Version Date: 9/27/18
COLLECTION, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Users of the Platform Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person.
We analyze Non-Personally-Identifying Information gathered from users of the Platform to help us better understand how the Platform is being used. By identifying patterns and trends in usage, we are able to better design the Platform to improve users’ experiences, both in terms of content and ease of use. From time to time, we may also release aggregated Non-Personally-Identifying Information such as by publishing a report on trends in the usage of the Platform.
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows Platform operators to check whether a user has viewed a particular web page or an email. We may use Web Beacons on the Platform and in emails to count users and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information.
We may use third-party vendors to provide analytics services, inform, optimize, and serve ads based on your past activity on our Platforms and applications, including Google Analytics for Display Advertising. These vendors may use Web Cookies, Web Beacons and other technologies to collect information about your use of the Platform. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our service and other Platforms and better understand your online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network. You can do so by using Google’s Ads Settings (www.google.com/settings/ads).
If you use a mobile device to access our Platform or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system and version information, and IP address. We send you push notifications if you choose to receive them letting you know when someone has sent you a message, or for other service-related matters. You can opt-out from receiving these types of communications by turning them off at the device level. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. We do not link the information we store within the analytics software to any Personally-Identifying Information you submit within the mobile application.
Third Party Advertisers
We may use third-party advertising companies to serve ads when you visit the Platform. These companies may use information (not including any Personally-Identifying Information) about your visits to this and other Platforms. We do not identify you to the advertiser. Opt out information is available at http://networkadvertising.org/managing/opt_out.asp.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves when (1) registering for and using our service, (2) participating in polls, surveys or other features of our service, or responding to offers or advertisements, (3) communicating with us, (4) creating a profile, or (5) signing up to receive newsletters. That information may include your name, address, email address, and telephone number, and, if you transact business with us, financial information such as credit card number, type, expiration date or other financial information. We also may request information about your interests and activities, gender, age, birthday, username, hometown and other demographic information, and information we consider relevant. You are under no obligation to provide us with Personally-Identifying Information of any kind, but be aware that your refusal to do so may prevent you from using certain Platform features.
BY REGISTERING WITH OR USING THE PLATFORM, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS SECTION.
We may provide areas on our Platform where you can post reviews and other information relating to your activities on the Platform. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.
We may share or disclose Personally-Identifying Information as follows:
- With such third party vendors as we deem necessary for facilitating the provision of services by these third party vendors to you.
- With our authorized service providers that perform certain services on our behalf, such as fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, performing translation, proofreading, patent filing, and related services, supporting our Platform functionality, and processing credit card payments.
- Emails from us to you about products and services that we believe may be of interest. You can opt out by using the unsubscribe link or contacting us.
Changing Personally-Identifying Information; Account Termination
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law.
COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
GENERAL DATA PROTECTION REGULATION (GDPR)
We will comply with all applicable data protection and privacy laws & regulations in the performance of our obligations under the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998 (“Data Protection Laws”).
EU-U.S. PRIVACY SHIELD
The Platform has security measures in place to protect the loss, misuse, and alteration of the information under our control. However, even the best security measures cannot fully eliminate all risks. We are not responsible for third party circumvention of any privacy settings or security measures.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year.
DO NOT TRACK POLICY
Our Platform does not respond to “Do Not Track” signals or mechanisms.
Sun IP LLC
3000 Marcus Ave, Suite 1E6
Lake Success, NY 11042