Effective Date: April 2020
Last Update: July 2020
How We Collect and Use Information
We may collect and store personal or other information that you voluntarily supply to us online while using the Site (e.g., while on the Site or in responding via email to a feature provided on the Site). The Site only contacts individuals who specifically request that we do so or in the event that they have signed up to receive our messaging, attended one of our events, or have purchased one of our products. The Site collects personally identifying information from our users during online registration and online purchasing. Generally, this information includes name and e-mail address for registration or opt-in purposes and name, postal address, and credit card information when registering for our events or purchasing our products. All of this information is provided to us by you.
We also collect and store information that is generated automatically as you navigate online through the Site. For example, we may collect information about your computer's connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Site. We also may use a standard feature found in browser software called a "cookie" to enhance your experience with the Site. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Site, cookies help us deliver advertisements, identify how many unique users visit us, and track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Site where you may have entered preference information before. The Site also may use web beacons (single-pixel graphic files also known as "transparent GIFs") to access cookies and to count users who visit the Site or open HTML-formatted email messages.
Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online - for example on message boards, web logs, through email, or in chat areas - that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.
Be aware that we may occasionally release information about our visitors when release is appropriate to comply with law or to protect the rights, property or safety of users of the Site or the public.
Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets, or one or more of our websites is acquired by another company, information about our users may be among the transferred assets.
We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include:
By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Site. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The "Remarketing" feature allows us to reach people who previously visited our Site, and match the right audience with the right advertising message.
We abide by Facebook's Data Use Restrictions.
General Data Privacy Regulation (GDPR)
The GDPR took effect on May 25, 2018, and is intended to protect the data of European Union (EU) citizens.
As a company that markets its site, content, products and/or services online we do not specifically target our marketing to the EU or conduct business in or to the EU in any meaningful way. If the data that you provide to us in the course of your use of our site, content, products and/or services is governed by GDPR, we will abide by the relevant portions of the Regulation.
If you are a resident of the European Economic Area (EEA), or are accessing this site from within the EEA, you may have the right to request: access to, correction of, deletion of; portability of; and restriction or objection to processing, of your personal data, from us. This includes the "right to be forgotten."
To make any of these requests, please contact our GDPR contact: firstname.lastname@example.org
California Consumer Privacy Act (CCPA)
The CCPA took effect on January 1, 2020, and is intended to protect the personal information of California residents.
The CCPA has certain threshold requirements which a company must meet in order to be required to comply with its provisions. Upon information and belief, our company does not meet those thresholds. In the event of a change in our status, and if the data that you provide in the course of your use of our site, content, products and/or services is governed by CCPA, we will abide by the relevant portions of the Act.
If you are a resident of the state of California, you may have the right to: request disclosure of the personal information we have collected about you and the types of third parties with whom it has been shared; request a portable copy of your information; opt out from marketing messages or the sale of your information to third parties; and request deletion of your personal information.
To make these requests, please contact our CCPA contact at email@example.com
California Privacy Rights
This section contains disclosures required by the California Consumer Privacy Act ("CCPA") and applies only to "personal information" that is subject to the CCPA.
This policy applies to information we collect:
· On this Website.
· In email, text, and other electronic messages between you and this Website.
Under California Civil Code Section 1789.3, users of the Website from California are entitled to the following specific consumer rights notice: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
Personal information we collect, disclose for a business purpose, and sell
We collect the categories of personal information about California consumers identified in the chart below. In the past 12 months we have collected and disclosed California consumers' personal information to third parties for business or commercial purposes - details are set out in the chart below.
We did not sell any information collected in the past 12 months.
Disclosures of Personal Information for a Business or Commercial Purpose
|Categories of Personal Information||Examples||Collected in the last 12 months:||Categories of sources from which information is collected:||Business or commercial purposes for collection, use, and sharing:||Disclosed for business purposes to the following categories of third parties:||Sold to the following categories of third parties:|
|Personal and online identifiers||(such as first and last name, email address, or unique online identifiers, Internet Protocol Address)||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||No|
|Personal Information Categories -- as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||(A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.|
Some personal information included in this category may overlap with other categories.)
|Yes||All categories listed below.||All purposes listed below.||All categories listed below.||No|
|Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||No|
|Commercial or transactions information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||No|
|Internet or other electronic network activity information||(such as browsing history, search history, interactions with a website, email, application, or advertisement)||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||No|
|Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No||n/a||n/a||n/a||NO|
|Geolocation data.||IP||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||No|
|Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO||n/a||n/a||n/a||No|
|Professional or employment-related information||Current or past job history or performance evaluations.||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||No|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||No|
|Equipment information.||Information about your internet connection, the equipment you use to access our Website, and usage details.||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||No|
|Inferences drawn from the above information about your predicted characteristics and preferences||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||No|
Categories of sources
Global Brother SRL obtains the categories of Personal Information listed above from the following categories of sources:
· Directly from you - Personal Information that you input into our websites. For example, from:
o forms you complete, responses to surveys that we might ask you to complete for research or marketing purposes.
o products and services, you purchase through our partners Clickbank or Digistore24.
o Records and copies of your correspondence (including email addresses), if you contact us in relation to our products or services.
· Indirectly from you. For example, from observing User actions in the Google Analytics or other platforms
· Records and copies of your correspondence (including email addresses), if you contact us in relation to our products or services.
· Your responses to surveys that we might ask you to complete for research or marketing purposes.
· Your search queries on the Website
· Details of transactions you carry out through our partners (ClickBank, Digistore24 etc) and of the fulfilment of your orders.
· Affiliates in our group companies
· Consumer data resellers
· Comments or reviews you left on our website
You also may provide information to be published or displayed (hereinafter, "Posted") on public areas of the Website, including product reviews ("User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
How and Why We Use, collect and share Your Personal Information
We use the Personal Information to satisfy your requests, improve the quality of the Global Brother SRL products, engage in research and analysis relating to the Global Brother SRL offers, personalize your experience, track usage of our products, market our products, provide customer support, message you, and comply with legal obligations. Even when we do not retain such Personal Information, it still must be transmitted to our servers initially and stored long enough to process.
We also use Personal Information that we collect about you or that you provide to us, including any Personal Information used to fulfill our contractual obligations to you:
· To present our offers and the contents to you.
· To provide you with information, products, or services that you request from us.
· To satisfy any other purpose for which you provide it.
· To provide you with notices about your product or account, including expiration and renewal notices, shipping delivery notes and product updates.
· To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection.
· To notify you about changes of the products or services we offer or provide.
· In any other way we may describe when you provide the information.
· For any other purpose with your consent.
· To complete or meet the reason you provided the Personal Information, including integrated third-party products. For example, if you share your name and contact information to request a price quote or submit a query about other transactions, we will use that Personal Information to respond to your inquiry (automated or otherwise). If you provide your Personal Information to purchase a product or service, we will use that Personal Information to facilitate delivery of the product. We may also save your Personal Information to facilitate orders of additional users or Global Brother SRL or process decommissions.
· To provide, support, personalize, develop, and enhance our products and the customer experience.
· To present our partners offers or products
For commercial purposes, including marketing, advertising, and enabling commercial transactions
· To create, maintain, customize, and secure your account with us.
· To process your requests, purchases, transactions, and payments and prevent transactional fraud.
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Global Brother SRL, its customers, or others. This includes exchanging Personal Information with other companies and organizations for the purposes of fraud protection and credit risk reduction
· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
· To help maintain the safety, security, and integrity of the Global Brother SRL products and services, databases and other technology assets, and business.
· For debugging, testing, research, analysis, and product development, including to develop and improve existing products or create new products.
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Global Brother SRL will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
· Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services.
The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
Our Do Not Track Policy
Some browsers have a "do not track" feature that lets you tell websites that you do not want to have your online activities tracked. Currently, we do not respond to browser "do not track" signals.
Recipients of California Personal Information
We may disclose the categories of personal information listed above to the categories of third parties listed below for business purposes:
· To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. We may disclose Personal Information to a third-party manufacturer if the fulfillment of your order requires that your order be shipped directly from said third-party manufacturer to you.
· To our subsidiaries or affiliates in our group companies
· Advertising networks and consumer data resellers
· Internet service providers
· Data analytics providers
· Operating systems and platforms
· Social networks
· Government entities, if required to do so
We may share aggregated information about our users without restriction.
Your Rights Regarding Personal Information
California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
· The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you; the categories of sources from which we collected your personal information; our purposes for collecting or selling your personal information; the categories of your personal information that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
· The right to request that we delete the personal information we have collected from you or maintain about you.
· The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales.
· The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
Global Brother SRL will not sell your personal information. California law requires that we maintain a separate webpage that allows you to opt out of the sale of your personal information. Please read below for more details.
To exercise any of the above rights, please contact us as follows:
· Send us an email firstname.lastname@example.org
· On our website by clicking on the "Do Not Sell My Info" link here.
· Visiting our contact form.
Verification Process and Authorized Agents
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. At a minimum you will need to provide your name and email address.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may designate an authorized agent to make a CCPA request on your behalf by informing our customer service team email@example.com. You will need to provide your name and address, your agent's name and address, and a copy of the document by which you appointed the agent.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing using email.
We will deliver our written response by email.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
We will not discriminate against you for exercising any Personal Information rights. Unless permitted by applicable regulations, we will not:
· Deny you goods or services.
· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
· Provide you a different level or quality of goods or services.
· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Children's Privacy Statement
This children's privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen, and provides important information regarding their rights under federal law with respect to such information.
How do we store your information?
Your information is stored at the list server that delivers the Site content and messaging. Your information can only be accessed by those who help manage those lists in order to deliver e-mail to those who would like to receive the Site material.
All of the messaging or emails that are sent to you by the Site include an unsubscribe link in them. You can remove yourself at any time from our mailing list by clicking on the unsubscribe link that can be found in every communication that we send you.
This policy may be changed at any time at our discretion. If we should update this policy, we will post the updates to this page on our Website.
California residents are entitled to make certain requests in regards to their personal information - Do not sell my info
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