Privacy and Cookies Policy

2. Use of Personal Information

We use your Personal Information for the following purposes:

2.1.

To provide services to our subscribers, including sending you data, information, news, articles, and other related services that you specifically request from us.

2.2.

For marketing purposes, including sending offers, promotion alerts, newsletters, and other communications to our subscribers/users and business contacts.

2.3.

To manage our business relationships with our subscribers/users, vendors, suppliers, and business partners, including processing payments and sending service-related communications.

2.4.

To communicate with you, respond to your inquiries, and to notify you about changes to our Site or any services we provide through the Site.

2.5.

To protect the security, effective functioning of our Site and information technology systems.

2.6.

For other business purposes, such as to provide, operate and improve our products and services, to perform data analyses, to detect, prevent and respond to actual or potential fraud or illegal activities, to defend our legal rights and to comply with our legal obligations and internal policies.

3. Sharing of Information

We will share Personal Information with the following categories of recipients, subject to applicable law:

3.1. Affiliates and Employees.

We share Personal Information with our affiliates and employees all over the US as needed to provide our services, for purposes consistent with this Policy or to operate shared infrastructure, systems and technology.

3.2. Suppliers and Service Providers.

We share Personal Information with companies that provide products or services to us for the operation of our business. These include providers of IT and software services, remote office services, cyber security services, mailing services, marketing services and finance systems. Such parties provide reasonable security for Personal Information and to use and process such Personal Information on our behalf only.

3.3. Professional Advisors.

We share Personal Information with our accountants and other outside professional advisors in the course of the services they provide to us.

3.4. Corporate Purchases.

We may share Personal Information with any corporate purchaser or potential purchaser to the extent permitted by law as part of any merger, acquisition, sale of our assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Information would be transferred as an asset of us.

3.5. Mandatory Disclosures and Legal Claims.

We share Personal Information in order to comply with any subpoena, court order or other legal process, and to comply with a request from our regulators, governmental request or any other legally enforceable demand. We also share Personal Information to establish or protect our legal rights, property or safety, the rights, property or safety of others, or to defend against legal claims.

3.6. Other Third Parties with Your Consent.

We share Personal Information with other third parties with your consent.

4. Cookies

Through the use of cookies and similar technologies, we may collect your device identifier or IP address, unique device ID, hardware and software type, internet service provider, serving domain, geographical area, location data, browser type, settings data (such as screen resolution, color depth, time zone settings, browser extension and plugins), operating system, referring URLs, search history, information on actions taken or interaction with our digital assets (e.g., page views) and dates and times of actions. 

The types of cookies we use include:

4.1. Operational Cookies.

To the extent applicable, we use operational cookies which are required for the operation of our Site, for example, cookies that enable you to log into some areas. These operational cookies are session cookies that are erased when you close your browser.

4.2. Google Analysis.

We use Google Analytics to collect information about how you use our services. We use this information to create reports and improve our services. The cookies help us understand the number of visitors to our Site and where visitors come from. To learn more about how Google uses data, visit https://policies.google.com/technologies/partner-sites. To opt-out from these cookies across our Site, visit https://d2ph28qcv9dhz6.cloudfront.net/wp-content/uploads/gaoptout.

4.3. Functional Cookies.

We use functional cookies to improve the functional performance of our Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site. These cookies qualify as persistent cookies because they remain on your device for us to use during your next visit to our Site.

Most web browsers allow you to manage cookies through the browser settings. Be aware that, if you opt out from and do not agree to certain cookies, your experience on our Site may be diminished and some features may not work as intended depending on the cookies. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org. 

5. Data Security

We maintain administrative, technical and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of the Personal Information in our possession. However, because no information system can be One Hundred Percent (100%) secure, we cannot guarantee the absolute security of your information. We will not be liable for unauthorized disclosure of Personal Information that occurs through no fault of us including, but not limited to, errors in transmission, access to a user’s account by anyone other than the user, uses of users’ ID and password by a third party, user’s failure to comply with user’s security obligations, and the unauthorized acts of our employees.

6. Your Controls and Choices.

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your Personal Information. In accordance with local law, your controls and choices are described in this Section and supplemented by Section 8: 

6.1.

You may correct, update and delete your registration account on our Site. You may also update and correct inaccuracies in your account information at any time by logging in your registration account.

6.2.

You may change your choices for subscriptions, alerts and newsletters.

6.3.

You may choose whether to receive offers and updates from us and promotions for our services.

6.4.

You may request access to the Personal Information we hold about you and that we amend or delete such information.

6.5.

You may set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.

You may exercise your controls and choices, or request access to your Personal Information by contacting us as specified below. Please be aware that if you do not allow us to collect Personal Information from you, some of our services may not be available to you. If you have questions regarding the specific Personal Information about you that we process or retain, please contact us as specified below.

7. Changes to This Policy

We may make changes to this Policy. The “Last Updated” date at the top of this page indicates when this Policy was last revised. If we make material changes, we may notify you via a notice posted on our Site, emails or other methods. We encourage you to read this Policy periodically to stay up to date about our privacy practices.

8. Users‘ Rights

8.1. Rights for EEA Residents

Pursuant to the General Data Protection Regulation (“GDPR”), if a user is a resident of the European Economic Area (“EEA”), we process his or her Personal Information under the following lawful bases:

8.1.1.

Users’ consent.

8.1.2.

The performance of the contract between users and our Site.

8.1.3.

Compliance with our legal obligations.

8.1.4.

To protect users’ vital interests.

8.1.5.

To perform a task carried out in the public interest.

8.1.6.

For our legitimate interests, which do not override users’ fundamental rights and freedoms.

If users are residents of the EEA, they also have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on them or otherwise significantly affects them.

We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data. Services that include elements of automated decision-making include:

8.1.7.

Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a small number of hours.

8.1.8.

Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a small number of days.

If users are residents of the EEA, they also have the right to access the Personal Information we hold about them, to port it to a new service, and to ask that their Personal Information be corrected, updated, or erased. If they would like to exercise these rights, they shall contact us through the contact information in the Section 12 below.

Users’ Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States.

8.2. Rights for California Residents

If users are residents of California, they have the right to access the Personal Information we hold about them, to port it to a new service, and to ask that their Personal Information be corrected, updated, or erased.

8.2.1. Right to Request Access or Know Personal Information.

If users are residents of California, they have the right to request and receive the categories and specific pieces of Personal Information we have collected about them, the categories of sources from which the Personal Information is collected, the business purpose for collecting the Personal Information, the categories of third parties with whom we share Personal Information, the length of time we intend to retain each category of Personal Information, and, if that is not possible, the criteria used to determine that information.

8.2.2. Right to Correct Inaccurate Personal Information.

If users are residents of California, they have the right to request that we correct inaccurate Personal Information, taking into account the nature of the Personal Information and the purpose for which it was collected.

8.2.3. Right to Delete Personal Information.

If users are residents of California, they have the right to delete their Personal Information under certain circumstances. We may refuse requests to delete for certain enumerated reasons, including that the Personal Information was not collected from them (e.g.obtained from other sources), as necessary to comply with applicable laws, or if deleting the data would prevent us from exercising or defending legal claims.

8.2.4. Right to Consent to Collection of, or Limit the Use of, Sensitive Personal Information.

If users are residents of California, they may have the right to consent or opt out of processing of sensitive Personal Information, or to limit the use of sensitive Personal Information. However, considering that we do not collect or process users’ sensitive Personal Information without their consent, do not use sensitive Personal Information for any purpose other than to provide the products and services they request, and do not use it to infer characteristics about them. Therefore, we do not, and are not required to provide the users with the right to limit the use of their sensitive Personal Information.

8.2.5. Right to Opt Out of the Sharing of Personal Information.

If users are residents of California, they have the right to opt out of the sharing of Personal Information for targeted advertising purposes. As a result, users have the right to reject all cookies except functional cookies (this option will opt them out of all sharing for targeted advertising purposes). If users visit us from a different device or browser, or clear cookies, they may need to re-select their preferences. Please note that even if the users opt out of the sharing of their Personal Information, their use of our Site may still be tracked by us and/or our service providers.

8.2.6. Right to Request a Notice of the Disclosure of Personal Information.

If users are residents of California, California Civil Code Section 1798.83 permits them to request a notice regarding the disclosure of their Personal Information by us to partners for the partners’ direct marketing purpose. If users are California residents and would like a copy of this notice, please contact us by email using the details provided under the Section 12 below.

If users would like to exercise these rights, please contact us through the contact information in the Section 12 below. If users would like to designate an authorized agent to submit these requests on their behalf, please contact us at the address in the Section 12 below.

8.3. Rights for Other U.S. States’ Residents

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

8.3.1.

Confirm whether we process their Personal Information.

8.3.2.

Access and delete certain Personal Information.

8.3.3.

Data portability.

8.3.4.

Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

8.3.5.

Correct inaccuracies in their Personal Information, taking into account the information’s nature processing purpose.

8.3.6.

Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. 

9. Children Under Thirteen (13) Years of Age

We are committed to protecting the online privacy of children and making the internet safe. We do not provide products and services to children, or knowingly collect or solicit Personal Information from children under Thirteen (13) years of age. Any communication we get that is identified as being from a child under Thirteen (13) years of age will not be kept by us. We encourage parents or guardians of children under Thirteen (13) years of age to regularly check and monitor their children’s use of email and other activities online.

10. Miscellaneous Issues

10.1. What are the Consequences of Not Providing Personal Information?

You are not required to provide all Personal Information identified in this Policy to visit our Site or to interact with us offline, but certain functionality will not be available if you do not provide Personal Information. If you do not provide Personal Information, we may not be able to respond to your request, provide services to you or provide you with information that we believe you would find valuable. 

10.2. Does the Site Honor Do Not Track (“Dnt”) Signals Sent via Browsers?

Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to DNT signals at this time. We will continue to work with the online industry to define a common understanding of how to treat Do Not Track signals. 

10.3. How Long Do We Retain Personal Information?

We typically retain Personal Information related to marketing activities for as long as you accept marketing communications from us, and we will securely delete such data in accordance with applicable law upon request. For Personal Information that we collect and process for other purposes, we will typically retain such Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise specified in applicable record retention policies and procedures.

10.4. Are Third Party Websites Governed by This Policy?

Our Site may contain links and references to other websites administered by unaffiliated third parties. This Policy does not apply to such third-party sites. When you click a link to visit a third-party website, you will be subject to that website’s privacy practices. We encourage you to familiarize yourself with the privacy and security practices of any linked third-party websites before providing any Personal Information on that website.

11. Complaints

If users would like to make a complaint, they can contact us by email or by mail using the details provided under the Section 12 below.

If users are not satisfied with our response to their complaint, they have the right to lodge their complaint with the relevant data protection authority. They can contact their local data protection authority, or our supervisory authority based on their jurisdictions.

12. Contact Us

If you have any questions about this Policy, or if you would like to exercise your rights to your Personal Information, you may contact us at contact@astone.io. We will do our best to address your concerns.