Perfecting Your Privacy Policy

Posted on: 25th February 2013

Creating Privacy PolicyPrivacy policies usually contain information about how cookies can be collected and stored, and how the company and third parties can use collected information, including automatically information. They also contain exclusion clauses and statements of liability in regards to the security of collected information and the responsibility of users to ensure the safety of their passwords.

(COMPANY NAME) values the privacy of our users, members, and others who visit and use www.[Company].com and its associated websites and services (collectively, the “[Company] Site”). This statement governs information you provide to us or that we learn from your use of the [Company] Site and tells you how we may collect, use, and in some instances share, this information.The Information [Company] Collects User Provided Information: You may provide to (company name) what is generally called “personally identifiable” information when you register, such as your name and e-mail address. In addition, (company name) may give you the option to provide us with certain demographic information about yourself and to upload photographs or other personally identifiable information.

“Cookies” Information: When you visit the (company name) Site/App, we may send one or more cookies – a small text file containing a string of alphanumeric characters – to your computer. (company name) uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the (company name) Site/App. By using these cookies, we can “remember” what you have done on the (company name) Site/App before and personalize our site for you. These persistent types of cookies can be removed. Each web browser implements different functionality, so please refer to the manuals or technical support resources that are available in conjunction with your web browser to learn the correct way to modify your cookies set-up. If you are using the (company name) Site/App in a jurisdiction where your prior consent is required for us to deploy any particular cookies, you will be asked to accept such cookies before they are deployed. Please note that disabling cookies or declining to accept certain cookies will prevent you from accessing some of the functionality and site offerings available via the (company name) Site/App.

This discloses the policy regarding how how the company collects and how it can use its cookies data

“Automatically Collected” Information: When you visit the (company name) Site/App or open one of our HTML emails, we may record certain information from your web browser by using different types of technology, including “clear gifs” or “web beacons.” This “automatically collected” information may include your Internet Protocol address (“IP Address”), web browser type, the web pages or sites that you visit just before or just after the (company name) Site/App, the pages you view on our site, and the dates and times that you visit.The Way [Company] Uses Information(company name) uses the information that we collect to provide to you all of the features and services found on the (company name) Site/App. We may use your email address for marketing purposes, unless you have expressly notified us that you prefer for us not to use your email address for any specific marketing purposes (“opt-out”). While you may opt-out from such marketing use, you may not opt-out from our use of your email address for non-marketing or administrative purposes such as automatic notifications of recent account activity, or notifying you of major site updates.

(company name) may use all of the information that we collect from our Users to understand the usage trends and preferences, to improve the way the (company name) Site/App works and looks, to improve our marketing and promotional efforts, and to create new features and functionality.
this explains how the policy regarding how information is automatically collected and the ways in which this is then used it should be noted that restrictions are placed on its use, such as for improving marketing. It does not state whether this data is passed onto 3rd parties, but if it is it would be restricted to the stated purposes.
As part of this process, we may use Google Analytics to provide us with aggregated information about how Users interact with the (company name) Site/App, and may set cookies and/or use web beacons for this purpose. The information gathered by the Google Analytics software (including any personal information about you) will be sent to Google where it will be stored and used by Google in accordance with its own privacy policy rather than ours. Please review the Google Privacy Policy http://www.google.com/policies/privacy/ or contact Google for more information.

(company name) allows other users to view your name, other profile details and photographs should you provide this information and make it publicly viewable.

(company name) may use automatically collected information and cookies information to: (a) remember your information so that you will not have to re-enter it during your visit or the next time you visit the (company name) Site/App; (b) provide custom, personalized advertisements, content and information; (c) monitor the effectiveness of our marketing campaigns; and (d) monitor aggregate usage metrics such as total number of visitors and pages viewed. (company name) will not use your email address or other personally identifiable information to send promotional or marketing messages except for those specific programs or features for which you will have the ability to opt-out.
this further states the purposes of automatically collected data and its ability to store it for future use.

When (company name) Discloses Information(company name) may disclose both personally identifiable and automatically collected information to affiliated companies or other businesses or persons to process such information on our behalf, to provide website maintenance and security, to offer certain features on the (company name) Site/App, to assist us in improving the way the (company name) Site works and looks, and to create new features. We require that these parties agree to process such information in compliance with our Privacy Policy, we use reasonable efforts to limit their use of such information, and we require these parties to use any other appropriate confidentiality and security measures. (company name) may share automatically collected and other aggregated non-personally-identifiable information with interested third parties for their use and distribution for their business purposes, including without limitation for the purposes of assisting them in understanding the usage patterns for certain content, services, advertisements, and promotions. We may share personally identifiable information with other third-party organizations for their marketing or promotional use without your consent, except with respect to any specific program or feature for which you will have the ability to opt-out. We may disclose your personally identifiable information if we believe in good faith that such disclosure is necessary to (a) comply with laws or to respond to subpoenas, court orders, warrants or other legal demands or to establish or defend (company name) from legal claims; or (b) to protect and defend our rights or property, you, or third parties from fraud, abuse or violations of the Terms of Service or illegal acts; or (c) to protect the safety or integrity of (company name), its users, the public or other parties as it is deemed appropriate, in our sole discretion. You hereby consent to our sharing your personally identifying information under the circumstances described herein. Except as otherwise noted in this Privacy Policy, (company name) does not share personal information about Users with third parties unless doing so is appropriate to carry out a User’s request or it reasonably believes that doing so is legally required or is in (company name)’ interest to protect its property or other legal rights or the rights or property of others.

This explains the ability to share with third parties. The stated purpose for this sharing is for their marketing or promotional use. It also states that personally identifiable information disclose if they believe in good faith that such disclosure is necessary for legal reasons.

User Profile and Password
You have access to your personal information and you may update, correct, or delete your member information and email preferences at any time. To protect your privacy and security, we take reasonable steps to verify your identity before granting Users profile access. YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR UNIQUE PASSWORD AND ACCOUNT INFORMATION AT ALL TIMES. PLEASE NOTE THAT WITH THE EXCEPTION OF CERTAIN CATEGORIES OF INFORMATION AS IDENTIFIED BY (COMPANY NAME) FROM TIME TO TIME, ALL INFORMATION THAT YOU POST FOR VIEWING ON THE (COMPANY NAME) SITE IS MADE PUBLICLY AVAILABLE TO ALL USERS OF THE (COMPANY NAME) SITE/APP.

This states the personal responsibility for users maintaining the secrecy of their own passwords.

Children
Consistent with the federal Children’s Online Privacy Protection Act of 1998 (COPPA), we do not intend to collect personally identifiable information from anyone under the age of thirteen (13). Any person who provides their personal information to [Company] through the [Company] Site represents that they are 13 years of age or older.

Choice/Opt-Out

(company name) Site/App provides you with the opportunity to affirmatively opt-out of receiving communications from us and our partners at the point where we request information about you. (company name) Site/App gives you the option to end our use of your information, and to cease receiving or otherwise having access to future communications or services. (opt out email address)

This allows for the opt out feature, which is essential to ensure customer satisfaction.

Our Commitment to Data Security
Third-party Advertisers, Links to Other Sites(company name) may allow other companies, called third-party ad servers or ad networks, to serve advertisements within the (company name) Site/App. These third-party ad servers or ad networks may use technology to send, directly to your browser, the advertisements and links that appear within the (company name) Site/App. They may automatically receive your IP Address when this happens. They may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize their advertising content. (company name) may provide personally identifiable information to these third-party ad servers or ad networks except as part of a specific program or feature for which you will have the ability to opt-in. Also, please note that if an advertiser asks (company name) to show an advertisement to a certain audience or audience segment and you respond to that advertisement, the advertiser or ad-server may conclude that you fit the description of the audience they were trying to reach. You should consult the respective privacy policies of these third-party ad servers or ad networks. (company name)’ Privacy Policy does not apply to, and we cannot control the activities of, such other ad servers or ad networks or their websites.

This allows for the ability of third party advertisers to place advertisements, including using data of users for audience segmentation. It also removes the liability of the company for the activities of these third parties.

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use secure server software (SSL) and firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be illegally or improperly accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software.

This removes liability for the security of transmitted information beyond the reasonable efforts made by the company.

If (company name) learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. By using the (company name) Site/App or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the (company name) Site/App. (company name) may post a notice on the (company name) Site/App if a security breach occurs. If this happens, you will need a web browser enabling you to view the (company name) Site/App. (company name) may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us via email at (company email address).

This provides for the warning of users in the event of a security systems breach.

Special Note to International Users
The (company name) Site/App is hosted in (country of operation). If you are a User accessing the (company name) Site/App from the other regions with laws or regulations governing personal data collection, use, and disclosure, that differ from the country of operation’s laws, please note that you are transferring your personal data to the country of operation which does not have the same data protection laws as the EU and other regions, and by providing your personal data you consent to:
• the use of your personal data for the uses identified above in accordance with the Privacy Policy; and
• the transfer of your personal data to the United States as indicated above.
YOU ACKNOWLEDGE THAT THE LAWS OF THE (COUNTRY OF OPERATION) TREAT YOUR INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR INFORMATION TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR INFORMATION WITH US, OR MAKE USE OF THIS WEBSITE. TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED, YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR IDENTIFYING INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISIDICTION OTHER THAN THE(COUTNRY OF OPERATION). HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE MEMBER STATES OF THE EUROPEAN UNION. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THIS FOREGOING WAIVER DOES NOT APPY TO YOU.

This is a disclaimer to users to ensure that they are aware that their privacy will be treated according to the country of the Site/App’s operation. It also ensures that the legal responsibility is in the hands of the user if they wish to gain an understanding of that country’s privacy laws.

In the Event of Merger or Sale If (company name) should ever file for bankruptcy or have its assets sold to or merge with another entity, information (company name) receives from you through the (company name) Site/App is an (company name) asset and may be transferred to another party; however, in the event of such a transfer, we will require that the transferee agree to honor this Privacy Policy, as it applies to Users prior to the effective date of any such transfer, unless we are legally prohibited from doing so. Changes and Updates to this Privacy Policy

(company name) reserves the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. Each time Company exercises such right, you shall be required to affirmatively accept the updated Privacy Policy, and if you fail to do so, you will no longer be able to access or use the (company name) Site/App.

This sets out the changes to users’ Privacy Policies in the event of a sale or merger.

Contacting (company name)If you have any questions, comments, or concerns about this Privacy Policy, please email us at (company email address) or write to us at:

(company name), Company address

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