Rev. February 1, 2021
1. PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT
We collect personal information when you use our Services, create an account with us or submit personal information to us. Personal information means information relating to an identified or identifiable natural person such as your name, address, phone number or email address. The types of personal information that we may collect about you include, but are not limited to:
Information You Voluntarily Provide to Us on Our Services
The personal information we collect on or through our Site or services may include:
Providing personal information this way is completely voluntary. If any form which collects your personal information allows you to voluntarily provide additional information, we seek this information because we think it will help us to give you a better-quality service. You do not have to provide such information if you do not wish to do so.
Information Collected Automatically
As you navigate through and interact with our Site or Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Information You Provide to Our Affiliates and Subsidiaries
We may receive personal information about you from a company controlled by or under common control with IDEAL. We also may collect information about your use of the Services, such as your browser information, pages clicked, and time spent navigating the site. This information cannot be used to identify you. If we link this information with any personal information, we will treat such linked information as personal information.
Information Collected from Other Sources
We receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES
Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and Internet activities. We use first-party and third-party cookies for the following purposes: to make our Services function properly, to improve our Site or services, to make login to our Site or services easier (such as by remembering your User ID), to recognize you when you return to our Site, to track your interaction with the Site or services, to enhance your experience with the Site or services, to remember information you have already provided, to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Site or services. The length of time a cookie will stay on your browsing device depends on whether it is a "persistent" or "session" cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing).
We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.
Other Tracking Technologies
We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.
Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.
Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers, provide help pages relating to setting cookie preferences. Please visit your browsers help page for information related to preferences and cookies settings.
Do Not Track
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
If you do not want us to collect Location Information from your device, please delete our mobile application or disable your device’s location settings. Please note that disabling the location setting may affect certain features of the mobile application.
3. HOW WE USE YOUR INFORMATION
a) To Provide You Our Services
We will use your personal information to provide information or perform Services that you request. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable information to the third party providing the information or performing applicable Services. Your information may be available or provided to third-party service providers and contractors (such as the Site webmaster) that are contractually obligated to protect your information as disclosed in this Policy.
b) For Internal Use
We will use your personal information for the purposes of furthering our business, including analyzing your information and other uses. We may monitor how our users use our Site including without limitation search terms entered, pages visited, and documents viewed. This information may be stored with an IP address. This information is used solely for purposes of enabling us to provide you with a personalized Site experience. Aggregated forms of this data may also be used for research purposes in order to develop new products and identify future features and functions to develop for the Site.
c) To Provide You with Service-Related Communications
We will send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services.
d) To Provide Customer Support or Respond to You
We collect any information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes or issues. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
e) To Enforce Compliance with Our Terms and Agreements or Policies
f) To Ensure the Security of the Services
We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
g) To Maintain Legal and Regulatory Compliance
Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under applicable law. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.
h) To Engage in Marketing Activities
4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We may share personal information in the following circumstances:
a) Service Providers
c) Industry Partners or Sponsors
When you register or enter a promotion, sweepstakes, or contest through our Services, we may share the information you provide with authorized third-party providers (as described above in 4 a, participating sponsors, and advertising partners). Further, by entering any promotion, you are agreeing to the official rules that govern that promotion, which may require you to take certain actions, including, except where prohibited by law, allowing IDEAL and/or the sponsor(s) of the promotion to use the information in advertising or marketing associated with the promotion. Please review the relevant promotion, sweepstakes or contest rules for more information.
d) Corporation Transaction
Unless prohibited by applicable law, we may share, transfer or delete your personal information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by IDEAL or any affiliated company (in each case, whether in whole or in part). If required by applicable law, any such sharing of personal information will be reported to regulators in accordance with the applicable law.
e) Other Lawful Disclosures
5. THIRD-PARTY WEBSITES AND SERVICES
6. SECURITY PRECAUTIONS
We implement appropriate technical and organizational measures designed to ensure your personal information in protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. For example, we limit access of your personal information to authorized parties, periodically inspect, assess, and evaluate the effectiveness of our technical and organizational measures designed to ensure the security of our processing, and limit our collection and use of your personal information to the extent necessary to provide you with our services.
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 Site, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.
Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of personal information. Any transmission is at your own risk and we request that you use appropriate security measures to protect your personal information . If you believe that personal information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
7. RETENTION OF PERSONAL INFORMATION
We will keep your personal information or sensitive information for as long as necessary to fulfill the purposes we collected it for, including any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and all applicable legal requirements.
8. YOUR RIGHTS AND CHOICES
Correction: We must ensure that your personal information is accurate and up to date. Please advise us of any changes to your personal information by contact using the information in the “How To Contact Us” section below.
Rights of individuals in Australia: If you are located within Australia, you have the right to access personal information about you that we hold, and you may ask us to correct such personal information to ensure that it is accurate, up-to-date and complete. There is no charge to submit a request or to correct information, however we may apply an administrative charge for providing access to your personal information on request.
Please note that if you decide to exercise some of your rights, we may be unable to perform the actions necessary to achieve the purposes set out above or you may not be able to use or take full advantage of the services we offer.
Individuals located the European Economic Area, the United Kingdom or Switzerland (collectively “EEA”) at the time, please see Section 12, below for more information about your rights.
9. INTERNATIONAL TRANSFERS
While this is uncommon, when you access or use our Services, we may transfer your personal information to countries in the world where IDEAL conducts business. Such countries may be located outside of the country or jurisdiction where you are located and may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. In such countries, we will still handle your personal information in the manner describe herein. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.
Individuals located in the European Economic Area (“EEA”), the United Kingdom or Switzerland at the time they access our Services, please see Section 12, below.
10. CHILDREN’S PRIVACY
Our Services are not directed to or intended for use by minors. If we learn that we have received any personal information directly from a child under age 16, or such other age as set by the laws of jurisdictions where we operate without his or her parent’s verified consent, we will use that personal information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services and subsequently we will delete that personal information.
11. NOTICE TO CALIFORNIA RESIDENTS
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary for the last twelve (12) months of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect the Personal Information, where we obtain the Personal Information, and the third parties that we may share the Personal Information.
We generally collect the following categories of Personal Information when you use our Services:
We generally do not collect “Sensitive Information”, as identified and defined by the CCPA (California Civil Code section 1798.140 (o)), or protected classifications about our users such as, social security numbers, driver’s license or state identification numbers, account numbers, credit or debit card, in combination with any required security code, access code, password or credentials that would permit access to an individual’s financial account, medical information, biometric information, professional or employment-related information, education-related information user name or email address in combination with a password or security question and answer that would permit access to an online account.
For more information about the Personal Information we collect and how we collect it, please refer to Sections 1 and 2, above.
We collect your Personal Information for the business purposes described in Section 3, above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.
The categories of third parties with whom we may share your Personal Information are listed in Section 4, above.
If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information your account with us or the security of our network systems.
To assert any of your rights above Information, please contact us by email at firstname.lastname@example.org or via phone at (800) 435-0705. To confirm your identity, we may ask you to verify Personal Information we already have on file for you. Verification is required for all access and Deletion requests. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
12. NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM AND SWITZERLAND
Our Relationship to You
We will only contact individuals located in the EEA by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law or the individual’s consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your personal information in this way or to disclose your personal information to third parties for marketing purposes, please click an unsubscribe link in your emails or contact us at email@example.com. You can object to direct marketing at any time and free of charge.
Legal Bases for Processing Your Personal Information
Legal Bases for Processing: Based on our contract with you or to take steps at your request prior to entering into a contract.
Legal Bases for Processing: Based on your consent.
Legal Bases for Processing: Based on our legal obligations.
Legal Bases for Processing: To protect your vital interests.
Legal Bases for Processing: Based on our legitimate interests. When we process your personal data for our legitimate business interests we always ensure that we consider and balance any potential impact on you and your rights.
Your Individual Rights
We provide you with the rights described below when you use our Services. We may limit your individual rights requests in the following ways: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other's privacy; (c) to protect our rights and properties; and (d) where the request is frivolous or burdensome.
If you would like to exercise your rights under applicable law, please contact us at firstname.lastname@example.org. Please note, we may seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal information. When we fulfill your individual rights requests for correct (or rectification), erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort.
International Transfers of Personal Information
We may store, process and transmit personal information in locations around the world, including locations outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.
We transfer your personal information subject to appropriate safeguards as permitted under the applicable data protection laws. Specifically, when your personal information is transferred out of the EEA, we have the required contractual provisions for transferring personal information in place with the third parties to which your information is transferred. For such transfers, we rely on legal transfer mechanisms such as Binding Corporate Rules, Standard Contractual Clauses, or we work under international agreements and treaties with respect to data privacy and cross border transfers of Personal Information, as may be applicable.
HOW TO CONTACT US