Online Privacy Statement
Effective Date: January 1, 2016
This policy applies to information we collect:
- On this Website; and
- From electronic messages between you and this Website.
It does not apply to information collected by:
- Us, if you are a client;
- Us, offline or through any other means; or
- Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Website.
Children Under 13
We do not knowingly invite children under 13 to visit this Website and we do not knowingly collect personal information from children under 13. For more information about the Children’s Online Privacy Protection Act or COPPA, please visit the U.S. Federal Trade Commission website at www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online.
Information We Collect About You and How We Collect It
We collect several types of information from and about visitors to our Website, including information:
- by which you may be personally identified, such as name, postal address, e-mail address and telephone number (“personal information”); and
- that is about you, but individually does not identify you, such as your actions while browsing this Website, your Internet connection and the software and equipment you use to access our Website.
We collect this information:
- Directly from you when you provide it to us, i.e., through your completion of our “Contact Us” form; and
- Automatically, as you navigate through the Website.
We do not require that you register or otherwise provide us with personal information to visit this Website. You may choose to provide us with personal information when you complete the “Contact Us” form on our Website. [We may also retain records and copies of your correspondence (including email addresses), if you use the “Contact Us” form on this Website.]
As you navigate through and interact with our Website, the third party service providers we have retained to view and analyze the traffic to our Website may use automatic data collection technologies to collect information that does not personally identify you, such as:
- Details of your visits to our Website, which may include your Internet Protocol address, the domain from which you access the Internet, the date, time and duration of your visit to the Website, the specific pages, links and forms you access during your visit, the resources that you access and use on the Website, and whether you are a new or a returning visitor to this Website;
- Information about your Internet connection, the type of device you use to visit the Website and your operating system and browser type; and
- The website (such as www.google.com or www.bing.com) or referral source (such as an advertisement or social media site) that directed you to this Website.
We use the automatic data collection technology provided by our Website analytics system to gather and automatically provide the above listed information. The Website analytics system immediately aggregates the information. Moreover, we have implemented various features of Website analytics to avoid collecting personal information about you. Neither the Web hosting company nor we have access to the specifics of your particular visit to our Website. Both the web hosting company and we may see the aggregated data from all visitors for a particular time period.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to visitors and to improve visitor experience with this Website over time;
- To provide you with the information that you request from us;
- In any other way we may describe when you provide us with personal information; and
- For any other purpose with your consent.
Disclosure of Your Information
We may disclose aggregated information about all visitors to our Website, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates;
- To contractors, service providers, and other third parties we use to support our business;
- To fulfill the purpose for which you provide it;
- For any other purpose disclosed by us when you provide the information to us; and
- With your consent.
We may also disclose personal information:
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about visitors to our Website is among the assets transferred;
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- If we believe that disclosure is necessary or appropriate to protect our rights, property, or safety of our employees, our clients, or others.
Retention of Your Information
We only retain the data from the Website Analytics and our other third party service providers only as long as necessary to complete the purpose for which the information was collected, or as required by law and our record retention policies.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us.
We have implemented administrative, physical and technical safeguards designed to reduce the risk of accidental loss or unauthorized access, use, alteration, and disclosure of personal information in our possession or under our control.