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Effective Date: November 10, 2016
To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
1. What Information Does the Service Collect?
(a) Information You Provide to Us
(b) Information Collected or Stored As You Access and Use the Service
In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service ("Usage Information"). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a "Device") whenever you visit or interact with our Service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service, we will treat it as Personal Information.
We may use third-party services such as Google Analytics to better understand your online activity and provide you with information (including advertisements and product offerings) we believe may be of interest to you. You may exercise choices with respect to Google Analytics via the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.
This Usage Information may include: your IP address, UDID or other unique identifier ("Device Identifier"). A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier; your Device functionality (including browser, operating system, hardware, mobile network information); the URL that referred you to our Service; the areas within our Service that you visit and your activities there, including remembering you and your preferences; your Device location; your Device characteristics; and certain other Device data, including the time of day, among other information.
Tracking Technologies. We may use various methods and technologies to store or collect Usage Information ("Tracking Technologies"). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit the Service. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1×1 GIFs" or "clear GIFs") may be included in our Service's pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).
Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:
Tracking Technologies Choices.
We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed. With respect to cookies you may be able to choose to have your device warn you each time a cookie is being sent, or you may be able to turn off all cookies. You can do this through your browser settings. If you turn cookies off, some features of the Service may be disabled and the Service may not function properly,
You can find more information about cookies at websites such as www.allaboutcookies.org.
Third Party Tracking and Do Not Track.
Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies or other Tracking Technologies. For information on disabling Flash cookies go to Adobe's website www.adobe.com. Please be aware that if you disable or remove these technologies some parts of our Services may not work and that when you revisit our Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations. Further, App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of the App) can only be disabled by uninstalling the App. To uninstall an app, follow the instructions from your operating system or handset manufacturer.
Social Media Features.
The Site includes social media features, such as a Twitter feed. Actions you take in connection with social media features may be reflected in a manner visible to others; for example, if you "Like" us on Facebook, others may be able to see that you have done so.
Social Media Pages.
The collection and use of information on social media websites and applications is governed by their own privacy policies. Please remember that any information posted on Facebook or on other social media pages or channels such as Twitter or YouTube is public.
We may receive personal information from a social media site platform or application when you connect through a social media feed, post content, or otherwise interact with us using social media tools. For example, we may receive basic Facebook account information (name, e-mail, gender, birthday, current city, and profile picture URL) through a Facebook page. Also, when you "like," "subscribe to," or send a "tweet" to us through a social media channel, we may receive your username, handle, and any other available personal information from the social media site or application. All information we receive from social media sites and applications is treated and used in the same manner and for the same purposes as described in this Policy with respect to similar information we obtain through the Site.
Actions you take in connection with Social Media Sites may be reflected in a manner visible to others, for example, if you "Like" us on Facebook or follow us on Twitter, others may be able to see that you have done so.
(c) Information Third Parties Provide About You
(d) Interactions with Third-Party Service Providers
2. How Do We Use the Information Collected?
Contact Us. Please note that information submitted to any of the Services via a "contact us" or other similar customer inquiry function may not receive a response. We will not use the information provided by you in a customer inquiry communication to contact you for marketing purposes unrelated to your request unless you agree otherwise.
3. How and When Do We Share Information with Third Parties?
(a) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on our Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Service or link to them from our Service. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
(c) To Deliver Social Content and Advertising. We, and others we work with (e.g., third party publishers, advertisers and advertising services providers) may use your Personal Information, Demographic Information and/or Usage Information we have collected in connection with the Service to target and deliver content and advertisements to you and other users, both on and off of our Service. Further, by using the Service, you consent to the use of your Personal Information and your Service activity information (including regarding your content consumption) in, or in connection with, sponsored content and advertisements shown to your connections or other users. However, we may, from time to time, offer you options to manage this type of social sharing, and we will, make reasonable good faith efforts to respect settings. We do not guarantee that your setting selections will be effective immediately or be error free when delivering social content and advertisements.
(e) Affiliates and Business Transfer. We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates ("Affiliates"). We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
(g) EEOC / Affirmative Action Reporting. In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission ("EEOC"), the Office of Federal Contract Compliance Programs ("OFCCP") and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
(h) Your California Privacy Rights. California Civil Code Section 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us to, under certain circumstances, to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2016 will receive information about 2015 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing at: Howard M. Gitten, Locke Lorde LLP, 525 Okeechobee Blvd., Suite 1600, West Palm Beach, FL 33401
4. What About Information I Disclose Publicly Or To Others?
(a) User-Generated Content and Public Information. The Service may permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, "User Content"), such as on blogs and message boards. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that Roberts Group does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Service or what others do with information you share with them on the Service. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Service.
(b) Name and Likeness. We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.
5. Do Third-Party Content, Links To Third-Party Sites, and/or Third-Party Apps Appear on the Service?
The Service may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Service are served to you. In addition, when you are on the Service you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you "click" on a link, the "click" may take you off the Service onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies.
Third-party applications may also be available via the Service. The owners of these applications ("Third-Party Owners") may collect Personal Information and other data from you and may have their own policies and practices. We are not responsible for how Third-Party Owners or their applications collect or use your information and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. These Third-Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.
6. Are Ads Served On the Service?
The Service may use third parties such as network advertisers and ad exchanges to serve advertisements on the Service and may use third-party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Service and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your visits to the Service and other apps and sites you have visited. Third-party ad serving enables us to target advertisements to you for products and services in which you might be interested.
The Service's third-party ad network and exchange providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies (including Flash cookies), web beacons and other Tracking Technologies on your Device and track certain behavioral Usage Information regarding users of your Device via a Device Identifier. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities.
7. How Do I Change My Information and Communications Preferences?
8. What About Transfer of Information to the United States?
9. What Should Parents Know About Children?
We understand the importance of protecting children's privacy in the interactive world. We are a general audience service and do not use the Service to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children's Online Privacy Protection Act ("COPPA") without such parental consent. If you are a child under 13 years of age, you are not permitted to use the Service and should not send any information about yourself to us through the Service.
In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at the email: firstname.lastname@example.org.
10. What About Security?
We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. We recommend that you use caution when providing any information online.
The following third parties that collect information from you on or in connection with our Service have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows: NONE