Privacy Policy

This Policy was last updated on February 6, 2020.

INTRODUCTION

Logility, Inc. and Demand Management, Inc., New Generation Computing, Inc., and The Proven Method, Inc., each a subsidiary or affiliate (also referred to herein as “we,” “us,” and “our”), are committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat your personal information. This Privacy Policy (the “Policy”) will provide you with a comprehensive description of our practices regarding the collection, use, disclosure, and sale of personal information when we are acting as a data controller and of the rights you have regarding your personal information. You may obtain an accessible version of this Policy by contacting us via the methods identified in the Contact Us section at the end of this Policy.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE OR ENGAGE IN COMMUNICATIONS WITH US CONCERNING OUR PRODUCTS OR SERVICES.

WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

If you are a user in the European Union (the “EU”) or the European Economic Area (the “EEA”), for purposes of the EU General Data Protection Regulation, 2016/679 (the “GDPR”), We act as a data controller with respect to the personal information collected by us when you: (1) visit a website that displays or links to this Policy (the “Site”), (2) interact with us on our social media pages, and (3) communicate with us, including via emails and phone calls. For users in California, we act as a “business” under the California Consumer Privacy Act (the “CCPA”) with respect to this information. In these roles, we are responsible for implementing the applicable data protection principles and for safeguarding the personal information.

We also process personal information as a “processor” under the GDPR or a “service provider” under the CCPA on behalf of our customers. Questions regarding our customers’ practices should be directed to those customers. When we are acting as a data processor or a service provider, we collect and process personal information in accordance with the instructions provided by our customers.

WHAT PERSONAL INFORMATION DO WE COLLECT?

As a data controller, we collect and process the following personal information for the purposes set forth below. In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly-available sources. Please do not provide another person’s personal information to us.

Category

Types of Data and Purpose

Contact Information

When you visit the Site, register for events or programs with us, or request our products or services, we may ask you for your name, address, telephone number, email address, or other contact details in order to respond to your request or inquiry.

Business Information

When you seek products or services from us in the course of contractual or customer relationships between you, your organization, and us, we collect business contact information and other personal information in order to provide you with the services or products you have requested.

User Account Information

In order to access and use certain features of the Site, you must first complete a registration. When you create an account or register with us, we collect (a) your organization’s name, type (e.g. for-profit, non-profit, governmental), and address; (b) the name, title, e-mail address and telephone number of the individual who is the contact for your organization; (c) other demographic information (location, time zone); and (d) your organization’s industry and revenue. This information is necessary to enable us to provide you the account you have requested and to maintain the account and your profile. You may update your account information by contacting us at [email protected].

Cookies and Similar Technologies

When you visit the Site, we collect cookies and use similar technologies to enhance your experience, gather general visitor information, and track visits to the Site, all in order to provide you with a more personal and interactive experience on the Site, to improve our marketing efforts, and for usage analytics purposes (e.g. page response times, download errors, length of visit, webpages visited, etc.).

Please see our Cookie Policy, available here, for more information. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly.

Automated Information

When you visit the Site, we automatically collect information from your browser or your mobile device, which includes the date and time of your visit, your Internet Protocol (IP) address or unique device identifier, domain server, your browser type, access time, cookies, and data about which pages you visit in order to allow us to operate and provide the Site and our services. This information is used to understand how you interact with the Site and to provide you with advertising and a more personalized experience. To learn more about our collection of technical data, please see the “Cookies and Similar Technologies” section of this Policy.

Feedback / Support / Inquiries

If you provide us with feedback or contact us for support or to ask us questions, we will collect your name, address, telephone number, email address, and other information needed to respond to your feedback, or request for support, or to answer your question.

Your Communications

When you communicate with us, we may retain your communications in order to process and respond to them, as well as to improve our services. We may use your email address to communicate with you about our products and services. If at any time you would like to unsubscribe from receiving future emails, you may unsubscribe using the link at the bottom of each email.

Location Information

When you use the Site, we may collect information about your location and use of the Site, including your interaction with advertising and analytics services on the Site, in order to (a) serve you the content and functionality you request, and (b) maintain the privacy and security of the Site and services. Location information collected may include your Internet Protocol (IP) address and unique device identifier.

Email Interconnectivity

If you receive email communications from us, we may use certain tools to capture data related to if/when you open our message and if/when you click on any links or banners it contains. Other information collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page. We use this information to enhance our marketing efforts. We do not sell or distribute this information to third parties.

Mailing List

When you sign up for one of our mailing lists, we collect your contact information, including your email address.

Third Party Information

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly-available sources.

Financial and Payment Information

If you choose to purchase products or services from us through this Site, including training, we collect your first and last names, company name, country, street address, city, state, zip code, telephone number, and email address. You also will be asked to provide your bank account number, bank routing information, and other data necessary to process payments, including credit card numbers, security codes, expiration dates, and other related billing information; this information is passed directly to our payment processors and is not accessed by us. By submitting your payment card information, you expressly consent to the sharing of your information with third-party payment processers and other third-party services (including but not limited to vendors who provide fraud detection services to us and other third parties). Please note that credit card numbers and account information are not stored on our servers.

Contact Us

If you choose to contact us via the Contact Us form on the Site, we will collect your first and last names, job title, company, physical address, telephone number, email address, and the information that you choose to include in your message to us so that we can receive and respond to you request if needed. We may request that you provide additional user information relevant to the support requested. This information helps us direct your request and respond more quickly to your needs.

If you wish to contact us regarding training via the form on the Site, we will collect your first and last names; email address; telephone number, and the information that you choose to include in your message and subject line to us so that we can receive and respond to you request if needed.

Download Resources

If you wish to download a whitepaper or other resources from the Site, we will collect your first and last names and email address in order to provide you with the information you have requested.


HOW DO WE PROCESS AND USE PERSONAL INFORMATION?

We collect and use the types of personal information listed above in an effort to operate our business, to improve your experience on the Site, to provide services to you, and to communicate with you about the information you have requested. We may also use personal information to help target specific offers to you and to help us develop and improve the Site and our products and services. Additionally, we may use your personal information in the following ways:

  • To provide you with the products and services you have requested and to manage our relationship with you, including administering your account, processing payments, accounting, auditing, billing and collection, and taking other steps necessary to the performance of our business relationship with you;
  • To improve the Site’s content and functionality;
  • To personalize your experience (your information helps us to better respond to your individual needs);
  • To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs) and our products and services;
  • To respond to visitor, subscriber, and customer inquiries;
  • To determine user interests, needs, and preferences;
  • To provide notice of changes to the Site or the services and products we offer or provide;
  • To deliver products and services to you and to honor our Terms of Use
  • To comply with your instructions;
  • To conduct research and analysis;
  • To develop new products and services;
  • To manage and maintain the security of the Site and our services;
  • To market our services and products to you or to send you information about us, including our affiliates, or our products or services, or to contact you when necessary. Where legally required to do so, we will only provide you with marketing-related information after you have opted in to receive those communications, and we will provide you with the opportunity to opt-out of such communications at any time. We do not sell or distribute this information to third parties or use it for any other purpose; 
  • To send periodic emails, including information and updates pertaining to your account;
  • Pursuant to your consent;
  • In any other way we may describe when you provide the information; and
  • For any other purpose to which you have consented or for which we have a legal basis under law.

We do not use your personal information for making any automated decisions affecting or creating profiles other than as described above.

Other Processing Activities

We may process any of personal information identified in this Policy when necessary for:

  • The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for such processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.)
  • Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper protection of our business.)
  • Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us.

We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:

  • Because it is necessary to perform the services you have requested or to comply with your instructions or other contractual obligations between you and us;
  • To comply with our legal obligations as well as to keep records of our compliance processes; 
  • Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms; 
  • Because it is necessary to protect your vital interests; 
  • Because it is necessary in the public interest; or
  • Because you have expressly given us your consent to process your personal information in a particular manner.

We do not use your personal information for making any automated decisions affecting or creating profiles other than as described above.

Under the CCPA, we may use and disclose any of the personal information that we collect in order to:

  • Comply with federal, state, or local laws; 
  • Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; 
  • Cooperate with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate federal, state, or local law;
  • Exercise or defend legal claims; and 
  • Collect, use, retain, sell, or disclose consumer information that is de-identified or in the aggregate consumer information.

Is entry of personal information required?

Some pages on the Site may give you the option of providing certain of your personal information. You may choose not to provide us with any personal information, and you may still access and use much of the Site. However, you will not be able to access any portions of the Site that require your personal information.

SHARING AND DISCLOSING YOUR PERSONAL INFORMATION

Category

Disclosure Contexts

Acquisitions and Similar Transactions

We may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Site’s users is among the assets transferred.

Disclosures With Your Consent

We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent. 

Disclosures Without Your Consent

We may disclose your personal information in response to subpoenas, warrants, court orders or other legal processes, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our legal rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our Terms of Use

Service Providers 

We may share your personal information with our service providers that need access to your information to provide operational or other support services on our behalf. Among other things, service providers may help us to administer the Site; support our provision of services/products requested by you; provide technical support; send marketing, promotions and communications to you about our services/products; provide payment processing; and assist with other legitimate purposes permitted by law.

Aggregated Data

We may disclose aggregated information about our users, and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, for new product and marketing development.


HOW LONG DO WE STORE AND USE YOUR PERSONAL INFORMATION?

We will retain and use your personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements. When applicable, we store your personal data in accordance with the instructions from our data controller clients.

We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining your personal information, (3) your registration to use the Site lapses, (4) you opt-out of receiving further communications from us, or (5) you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives.

To the extent permitted by law, we may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement. When we delete personal information, it will be removed from our active servers and databases as well as the Site, but it may remain in our archives when it is not practical or possible to delete it.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, or disclosed or accessed in an unauthorized manner. We review our security procedures periodically to consider appropriate new technology and methods.

We use secure servers. We do not collect, store or save your financial information on the Site or in our servers. While our security measures seek to protect your personal information in our possession, no security system is perfect, and no data transmission over the Internet can be guaranteed to be completely secure. As a result, while we strive to protect your personal information, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you do so at your own risk. We cannot promise that your personal information will remain absolutely secure in all circumstances.

The safety and security of your personal information also depends on you. When you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone.

We also use reasonable security measures when transmitting personal information to consumers in response to requests under the California Consumer Privacy Act. We have implemented reasonable security measures to detect fraudulent identity-verification activity and to prevent the unauthorized access to or deletion of personal information.

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

RIGHTS AND CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

Please use the Contact Us details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit, or delete your personal information or if you no longer want to receive any email, postal mail, or telephone contact from us in the future, such requests may be submitted via the Contact Us details. If you are exercising a right that is the responsibility of our customers, we will direct you to contact the customer who is responsible for responding to your request.

Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link available at the bottom of our email communications or by contacting us at [email protected] and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.

Cookies. As discussed in our Cookie Policy, available here, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Site may be inaccessible or not function properly.

No Disclosure of Your Information for Third-Party Advertising. We do not share your personal information with unaffiliated third parties for promotional purposes.

No Sale of Personal Information. Under the CCPA, you have the right to direct us to stop selling your personal information to third parties and to refrain from doing so in the future. We do not sell any personal information, and we have not sold personal information during the past 12 months.

Online Tracking. We do not currently recognize browser settings or signals of tracking preferences, which may include Do Not Track instructions. Do Not Track is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to Do Not Track signals on the Site or on third-party websites or online services where we may collect information.

Accuracy and Updating Your Personal Information. Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please let us know via the Contact Us details provided at the end of this Policy. You may directly edit your account details if you have a user account for training purposes. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Preferences. If you wish to change your communication preferences or ask that we restrict how we use your personal information, please contact us using the information in the Contact Us section of this Policy. You may follow opt-out links on marketing communications sent to you.

Complaints. If you believe that your rights relating to your personal information have been violated, you may lodge a complaint with us by contacting us using the information provided in the Contact Us section of this Policy.

California Residents - CCPA Requests to Know and Delete

The CCPA gives consumers the right to request that we (1) disclose what personal information we collect, use, disclose, and sell, and (2) delete certain personal information that we have collected or maintain. You may submit these requests to us as described in the Contact Us section of this Policy.

However, by way of example, these rights do not apply where we collect or sell a consumer’s personal information if: (1) we collected that information while the consumer was outside of California, (2) no part of a sale of the consumer’s personal information occurred in California, and (3) no personal information collected while the consumer was in California is sold. In addition, de-identified information is not subject to these rights.

If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (1) treat the request as if it had been submitted in accordance with the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.

Request to Know. You have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold and the categories of third parties to whom the personal information was sold; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, or selling personal information; and (7) the categories of third parties with whom we share personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request.

Request to Delete. You have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described below, we will delete your personal information from our records and direct any service providers (as defined under applicable law) to delete your personal information from their records.

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers for exercising their rights under the CCPA.

California Shine the Light

Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at [email protected].

Nevada Residents

You may submit a verified request to us at [email protected] to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. We will respond to any such request as required by Nevada law.

EU/EEA Residents

If you are located in the EU or EEA, you have the following rights under the GDPR. All requests should be sent to the address noted in the Contact Us section of this Policy, and we will fulfill requests to the extent required by applicable law.

Right of Access. To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.

Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.

Right to Erasure. In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) the data subject has objected to the process in certain instances, (4) the personal information has been unlawfully processed, (5) the personal data have to be erased for compliance with a legal obligation; and (6) the personal data were collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases as well as the Site, but it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Restrict Processing. You have the right to restrict processing when the accuracy of the personal data is contested, the processing is unlawful and the data subject opposes erasure, we no longer need the personal data but you require it for the establishment, exercise or defense of legal claims; or the data subject has objected to processing.

Right to Object. In certain circumstances, you have the right to object to the processing of your personal information where the processing is necessary for performance of a task carried out in the public interest, for our legitimate interests, or for the legitimate interests of others. You also have the right to object where personal data are processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.

Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purposes to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.

Right to Complain. If you believe we have not processed your personal information in accordance with applicable provisions of the GDPR, we encourage you to contact us at [email protected] You also have the right to make a GDPR complaint to the relevant Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

We are located and established in the United States and, therefore, your personal information may be transferred to, stored, or processed in the United States. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the privacy and security of your personal information. By using the Site or requesting services from us, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Policy. 

When storing, hosting, or otherwise processing information (including personal data) for residents of the EU/EEA, we may send such data outside of the EU and the EEA. When we transfer information to the United States or other countries, we do so for the purposes set forth in this Policy and in accordance with applicable law. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information outside of the EU and EEA, such as your express informed consent to do so, when transfer is necessary for us to deliver services pursuant to an agreement between us and you, or when the transfer is subject to safeguards that assure the protection of your personal information, such as the European Commission’s approved standard contractual clauses.

Privacy Shield Certification

We comply with the EU.-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the EU, EEA and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles (the “Principles”). If there is any conflict between the terms of this Policy and the Principles, the Principles will govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

We are committed to subjecting all personal information received from the EU, EEA and Switzerland to the applicable Principles of the Privacy Shield Frameworks, including with respect to onward transfers of personal information. In the context of an onward transfer we have responsibility for the processing of personal information we receive under the Privacy Shield and subsequently transfer to a third party acting as an agent on our behalf. We shall remain liable under the Principles if our agent processes such personal information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

In compliance with the Principles, we commit to resolve complaints about our collection or use of your personal information. EU, EEA and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at: [email protected].

If you do not receive timely acknowledgment from us of your complaint or if we have not resolved your complaint, please contact or visit the applicable data protection authorities (DPA) or the Swiss Federal Data Protection and Information Commissioner for more information or to file a complaint. These services are provided at no cost to you. You may contact the respective authorities as follows:

EU or EEA: https://edpb.europa.eu/about-edpb/board/members_en

Swiss: https://www.edoeb.admin.ch/edoeb/en/home/data-protection/handel-und-wirtschaft/transborder-data-flows/transfer-of-data-to-the-usa.html

We also commit to cooperate with the EU DPAs and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by a panel of the DPAs or by the Commissioner with regard to data transferred from the EU or Switzerland, respectively. In certain circumstances, each Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Principles.

The Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

CHILDREN’S ONLINE PRIVACY PROTECTION ACT

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Site and services are not directed to children aged 18 or younger, nor is information knowingly collected from children under the age of 18. No one under the age of 18 may access, browse, or use the Site or provide any information to or on the Site. If you are under 18, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 18, please contact us using the contact information provided below.

For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule

THIRD-PARTY SITES

This Policy is applicable only to the Site, and it does not apply to any third-party websites.

The Site may contain links to, and media and other content from, third-party websites. These links are to external websites and third parties with which we may have no relationship. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to the Site and which are to external, third-party websites. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left this Site.

We cannot and do not (1) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your personal information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on this Site.

Any personal information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.

UPDATES AND CHANGES TO THIS POLICY

We reserve the right, at any time, to add to, change, update, or modify this Policy to reflect any changes to the way in which we treat your personal information or in response to changes in law. Should this Policy change, we will post all changes we make to this Policy on this page. If we make material changes to how we treat your personal information, we will also notify you through a notice on the home page of the Site for a reasonable period of time. Any such changes, updates, or modifications shall be effective immediately upon posting on the Site. The date on which this policy was last modified is identified at the beginning of this Policy.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your personal information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, do not access, view, or use any part of the Site.

CONTACT US

For more information, or if you have any questions or concerns regarding this Policy, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.

In Writing: 470 East Paces Ferry Road, Atlanta, GA 30305

By Telephone: 1-800-762-5207
EMEA: +44 (0) 121 629 7866 

Asia Pacific: +61 (0) 2 9911 4029

South America: +55 (11) 3568-2442

By Email: [email protected]