Collectively, we refer to the Website, Apps, Social Media Pages, emails, communications, and offline interactions as the “Services.”
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The types of Personal Information we collect depends on your level of engagement with the Services. The more you interact with the Services, the more information we need to provide the Services.
To the extent permitted by applicable law, we may use, process, transfer and store user data in an anonymous and aggregated manner. We may combine such data with other information collected, including information from third-party sources. By using the Services, you agree that we are permitted to collect, use, share and store anonymized aggregated data collected through the Services for benchmarking, analytics, metrics, research, reporting, machine learning and other legitimate business purposes. Personal Information does not include information that has been de-identified or aggregated such that you can no longer be identified.
From registered and unregistered users of the Website, we automatically receive and record information whenever you interact with the Website, including:
We may collect Personal Information from you when you request information about our Services, register for our newsletters, request customer or technical support, or otherwise communicate with us. We may send marketing materials to you using various communication channels, including without limitation, email, text messages/SMS, push notifications, telephone calls, and direct mail. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include Personal Information.
When you create your account on the Website, you provide us with:
By visiting your Account Settings on our Website, you can correct, amend, add or delete Personal Information associated with your account. However, even after you update information, we may maintain a copy of the original information in our records as required by applicable law or other legal obligation.
We and our service providers use Personal Information for the following purposes:
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest. We will provide personalized services based on our legitimate interests and with your consent, to the extent that your consent is required by applicable law.
We disclose Personal Information:
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. We collect Other Information such as:
We and our service providers may collect Other Information in a variety of ways, including:
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Services or otherwise to us.
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete or improperly processed Personal Information; and (vi) request erasure of Personal Information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we may take steps to verify your identity before fulfilling your request.
You may delete your Risk Factor account on the Settings page under “Close Account”. We retain Personal Information for as long as we have a valid business purpose to or to meet our legal obligations. We may be required to keep a copy of your Personal Information as necessary to fulfill the purposes(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Risk Factor32 Bridge Street, Floor 3Brooklyn, NY firstname.lastname@example.org
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
Pursuant to the CCPA, effective January 1, 2020, consumers whose personal information have been collected by us, have certain rights, including:
We may have collected the following categories of personal information of California residents in the past 12 months:
We may have disclosed your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. During the past 12 months, we have disclosed the following categories of personal information for a business purpose: Identifiers, California Customer Records personal information categories, professional or employment-related information.
Right to Opt-Out of Sale of Your Personal Information: Consumers have the right to request that a business that sells the consumer’s personal information, or that discloses it for a business purpose, inform the consumer of what has been collected about them and who it has been sold or disclosed to. Consumers also have the right, at any time, to direct a business that sells personal information about them not to sell their personal information. The CCPA sets forth certain obligations for businesses that “sell” personal information. The CCPA defines “sale” broadly to include not only providing data to third parties for payment but also transferring personal information to third parties in exchange for “other valuable consideration.” During the past 12 months, we have not provided and we do not currently provide personal information to third parties for monetary payment.
Consumer request process: Consumers may submit a Verifiable Consumer Request by sending us a message through the Website or emailing us at email@example.com on up to two occasions every 12 months. Upon receiving a Verifiable Consumer Request (that’s reasonable in light of the nature of the personal information requested) we will provide this information in writing, free of charge, within 45 days of the request, or if reasonably necessary (upon notice to you), within 90 days. We will also disclose, if applicable: the categories of sources from which the personal information was collected; the business or commercial purpose for collection of the information; and the categories of service providers with whom we shared the information.
We may not be able to fulfill the request if we (or our service providers) are required to retain the personal information for the following reasons:
California residents also have the right to not be discriminated against if they choose to exercise their privacy rights. We will not discriminate against the consumer for exercising their CCPA rights. Unless permitted by the CCPA, we will not: