Web Presence LLC dba InternetReputation.com (the “Company”), offers a variety of online reputation management services (the “Services”). The Company collects and uses information from you to operate its website internetreputation.com (the “Site”). The Company is committed to protecting the privacy and security of your information. This Privacy Policy sets forth, among other things:
* How the Company collects information.
* What information the Company collects.
* How the Company may use this information.
* What information the Company may share and who the Company may share it with.
* Your choices regarding the sharing of this information.
This Privacy Policy is governed by, and is subject to, the Company’s Terms of Service (“TOS”), which are available here, and which are incorporated into this Privacy Policy by this reference. The Company reserves the right to revise this Privacy Policy at any time by posting such revisions on this webpage. Any such revisions become effective as of the date they are posted on this webpage, which date is evidenced by the Effective Date at the bottom of this Privacy Policy. Your continued access and/or use of the Site constitutes your agreement to the revised Privacy Policy. If you do not agree to the revised Privacy Policy your only option is to discontinue access and use of the Site. The Company encourages you to periodically review this Privacy Policy.
YOUR ACKNOWLEDGEMENT AND AGREEMENT
Persons under the age of thirteen (13) are not permitted to communicate with the Company, access the Site, use the Services, or purchase goods or services from the Company. Persons who are thirteen (13) years of age or older but less than eighteen (18) years of age may communicate with the Company, access the Site, open an Account, use the Services, and/or purchase goods or services from the Company if, and only if, they have permission from at least one of their parents or legal guardians. Persons who are eighteen (18) years of age or older may communicate with the Company, access the Site, use the Services, and/or purchase goods or services from the Company. In no event may a person who is legally incompetent communicate with the Company, access the Site, use the Services, or purchase goods or services from the Company. In the event that you provide the Company with information pertaining to a person who is less than eighteen (18) years of age, that information is treated in the same manner as information you provide about yourself. By communicating with the Company, accessing the Site, using the Services, or purchasing goods or services from the Company, you consent to the Company’s use and sharing of the information collected or submitted as described in this Privacy Policy. If you do not consent to this Privacy Policy, you are not permitted to communicate with the Company, access the Site, use the Services, or purchase goods or services from the Company.
HOW DOES THE COMPANY COLLECT INFORMATION AND WHAT INFORMATION IS COLLECTED?
The Company collects personally identifiable information (“PII”) and non-personally identifiable information (“Non-PII”) through various sources, including those discussed below. For your reference, PII is data collected with an intention to specifically identify, contact, or locate a person, including but not limited to name, address, telephone number, and/or e-mail address. Conversely, Non-PII is data that is not used to specifically identify, contact, or locate an individual, including but not limited to zip code, gender, age, media access control address (“MAC ID”), and/or internet protocol (“IP”) address. In general, PII and Non-PII is collected from information you provide by contacting the Company via phone, email, letter, use of the Services, purchase of goods or services from the Company, or use of the Site. In some situations PII and Non-PII may also be collected or supplemented from information passively provided by your device, its software, or files on your devices such as cookies or web beacons. Information that is passively collected is generally limited to technical information such as mobile subscription identification numbers, system identification codes, international mobile equipment identification numbers, international mobile subscriber identities, mobile equipment identifiers, subscriber identity modules, mobile serial numbers, equipment serial numbers, operating systems, build numbers, software versions, MAC IDs, and/or IP addresses.
The Company collects PII and Non-PII when you contact the Company, use the Services, purchase goods or services from the Company, use the Site, register for an Account through the Site, subscribe to the Company’s newsletter, or fill out a form on the Site. In general, the Company collects only the information needed to communicate with you, provide the Services, complete sales transactions, or operate the Site.
The Company may engage third party operators, such as an advertising network or a social network plug-in that collects or maintains PII. The name, address, telephone number, and email address of each such operator is listed below, along with a description of what information is provided to each operator and how each operator uses that information:
Facebook, Google, Microsoft
Website Contact Feature
The Company collects information about you when you contact the Company, use the Services, purchase goods or services from the Company, use the Site, register for an account through the Site, subscribe to the Company’s newsletter, open an Account, or fill out a form on the Site. The type of information that the Company collects may include, but is not necessarily limited to, your:
* Full name
* Address(es)
* Telephone number(s)
* Email address(es)
* Date of birth
* Contents of messages you submit to the Company
* Any information, data, or files (such as photographs, word documents, spreadsheets, or Adobe Acrobat pdf format documents) that you submit to the Company
Adobe, Adobe Acrobat, and Adobe Reader are trademarks of Adobe Systems Incorporated, which is a separate company that is not affiliated with or an endorser of the Company.
Use Information
The Company automatically collects information about how people access and use the Site (“Use Information”). When you access the Site, the Company collects information showing the type of device, manufacturer, operating system, build number, version number, web browser, mobile network provider, internet service provider (“ISP”), IP address, MAC ID, screen size, Unique Device Identification number (“UDID”), date/time stamp, referring uniform resource locator (“URL”), the webpages you access on the Site, the duration of time spent on each such page, crash logs, and other information related to your use of the Site.
Message Information
The Company collects data about messages and emails you send to the Company, including but not limited to information submitted through the Site (“Message Information”). Message Information may include the sending user, the recipient, date/time, attachments, and the contents of the message.
The Company retains the right to securely and permanently delete Message Information on a regular basis. When Message Information is deleted in this manner, it cannot be retrieved by the Company. Some Message Information may be stored or retained by the Company because it has a purpose other than transmission of the information. For example, if a user were to send an email to the Company describing a problem with the Site, an Account, or the Services, the Company may store that Message Information so that it can investigate and correct the problem, or to preserve a record of communications between the Company and its users.
Cookies and Other Digital Identifiers
Cookies are small, removable files that contain unique alphanumeric identifiers and are saved on your device. A cookie is created and saved in the local memory of your device when you use a web browser to access the Site. The Company uses cookies to collect Use Information and Non-PII, but does not use cookies to collect PII. If you delete this cookie or set your web browser to refuse requests to set cookies, the Site may not function correctly in whole or in part. By accessing the Site, you consent to the Company’s use of cookies.
Additionally, the Company may use pixel tracking technology to track the completion of transactions with the Company or its advertisers, the source information for those transactions, and your IP address, MAC ID, date/time stamp, browser type, and referring URL.
THIRD PARTY ACCOUNT INFORMATION
The Company may offer you the option to sign into your Account through a third-party service (i.e. via a single sign-on integration or service such as Log In with Facebook, or Log in Using Your Google Account). The Company hereby advises you that some information will be shared between that third party service and the Company. Information the Company received from such third parties shall be associated with your Account and will be covered by this Privacy Policy.
You may revoke a third-party service’s right to access your Account in the Settings section of your Account. Revoking such permission will disable data access between the third-party provider and the Company.
HOW DO I CORRECT AN ERROR?
You can review, correct, update, or change your PII, so long as the change is factually accurate, by contacting the Company’s Customer Service department at [email protected].
HOW DOES COMPANY USE THIS INFORMATION?
The Company may use the information collected from you for any legally permissible purpose in the Company’s sole, absolute, and unfettered discretion, including but not limited to those uses detailed below.
Operation of the Site, Communications, Sales Transactions, and Provision of the Services
The Company may use some or all of your PII and Non-PII to operate the Company, enhance or improve the Company’s operations, operate the Site, improve the Site, process transactions, provide the Services, personalize your experience, communicate with you, notify you about changes to the Company’s products and services, provide you with customer service, service your Account, detect and address technical issues, and improve its operations, products, and services. The Company may also use your PII and Non-PII to verify your identity, verify your Account status and, where the Company determines in its sole, absolute, and unfettered discretion that it is appropriate, to investigate your compliance with the TOS or any advertisements, promotions, terms and conditions, or other offers. Please note that the Company retains your correspondence with the Company’s customer service personnel, and that any calls to the Company may be recorded for training purposes.
The Company may utilize Use Information to monitor and improve the Site and the Services. For this purpose the Company may collect Use Information including but not necessarily limited to how often you access the Site, communicate with the Company, use the Services, what webpages you visit on the Site, and what webpages you visit before or after accessing the Site.
The Company may utilize Google Analytics for similar purposes. Although Google Analytics collects only the IP address assigned to your mobile device on a particular day, the Company may combine the data it receives from Google Analytics with other PII and Non-PII in the Company’s database.
Use of PII
The Company may use your PII to communicate with you, provide the Services, and/or charge you for orders, which use may include but is not necessarily limited to collecting your PII, transmitting your PII, storing your PII, and associating your PII with a specific customer account. The Company may disclose PII when authorized, when necessary to protect public safety or health, or in response to legal process.
Marketing
The Company may use your PII and Non-PII in its marketing programs. By providing this information to the Company, you consent to receiving regular text message, email, correspondence, and/or phone communications from the Company.
Data Retention
Except as provided elsewhere in this Privacy Policy, the Company retains the right, but not the obligation, to store your PII and Non-PII for as long as necessary for the purposes set forth in this Privacy Policy. The Company may retain and use your PII and Non-PII to the extent necessary to comply with legal obligations, resolve disputes, and enforce Company policies.
HOW DOES COMPANY SHARE INFORMATION?
The Company may share your PII and Non-PII for any legally permissible purpose in the Company’s sole, absolute, and unfettered discretion, including but not limited to those detailed below.
Independent Contractors
The Company may share your PII and Non-PII with various third party independent contractors that perform services for or on behalf of the Company, including but not limited to vendors that provide the Company with technology to deploy commercial email, host websites, and maintenance of the Company and the Site. In general, the Company provides these independent contractors with only the information they need to provide their respective services. Each such independent contractor must agree to utilize reasonable security procedures, policies, practices, software, and hardware, as appropriate to the nature of the information involved and the service being provided. Independent contractors are prohibited from using your PII and Message Information except as authorized by the Company.
Ad Serving Companies
The Company may use third party advertising networks or ad serving companies to serve advertisements on the Site or in communications with you. The Company may forward your PII and Non-PII to these companies so that they can deliver targeted advertisements that they believe will be of interest to you. The information forwarded to these companies may include, but is not limited to, your full name, mailing address, telephone number, email address, date of birth, gender, IP address, MAC ID, location, device, date/time stamps, and referring URL. Web pages that are served by these companies will state that they are “powered by” or “ads by” the applicable company and will contain a link to the provider’s privacy policy.
Data Enhancement/Appending/Validation
The Company may use third party service providers to enhance the Company’s database of PII and Non-PII information with additional elements. Further, the Company may use third party service providers to append additional information to the information you provide to the Company. Company also may use third party service providers to validate the PII and Non-PII information in the Company’s database.
Governmental Agencies or Other Companies
The Company may share your PII and Non-PII with law enforcement officials or governmental agencies (1) in response to their request; (2) when permitted or required by law; or (3) to establish the Company’s compliance with applicable laws, rules, regulations, or guidelines. In addition, there are certain situations where the Company may be authorized or required by law to disclose your PII and Non-PII to law enforcement officials or governmental agencies, such as when there is a threat to public health, or if the Company receives a valid subpoena for some or all of your information from a court of competent jurisdiction.
The Company may store and share your PII and Non-PII with third parties for suppression or opt-out purposes.
The Company also may share your PII and Non-PII with third parties when (1) trying to protect against or prevent actual or potential fraud or unauthorized transactions; (2) investigating fraud that has already taken place; (3) enforcing or applying the TOS, existing terms and conditions, and/or other agreements; (4) protecting the rights, property or safety of the Company, the Site, the Services, other customers of the Company, or third parties; or (5) responding to subpoenas, court orders or legal process, or to establish or exercise the Company’s legal rights or defend against legal claims. In such situations, this PII and Non-PII is not being provided to these entities or persons for marketing purposes.
Right to Transfer
Should the Company choose to sell or transfer business assets, it is possible that the information the Company possesses about you may be transferred as part of that transaction. The Company may decide to retain a copy of your information even after the sale or transfer has been completed.
CUSTOMER CHOICES
Marketing Communications
By sharing PII and Non-PII with the Company, including but not limited to registering with the Company, subscribing to the Company’s newsletter, and/or creating an Account, you are consenting to receive marketing communications from the Company and its third party marketing partners, if any. If, after you have shared your PII and Non-PII with the Company, you decide that you do not want to receive marketing communications from the Company and its third party marketing partners, if any, you can discontinue the communications by following the opt-out instructions. If you have registered or submitted PII and Non-PII under more than one email account, you must submit separate unsubscribe requests for each email account.
Deleting Your Information
You may instruct the Company to close your Account and/or delete your PII by emailing the Company’s Customer Service department at [email protected]. When the Company receives your request it shall securely delete your Account and all PII in the Company’s possession, as appropriate to your request, unless the Company has retained such information for a purpose authorized by the TOS or this Privacy Policy. Please allow thirty (30) days for Company to process your request.
Revoking Permissions to Collect User and Use Information
The Site and the Services will not work without the ability to collect PII and Use Information. Accordingly, the only manner by which you may revoke permission for the Company to collect PII and Use Information is by submitting a request to delete your information, close your Account, and stop accessing the Site.
WHAT HAPPENS IF YOU FOLOW A HYPERLINK FROM THE SITE TO ANOTHER WEBSITE?
The Company may offer links to other websites. Other websites have their own terms of use and privacy and security policies. If you choose to visit one of these sites, you should review the policies that govern that particular site.
APPLICATION OF THIS PRIVACY POLICY
This Privacy Policy applies to all information collected by or submitted to the Company as a result of your interaction with the Company, your Account, or use of the Site. It does not apply to information the Company collects offline. Other affiliated entities of the Company may obtain PII and Non-PII independently from transactions and experiences with you or from other sources.
This Privacy Policy does not pertain to that information.
WHAT IS THE POLICY WITH RESPECT TO COMMUNICATING WITH CHILDREN?
The Company recognizes the unique privacy concerns regarding children and is committed to carefully protecting privacy where children are involved no matter the point of contact. In particular, it is the Company’s intention is to fully comply with the Children’s Online Privacy Protection Act (“COPPA”). Per COPPA guidelines, Company does not knowingly collect PII from children under the age of 13. If a parent or guardian is made aware that a child under the age of 13 has provided the Company with PII through any point of contact, the parent or guardian should contact the Company, whereupon the Company shall use commercially reasonable efforts to delete the PII about the child from its files. In the event that you provide the Company with information about a child under the age of 13, for example a son, daughter, niece, nephew, or grandchild, the Company treats that information the same as information you provide about yourself.
COPPA NOTICE OF PARENTAL RIGHTS
Pursuant to COPPA, the Company hereby notifies parents about its practices for collecting information from children under the age of 13. The Company will not require a child under the age of 13 to provide any information at all. If you choose to provide information about a child under the age of 13, the Company will not require you to provide more information about that child than is reasonably necessary for the Company to provide the Services and complete its other routine business operations. You can review any information you provide about a child under the age of 13 in the same way that you review any other information you provide to the Company. You may direct the Company to stop further collection or use of information you provided about a child under the age of 13, authorize the Company to continue collection and use of information you provided about a child under the age of 13 but cease disclosure to third parties unless they are an integral part of the Services, or direct the Company to delete information you provided about a child under the age of 13, by sending an email to the Company’s Customer Service department at [email protected].
In the event that you provide the Company with information about a child under the age of 13, the Company collects information about the parents or legal guardians of that child for the purpose of obtaining their consent to its collection, storage, and use of that information. That consent is required for the Company’s collection, storage, and use of that information. The types of information that are collected from children under the age of 13 is the same as the types of information collected from other persons, which are detailed in the section above entitled “How does the Company collect information and what information is collected?” Parents and legal guardians give their consent for the Company to collect, store, and use this information by providing it to the Company. That consent can be revoked or limited using the procedures set forth in the preceding paragraph. If a parent or legal guardian revokes their consent, or the Company determines that the user who provided the information lacked legal authority to do so, the Company will delete the information and the parent’s online contact information from the Company’s records.
SECURITY
There is no such thing as complete security on the Internet or otherwise. The Company uses various security techniques on the Site and when providing the Services to help protect against the loss, misuse, or modification of information collected from you. When you transmit your information to the Company, that information is stored on servers for which the Company has taken steps to protect against unauthorized access or intrusion. While the Company strives to protect your information, the Company cannot and does not ensure or warrant the security of any information you provide to the Company. You acknowledge and assume this risk when providing information to the Company.
DATA BREACHES
If the Company experiences a data breach, the Company shall attempt to determine how the intrusion was made, who perpetrated the breach, what information was taken, and which customers were affected. The Company shall notify any affected persons using the contact information in the Company’s databases.
GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the European Economic Area, you have certain data protection rights. If you meet this criteria, you have the following data protection rights in certain situations: (1) the right to access, update, or delete the PII that the Company has in its possession; (2) the right of rectification of your PII; (3) the right to object; (4) the right of restriction; (5) the right to data portability; and (6) the right to withdraw consent. To invoke these rights, please see the corresponding section of this Privacy Policy. For example, if you want the Company to delete your PII, please follow the procedure set forth in the section entitled “Revoking Permissions to Collect User and Use Information” above.
LIMITATION OF LIABILITY
YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TOS, AS SUPPLEMENTED BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. YOU AGREE THAT THE COMPANY’S LIABILITY FOR ANY BREACH OF THE TOS OR THIS PRIVACY POLICY IS LIMITED TO THE AMOUNT
YOU HAVE PAID TO THE COMPANY.
State-Specific Terms and Conditions
Pursuant to Sections 1798.83 and 1798.84 of the California Civil Code, residents of the State of California have the right to request a notice specifying the categories of PII that the Company shares with affiliates and third parties for marketing purposes and the contact information for those affiliates and third parties. You may submit such a request by sending an email to the Company’s Customer Service department at [email protected].
Effective Date: June 19, 2019.
