion initiatives;
- Restructuring and relocation;
- Emergency contacts and services;
- Employee safety;
- Compliance with statutory requirements;
- Processing of Employee expenses and travel charges; and
- Acquisitions, divestitures, and integrations.
5. Onward Transfer—Company May Disclose Your Information
1. Information We Share
- We Use Vendors and Service Providers . We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services, such as hosting the Site and Service, maintenance and security; (ii) provision of information and services you have requested; (iii) customer service activities; (iv) to manage our contacts and send out promotional messages on our behalf; (v) to assist us in improving the way the Service works and looks, and to create new features; and (vi) in connection with the provision of the Site. Company has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners . Company may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Company may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Company. Company requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Company provided them.
- Public Areas . Any information that you voluntarily choose to include in a publicly (or semi-publicly) accessible area of the Service, such as a public profile page or communications you may initiate or engage in through the Service, will be available to anyone who has access to that content, including other Users. We cannot control who reads your posting and we are not responsible for privacy practices of the other Users who will view and use the posted information, so we encourage you to exercise discretion and caution with respect to your Personal Information.
- Marketing – Interest-Based Advertising and Third-Party Marketing . If you direct us to do so, we may sell or render access to User information, including contact information, to Third Parties for their use in marketing or promoting products or services that they believe you may be interested in based on your use of the Service. For example, if you express a desire to be contacted about a listing with particular features, we may provide your information to Third Parties so that they may contact you directly regarding their listings that may be similar to the one you expressed interest in. Through our Service, Company may also allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Company related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 6 below.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures) . Company may share, access, and preserve your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce Company policies or contracts; (v) to collect amounts owed to Company; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
- Aggregate Data . We may share automatically collected and aggregate data with interested Third Parties to assist them in understanding the interest and usage patterns for certain information, products, services, data, content, advertisements, promotions, and/or functionality on the Service.
2. INTERNATIONAL Data Transfers
The Service is hosted in the United States, and all or a portion of the Service may also be hosted on the “cloud”, or other similar distributed hosting platform. You agree that all Personal Information collected via or by Company may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. If you are a User accessing the Service from the European Union, Asia, or any other region, please note by providing your personal data you explicitly consent to the storage of your Personal Information in these locations.
6. Opt-Out (RIGHT TO OBJECT TO PROCESSING)
You may, of course, decline to share your Personal Information with Company, in which case Company will not be able to provide to you some or all of the features and functionality found on the Service.
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Company’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting email@example.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Site and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
To protect your privacy and security, we take reasonable steps to verify your identity before granting access to Users' profiles. YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR UNIQUE PASSWORD AND ACCOUNT INFORMATION AT ALL TIMES.
2. Email and Telephone Communications
3. Mobile devices
Company may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Company may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.
4. Human Resources Data
With regard to Personal Information that Company receives in connection with the employment relationship, Company will use such Personal Information only for employment-related purposes as more fully described above. If Company intends to use this Personal Information for any other purpose, Company will notify the Individual and provide an opportunity to opt out of such uses.
5. “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that Users can set in certain web browsers. DNT is a way for Users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6. Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp , or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here .
7. Rights of Access, Rectification, Erasure, and Restriction
Although Company makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Company is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Company determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Company will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
8. Data Retention
9. Security of Your Information
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we take steps to protect your information from unauthorized access, disclosure, alteration, or destruction, which may include use of industry standard technologies and procedures. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software. We do not accept liability for unintentional disclosure.
If Company learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Service or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. Company may post a notice on the Service if a security breach occurs. If this happens, you will need a web browser enabling you to view the Service. Company may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us via email at firstname.lastname@example.org.
10. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
11. Children’s Privacy
Our Services are not directed to children under 13. In addition, you are not permitted to use our Service if you do not meet the minimum age requirement applicable to our Service in your jurisdiction. We do not knowingly collect Personal Information from children under 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected Personal Information of a child under 13 (or under 16 in certain jurisdictions, such as EU member countries) we will take steps to delete such information from our files as soon as possible and terminate the child’s account unless we receive verifiable parental consent.
12. Redress/Compliance and Accountability
13. Other Rights and Important Information
- New Uses of Personal Information . Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Company will endeavor to comply with the law or contract.
2. California Privacy Rights
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Company or to which Company discloses Personal Information for use on its behalf.
- “Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Company or its subsidiaries worldwide.
- “Personal Information” is any information relating to an identified or identifiable natural person (“ Individual”).
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Sensitive Data” or “ Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Company or Company’s Agents.
14. Contacting the Company
211 Sutter Street, Suite 200
San Francisco, CA 94108
15. Revision history
Title (Effective Date)