EFFECTIVE DATE: December 26, 2019
For California residents, please see the section at the end of this Policy entitled “Important Additional Privacy Information for California Residents” (“the California Section”), which discusses the forms of personal information that we collect from California residents not only through the Sites but also in any off-line interactions with such residents, how we use that information, and California residents’ rights with respect the personal information we collect. If any other section in this Policy can be read to conflict with the California Section, then the California Section controls with respect to California residents.
By visiting or using any of our services on the Sites, you agree that your personal information will be handled as described in this Policy. Your use of our Sites, and any dispute over privacy, is subject to this Policy and our Terms of Service and Conditions of Use (collectively the “Terms”), including its applicable limitations on damages and the resolution of disputes. The Terms are incorporated by reference into this Policy.
The Information We Collect About You
We collect information about you directly from you, from other individuals and entities, as well as automatically through your use of our Sites.
Information We Collect Directly From You
The information that we collect from you depends on how you use our Sites.
- Account Creation. The account creation process varies based on our particular Site. If you would like to make a purchase through certain of our Sites, you have the option of creating an account or checking out as a guest. (You also may create an account without making a purchase.) When you create an account on one of our Sites, we typically collect the following minimum information from you: name, email address, your physical address, phone number, business name (if purchasing on behalf of a business), and the password you will use for your account. For our software products, to create a user account online, we will collect your name and email address.
- Online Purchases. To create an account at our online store, you must provide your name, email address, your physical address, phone number, and the password you will use for your account. If you make a purchase, we will collect information about the products in which you are interested, the products you purchase, and your payment information, such as your payment card and billing and shipping information.
- Requesting Our Newsletter. If you would like to receive our newsletter, we request your name, email address, zip code, and company name.
- Blog subscriptions. If you subscribe to one of the blogs available through our Sites, we request your name and email address.
- Requesting Printed Catalog. If you request a printed catalog from us, we will request your name, email address, and physical address.
- Sign Up for Webinar. If you sign up for a webinar, we will request your name and email address.
- Warranty Registration. To register a warranty through our online submission process, you must provide your name, email address, physical address, phone number, and purchase information. If you have provided us with other personal information, then we may associate this warranty registration information with the other personal information we have collected about you.
- Portals. We use online portals to manage software license registrations. To register an account with one of our online portals, you must provide your name, email address, postal code, your country of residence, and the password you will use for your portal account. You have the option of providing us with information about your company and your mailing address. We also collect information pertaining to your license keys to validate your use of our portals as well as your use of our portal (e.g., the products and services of interest to you).
- Contacting Us. If you contact us through our Sites or leave a product testimonial, we collect your name, mailing address, phone number, email address, your profession and company information, the products you own, your reason for contacting us or your comments on our products, and any other information you choose to provide to us. If you leave a product testimonial, we typically do not associate that testimonial with the other personal information we have collected about you. If you contact us to resolve a product or delivery issue, then, if you have provided us with other personal information, we may associate that information with the other personal information we have collected about you to assist us in resolving the issue.
Information We Collect Automatically
We automatically collect the following information about your use of our Sites through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit or use our Site; and the referring URL, or the webpage that led you to our Sites. We may also collect your approximate location through collection of your IP address. Typically, we do not combine this information with other information that we have collected about you, including, other personal information. Please see the section “Cookies and Other Tracking Technologies” below for more information.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
- To provide our services to you, to communicate with you about your use of our services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
- To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Sites. For example, we may display product distributors in your area or display in a customer portal the products and services you have purchased or registered with us.
- For marketing and promotional purposes. For example, we use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our products and services on other websites.
- To better understand how users access and use our Sites, to improve our Sites and respond to user desires and preferences, and for other research and analytical purposes (such as evaluating product demand per market).
- To administer surveys and questionnaires, such as for market research or customer satisfaction purposes.
- To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
How We Share Your Information
We may share your information, including personal information, as follows:
- Distributors and Product Dealers. If you request, we also may forward your information to a distributor in the area.
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries. Specifically, if you seek a product offered by an entity other than the one that you contact, we will provide your information to an affiliated entity so that they may respond to your inquiry.
- Vendors. We disclose the information we collect from you to vendors, contractors and/or agents who perform functions on our behalf, including, without limitation, vendors that host our Sites, assist us with our marketing efforts, and mail products that you purchase from us.
We also may share information in the following circumstances:
- Business Transfers. If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena. We may disclose this information to law enforcement, regulators, or other parties as required to satisfy these purposes.
- To Protect Us and Others. We also may disclose the information we collect about you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms or this Policy, or as evidence in litigation in which we are involved. We may disclose this information to law enforcement, regulators, or other parties as required to satisfy these purposes.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with vendors for marketing, advertising, research or similar purposes.
- Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites, while others are used to enable a faster log-in process or to allow us to track your activities at our Sites. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
- Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising both on our Site and on sites operated by other entities.
- Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies will be able to browse certain areas of the Site, but some features may not function.
- Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our vendors also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
- Do-Not-Track. Currently, our systems do not recognize web browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Ad Network section.
- Users in the United States may opt out of many vendor ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Links to Other Websites
Our Sites contain links to other websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those other websites. We are not responsible for the information practices of such other websites.
Security of My Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access To My Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information or by contacting our customer service department at the phone number in the Contact Us section below. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time. For California residents, see the California Section for specific information about how to access personal information we have collected.
What Choices Do I Have Regarding Promotional Emails?
We may send periodic promotional emails to you. You may opt-out of such promotional communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites.
Important Additional Privacy Information for California Residents
Under the California Consumer Privacy Act (“CCPA”), we are required to notify residents about the personal information that we collect about them, whether online or offline, and how we handle their personal information. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. It does not include publicly available data as defined by the CCPA.
- Categories of Personal Information that We Collect, Disclose, and Sell. Above we described the personal information that we collect about you through our Sites. In the table below, we summarize the personal information collection described above, as well as include information about you that we may collect outside of your interaction with our Sites. For example, if you call our customer care center, we may record your call for quality assurance and customer service purposes. In describing our information collection practices below, we are using the categories set forth in the CCPA. In the table, we also note whether we disclose or sell that particular category of personal information. Please note that the CCPA broadly defines a “sale” as disclosing or making available to a third party personal information in exchange for monetary or other valuable consideration. Although we do not monetize your information (e.g., we do not sell customer lists to other entities), we do make your information available in the following circumstances, which could be deemed to be a sale under CCPA: online advertising and analytics providers, e.g., we may permit such providers to place a cookie, tag, or other tracking tool on our Sites to assist us with our own advertising. These providers also may use your information to assist other companies with advertising as well.
|Categories of personal information||Do we collect?||Do we disclose for a business purpose(s)||Do we sell?|
|Name, Contact Information and other Identifiers: Identifiers such as a real name, alias, address, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.||YES||YES||YES|
|Customer Records: Paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, current employment, employment history, bank account number, credit card number, debit card number, or any other financial or payment information.||YES||YES||NO|
|Purchase History and Tendencies: Information about your purchases with us. We will disclose this to service providers that assist us in tendering products, maintaining our website, and as described above.||YES||YES||NO|
|Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other activity information related to your use of any Vispero Sites, applications or other online services.||YES||YES||YES|
|Geolocation Data: Precise geographic location information about a particular individual or device.||YES||YES||YES|
|Audio, Video and other Electronic Data: Audio information, such as call recordings, if you contact our call center.||YES||YES||NO|
|Professional or employment-related information: We obtain your employer’s name if you interact with us in your business capacity.||YES||YES||NO|
|Profiles and Inferences: We do not create our own user profiles; we engage advertising providers to assist us in determining relevant advertising. These providers may draw inferences on our behalf using your online interactions with us. We do not obtain this information from the provider.||YES||YES||YES|
- Our Use of Personal Information. The purposes for which we use collected personal information are set forth in the “How We Use Your Information” section above.
- Notice at Collection. Under the CCPA, you have the right to be notified about the categories of personal information that we collect about you; if we collect additional information beyond what is described in this Policy, then we will provide an updated Policy or separate notice, as applicable.
- California Resident Rights. You have the following rights, each of which may be exercised by clicking [HERE]:
- Right to Opt-out of Sale of Personal Information. If you do not want us to share your information with advertising providers, click here. We do not sell personal information about residents who we know are younger than 16 years old, without opt-in consent.
Request to Delete: You may request that we delete your personal information; please note that exceptions apply to this request.
Request to Know: You may request (up to two times per twelve-month period) and, subject to certain exemptions, to receive a copy of the specific pieces of personal information that we have collected about you (in the past 12 months). You have the right to receive this information (at no cost to you) (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that you could provide to a different entity. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:
categories of personal information collected;
categories of sources of personal information;
business and/or commercial purposes for collecting and selling their personal information;
categories of third parties/with whom we have disclosed or shared their personal information for a business purpose;
categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.
- Submitting Requests. Requests to Opt-out of Sale of Personal Information, Requests to Know, and Requests to Delete may be submitted by going to our California Individual Rights Page at www.freedomscientific.com/ccpa, as well as by contacting us at 1-800-444-4443, Ext. 1191 (toll free). We will respond to verifiable requests received from California consumers as required by law.
- Right to Non-Discrimination.The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.
- Financial Incentives. A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, provided the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentive offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent. We do not offer any incentives at this time.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please call 1-800-444-4443, ext. 1191 or email us at firstname.lastname@example.org.