1. Collection: Information We Receive
We receive information concerning individuals such as you from a variety of sources. We receive information from people who visit the Site. We also receive information from certain social media sites (e.g., Facebook, Twitter, YouTube, and FourSquare) used by us when we incorporate a Shoutlet Application into those sites and the visitors voluntarily populate screens associated with that Shoutlet Application. For example, we can deploy Shoutlet Applications to collect information from individual users about their product preferences or other matters. The Shoutlet Applications can be in the form of a website-based contest, survey, poll, or other information-gathering tool.
Either on the Site or through a Shoutlet Application deployed by us elsewhere, you may voluntarily provide to us your name, address, telephone number, email address, or other types of personally identifiable information (collectively, “Personally Identifiable Information”) or other information. We may also receive other information that you voluntarily provide, such as your age, gender, education, and occupation. This information may be gathered through the Site or through a Shoutlet Application when you, for example, register for an account, post information on the Site, or enter a promotion, sweepstakes, survey, or contest created by us. In all cases, you control the initial release and have the option of providing us, either directly or through a social media site, with the Personally Identifiable Information or other information. If you do not want to provide Personally Identifiable Information to Shoutlet, you may choose not to.
The specific types of information we receive include the following:
Information You Provide to Us
Information about you. When you sign up for our newsletter, participate in surveys, comment on our blog, or use a Shoutlet Application deployed by us, you are likely providing us with Personally Identifiable Information or other information about you.
Content. There are many opportunities for you to provide content to the Site or through a Shoutlet Application deployed by us. In many situations, you can provide general information and your opinions, upload pictures and videos, or refer, share, or provide information to a relative, friend, or contact, whose information you provide to us.
Information We Collect from Your Computer or Internet Device
Access device and browser information. When you access the Site or use a Shoutlet Application from a computer or other Internet device, we may collect information from that device about your browser type, location of the device, operating system, and IP address, as well as which Shoutlet Application you use, the pages you visit on the Site, which site you came from, and which site you went to after using the Site.
Information We Receive from Third Parties
Social media websites. We do not own or operate the social media sites that we use that integrate Shoutlet Applications. However, whenever you provide information through a Shoutlet Application, we likely will receive information not only from you, but also from the relevant social media site, including information about actions you take and perhaps some additional information that the social media site previously collected. Most of the Shoutlet Applications are set up to collect Personally Identifiable Information and other information. When this information is collected by a Shoutlet Application, we collect the information (a) fairly, without intimidation or deception, and (b) lawfully, adhering to all relevant rules of law, whether derived from statute or common law, relating to collection of personal information.
Information from other websites. We may obtain information from partners and other websites that share information with us. For example, we may ask others to tell us additional information about you or how you responded to ads or offers.
Information from other users. We may receive information about you from our customers or other users. This information may include Personally Identifiable Information, such as your name and email address and may include other information, such as your connections with others or exchanges of information between you and another user.
2. Quality, Use, Disclosure, Retention, and Disposal: How We Can Use and Share Your Information
We consider information that is not Personally Identifiable Information, such as answers to surveys, comments, ideas, and suggestions that do not include your Personally Identifiable Information, to be non-personal, and except as otherwise provided by contract, we are free to disclose and use such data or information without any obligation to you.
Associate You with Your Account
We may use the information that you provide us in an effort to identify and associate you with your account or to otherwise verify your identity.
Aggregate and Statistical Data
We use Aggregate and Statistical Data in the aggregate and on an individual basis to enable us and our customers to better understand the Site and our tools and services-related activity. We use it to track general information about you. We also use the Aggregate and Statistical Data to enable us and our customers to monitor their social media efforts with customizable report options that track user communications, who sees it, and where it is shared. The Aggregate and Statistical Data also allows us to (a) better troubleshoot and resolve issues, (b) provide technical support assistance, and (c) improve the Site and our offerings by enabling us to better understand which areas of the Site and Shoutlet Applications our users prefer, based on visits and usage. When we use Aggregate and Statistical Data, we do not link it to your Personally Identifiable Information. We use the Aggregate and Statistical Data we collect and share it with selected affiliates and customers in analyzing trends, the demographics of the users, and usage of the Site and Shoutlet Applications. We may use Aggregate and Statistical Data to improve our marketing and promotional efforts, to statistically analyze Site and Shoutlet Application usage, and to improve our content and product and service offerings.
Point of Collection Purposes
Sometimes, we have specific purposes for which we plan to use your information and we describe those purposes at the point of collecting your information. For example, we may solicit your feedback in order to improve the Site or our services and products, respond to your questions or comments, register you in connection with a contest, giveaway, or drawing, respond to a request for a brochure, or to otherwise send information to you.
Vendor Services to Shoutlet
We may share your Personally Identifiable Information and other information with our vendors, contractors, and partners in connection with services that these individuals or entities perform for or with us and our customers. These vendors, contractors, and partners are restricted from using this information in any way other than to provide services for us, and they may not share or resell that data. The services they provide may include such activities as direct mailing, fulfillment services, and email campaigns.
Acquiror of Shoutlet
We may disclose your Personally Identifiable Information and other information in connection with an anticipated merger, acquisition, or sale of all or substantially all of our assets or the Site’s assets or services.
Disclosure and Use for Legal Reasons
Respond to Requests You Initiate
We may disclose and use Personally Identifiable Information and other information about you in order to respond to an inquiry, request, or complaint that you have made or to provide you with additional information, alerts, and updates regarding our services and products.
Deletion of Personally Identifiable Information
At your request, we will delete from our active databases your Personally Identifiable Information collected by us through the Site or a Shoutlet Application deployed by us. We may retain such information to the extent required by law or if copies are kept in archival backups, but in no event will we use or disclose such information except as required by law. To request the removal of Personally Identifiable Information, please send us an email at email@example.com. See “Your Access to and Correction of Your Personally Identifiable Information” below for additional information as to correction of your Personally Identifiable Information.
3. Choice and Consent
In accessing the Site or using a Shoutlet Application we deploy, you do not have to provide to us your Personally Identifiable Information. We enable you the opportunity to choose (opt out) by contacting us whether your Personally Identifiable Information can be (a) disclosed to a non-agent third party, or (b) used for purposes other than the purposes for which it was originally collected or subsequently authorized to be used by you.
4. Access, Security, and Other Important Matters Related to Your Privacy
Your Access to and Correction of Your Personally Identifiable Information
Protection of Children’s Personally Identifiable Information
We do not intend to collect Personally Identifiable Information from anyone under age 13 and will not knowingly collect, maintain, or disclose such information. If you are under age 13, do not enter any Personally Identifiable Information about yourself on our Site or through a Shoutlet Application. If you are a parent or guardian who has discovered that your child under age 13 has submitted his or her Personally Identifiable Information to us without your permission or consent, we will make reasonable efforts to remove the information from our database, at your written request. To request the removal of your child’s information, please send us an email at firstname.lastname@example.org and include in your message your child’s name and the email address that your child submitted.
We have developed and implemented a security policy and program that includes administrative, technical, and physical safeguards to protect Personally Identifiable Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. In addition, we have restricted logical access to Personally Identifiable Information, and we have restricted physical access to the environment where we store that information.
Links to Other Sites
Your California Privacy Rights
We qualify for and select the alternative option. As described above under the heading, “Choice and Consent” you may opt out of our providing your personal contact information to third parties for direct marketing purposes. If you are a California resident and would like more information about our compliance with your California privacy rights, send your request to us at email@example.com.
EU Safe Harbor
We adhere to the U.S. Department of Commerce’s EU Safe Harbor Program and the Swiss Safe Harbor Program (http://export.gov/safeharbor/) (the “Safe Harbors”) of Notice (see section on “Quality, Use, Disclosure, Retention, and Disposal: How We Can Use and Share Your Information”), Choice (see section on “Choice and Consent”), Onward Transfer (see section on “Quality, Use, Disclosure, Retention, and Disposal: How We Can Use and Share Your Information”), Security (see section on “Security Program”), Data Integrity (see section on “Quality, Use, Disclosure, Retention, and Disposal: How We Can Use and Share Your Information”), Access (see section on “Your Access to and Correction of Your Personally Identifiable Information”), and Enforcement (see section on “BBB Online program: privacy complaints by European Union and Switzerland citizens”) with respect to personal information (as defined below). We will respond to your request to access or delete personal information within 30 days. We will adhere to the requirements of the Safe Harbors with respect to sensitive information (as defined below).
For purposes of the Safe Harbors notice, “personal information” means data that is (a) transferred from the European Union or Switzerland, as the case may be, to the United States; (b) recorded in any form; and (c) about, or pertains to, a specific individual who is identified in, or is identifiable from, the data. “Sensitive information” means personal information specifying medical or health conditions, personal sexuality, racial or ethnic origin, political opinions, religious, ideological, philosophical, or trade union-related beliefs, views or activities, trade union membership, information specifying the sex life of the individual, information on social security measures, or administrative or criminal proceedings and sanctions, which are treated outside pending proceedings. Sensitive information also includes personal information received from a third party where the third party treats and identifies it as sensitive.
Monitoring and Enforcement
BBB EU Safe Harbor Program: Privacy Complaints by European Union Citizens