PRIVACY POLICY

Last Changes to Privacy Policy: October 19, 2019

We are strongly committed to letting you know how we will collect and use your personal information. The policies below are applicable to data and information collected through the Data Obrii network of websites, including dataobrii.com (including any versions optimized for viewing on a wireless or tablet device) through our services (“Services”); all email newsletters published or distributed by Data Obrii; all apps published by Data Obrii; and all other interactive features and communications provided by Data Obrii (“Website”), however accessed and/or used, that are operated by us, made available by us, or produced and maintained by Data Obrii, Inc. (collectively “Data Obrii” or “we”, “us”, or “our”). We have established this privacy policy (“Privacy Policy”) to let you know the kinds of personal information we may gather during your use of this Website, why we gather your information, what we use your personal information for, when we might disclose your personal information, and how you can manage your personal information.

Please be advised that the practices described in this Privacy Policy apply only to information gathered online through our Website. It does not apply to information that you may submit to us offline or by companies or organizations to which we may link or who may link to us.

We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice. If we intend to apply the modifications or amendments to this Privacy Policy retroactively or to personal information already in our possession, we will provide you with notice of the modifications or amendments.

Information Collected

We collect two basic types of information from you in conjunction with your use of the Website, personal information and non-personal information. Personal information is information that you may supply to us, as described more fully below, i.e., when you obtain a subscription, complete a survey, register on the Website, upload content, participate in a community, or provide your email address. Personal information is any information that can individually identify you and includes, among other things, your name, e-mail address, telephone number, postal address, credit card, billing and contact information. Non-personal information includes information that does not personally identify you, but it may include tracking and usage information about your location, demographics, use of the Website and the Internet.

Personal Information

As a general matter, you can browse the Website without submitting your personal information to us. However, there are a number of circumstances in which you may supply us or our agents with your personal information. The following lists the most common ways in which we may collect your personal information.

·        Registration for an event sponsored by Data Obrii

·        Downloading collaterals from the Website

·        Submitting an application to work at Data Obrii

·        Sign up to receive alerts or other information via email, text or instant message from Data Obrii

·        Request for sales calls, customer service, support requests or other assistance

·        Website related communications, e.g. account verification; technical notification

·        Participation in communities, commenting to blog entries and participation in other forums

·        Any other place on the Website where you knowingly volunteer personal information

Non-Personal Information

·        In addition, when you interact with the Website, we may collect certain information that does not identify you individually and our servers may automatically keep an activity log of your use of our Website (“Non-Personal Information”). Generally, we collect and store the following categories of Non-Personal Information:

·        Non-identifiable demographic data such as age, gender, and five-digit zip code as part of collecting personal information

·        Device information about your computer, browser, mobile device, or other device that you use to access the Website. This information may include IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information.

·        Analytics and usage information about your use of the Website.

·        Additional “traffic data” and log files such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses.

·        Other information regarding your use of the Website.

·        We may also gather and use information about you from publicly available third-party sources.

Collection of Your Source IP Address/Location Information

We may collect and store location information about you on the Website and associated with your account that you volunteer on the Website or enable through the Website or your device. We will not collect any location information that you do not volunteer or enable. We will delete any location information that you request is deleted. We do collect and store your device’s source IP address which may disclose the location of your device at the time you access the Website.

Tracking and Targeting

We may allow service providers and other third parties to use cookies and other tracking technologies to track your browsing activity over time and across the Website, Services and third party websites. For example, we may partner with third party advertisers to display advertising on the Website or manage our advertising on other sites. These advertisers may also provide you targeted ads based upon your interests on third party sites. We also use third party website analytics services that help us analyze users’ interactions with the Website. Some advertising networks allow you to opt out of targeted advertising. For more information, visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

See our Cookies and Similar Technologies Notice for more information about how the third party analytics, advertising and social media companies use cookies and similar technologies to collect your information when you use the Website or Services.

The Website will respect your browser’s Do Not Track signals (or other well-established, commercially available mechanisms that provide you with the ability to exercise choice regarding the collection of Personal Information).  If we receive a Do Not Track notice, we will stop using any Personal Information for online behavioral advertising purposes. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

In some of our communications, we track clicks on links in the communications to content on the Website and in the Services to help us measure the effectiveness of our communications.

How Do We Use Your Information?

We use your personal information and other non-personal information, such as your location information, we learn from you to help us personalize and continually improve your experience on the Website.  We may use your Personal and Non-Personal Information in the following ways:

To provide the Services

We use your personal information to provide, support, understand and improve the Services. As part of providing the Services we may send you service announcements, technical notices, updates, security alerts and support-related messages related to your account or transactions with us, through the Services or by email. We may also communicate with you in response to your support requests, questions, feedback or comments to a blog post, or to provide you with information about our policies.

To personalize the Services

We use the information we collect to personalize content and experiences on our Website, to better understand your interests, make personalized recommendations based on your interests or information and otherwise personalize your experience with the Services.

To send you marketing communications

If you use the Services, request information from us, or participate in our surveys, promotions or events, we may send you John Elliott-related marketing communications. You can always opt-out of these communications by following the opt-out instructions in the message or by contacting us.

To create anonymous data

We may create aggregated and other anonymous data from our users’ personal information.  We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties to operate, understand and improve our Services, to develop new services, and for other lawful business purposes.

For security, compliance, fraud prevention and safety

We may use your personal information as we believe appropriate to investigate or prevent violation of the law or our Terms of Service; to secure the Services; to protect our, your or others’ rights, privacy, safety or property; and to protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. For example, we may use tools to scan your videos and other content in the Services for content that violates our Terms of Service or the law. We may also use the information we collect about your device to detect users violating our Terms of Service and prevent further violations.

For compliance with law; legal claims

We may use your personal information as we believe appropriate (a) to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) where permitted by law in connection with any legal investigation; and (c) to prosecute or defend legal claims.

With your consent

In some cases we may ask for your consent to collect, use or share your personal information with your consent. We use the information from one portion of the Website on other portions of the Website or elsewhere in our network of websites, apps, and other interactive features, or in reports and analysis, all of which are owned and operated by Data Obrii, and we may combine information gathered from multiple portions of the Website into a single customer record or analysis or report. We also use and/or combine information that we collect off-line or we collect or receive from third party sources to enhance, expand, and check the accuracy of your customer records.

How We Share Your Personal Information?

We do not disclose information about your Personal Information collected online to any companies not part of Data Obrii or its parent, subsidiaries or related entities. In no event will we sell or rent your Personal Information as part of a customer list or similar transaction.

Affiliates

We may share some or all of your personal information with our subsidiaries, joint ventures, or other companies under common control, in which case we will require those entities to honor this Privacy Policy.

Business Partners and Third Parties

We may share your Personal Information with our business partners from time to time.  You may withdraw your consent to our sharing of your Personal Information with business partners and third parties at any time by following the opt-out process described below.

Third-Party Agents

We have third party agents, subsidiaries and partners that perform functions on our behalf, such as hosting, billing, push notifications, storage, bandwidth, content management tools, analytics, customer service, fraud protection, etc.  These entities have access to the Personal Information needed to perform their functions and are contractually obligated to maintain the confidentiality and security of that Personal Information. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to the Website.

For compliance with law; legal claims; security, compliance, fraud prevention and safety

We may also use or disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Website; (b) protect and defend our rights or property, the Website or our users, and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Website or the public. This includes exchanging information with other companies and organizations for fraud protection.

Business transfers

We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization, sale of assets or in the event of bankruptcy.

What Steps Are Taken To Keep Personal Information Secure?

We are concerned about ensuring the security of your Personal Information.  We exercise great care in providing secure transmission of your information from your device to our servers.  Personal Information collected by our Website are stored in secure operating environments that are not available to the public. Our security procedures mean that we may occasionally request proof of identity before we disclose your Personal Information to you. Please understand, however, that while we try our best to safeguard your Personal Information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

How Can We Transfer Your Personal Information?

Data Obrii is headquartered in the United States and has service providers in other countries. Your personal information and other information collected through the Website and Services may be stored and processed in the United States or any other country in which Data Obrii, its Clients, Affiliates or service providers maintain facilities. Data Obrii, its Clients, Affiliates, or service providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the United States or other regions with laws governing data collection and use that may differ from US law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. By registering for and using the Website you consent to the transfer of information to the US or to any other country in which Data Obrii, its Clients, Affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy. If you are in the European Economic Area or Switzerland, please see the Cross-Border Data Transfer language below.

Cross-Border Data Transfer

If we transfer your personal information out of the European Economic Area or Switzerland and are required to apply additional safeguards to your personal information under European data protection legislation, we will do so.  Such safeguards may include applying the European Commission Model contracts for the transfer of personal data to third countries described here (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en#international-data-transfers-using-model-contracts), or for transfers to third parties in the United States, ensuring they participate in the EU-U.S. Privacy Shield Framework or Swiss-U.S. Privacy Shield Framework.  Please contact us for further information about any such transfers or the specific safeguards applied.

How Long Do We Keep Your Information?

Following termination or deactivation of your account, Data Obrii, its Clients, Affiliates, or its service providers may retain information (including your profile information) and user Content for a commercially reasonable time for backup, archival, and/or audit purposes. If you have any questions about termination or deactivation of your account, please contact us directly at [email protected].

Social Media Widgets

Our Service may include social media features, such as the Facebook, Twitter, Instagram and Tumblr widgets. These features may collect your personal information and track your use of the Service. These social media features are either hosted by a third party or hosted directly in the Service. Your interactions with these features are governed by the privacy policy of the company providing such functionality.

Payment Information

Any payment card information you use to make a purchase on the Services is collected and processed directly by us or our payment processor, Stripe, Inc. and we never receive or store your full payment card information]. Stripe, Inc. may use your Payment Information in accordance with its own Privacy Policy here: https://stripe.com/us/privacy.

What Happens When I Link To or From Another Website?

This Website may link or integrate with other websites and services operated by third parties, including social media platforms, advertising services, and other websites and applications. These links and integrations are not endorsements of or representations that we are affiliated with any third party. Please be advised that the practices described in this Privacy Policy for Data Obrii do not apply to information gathered through these other websites. We do not control the third-party websites, applications, or services and we are not responsible for the actions and privacy policies of third parties and other websites. Third-party websites and services follow different rules regarding their collection, use and sharing of your personal information and we encourage you to read their privacy policies to learn more.

User-Generated Content

We may make available on the Website or in the Services, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.

Children

The Services are not directed to anyone under the age of 16. A parent or guardian who becomes aware that his or her child under the age of 16 has used the Services may contact us at [email protected] and we will attempt to delete the child’s personal information as soon as possible.

Changes to This Privacy Policy

As our Website continues to develop, we may add new services and features to our Website. In the event that these additions affect our Privacy Policy, this document will be updated appropriately. We will post those changes prominently so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. We do, however, recommend that you read this Privacy Policy each time you use our Website in case you missed our notice of changes to the Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy or don’t see your concerns addressed here, you should contact us by email at [email protected].

How Do I Opt-Out or Correct Information About Me

You may always opt-out of receiving future e-mail messages and newsletters from Data Obrii.  We provide you with the opportunity to opt-out of receiving communications from us by going into your profile settings and choosing the appropriate options. To opt-out, you can also send us a message at [email protected].  Please note, however, that you generally cannot opt-out of service-related announcements, e.g. if the Website is temporarily suspended or if delivery of a product or service is delayed.