Last Revised February 8, 2017
BY USING THIS SITE OR SUBMITTING YOUR INFORMATION TO US YOU CONSENT TO THE TRANSFER OF YOUR INFORMATION AND TO OUR USE OF SUCH DATA AS OUTLINED IN THIS PRIVACY STATEMENT. IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT ACCESS OR USE THE SITE.
- Types of Information Collected
In order for us to deliver the level of service you expect from us online, we may gather two types of information from you: (a) personally identifiable information (defined below); and (b) non-personally identifiable information (defined below as “Traffic Data”).
- Personal Information Defined.
Personal identifiable information includes all of the information you voluntarily submit to us via your use of the Site, such as your: (i) contact data (ex. your name, job title, occupation, phone number, company name, company address, mailing and e-mail addresses); (ii) financial data (ex. your account or credit card number); and (iii) demographic data (ex. your zip code, age and income). Personally identifiable information may be gathered on this Site in several ways. First, at any time, we may require that you register to use this Site and create a user name and password. We may collect and store contact, financial and demographic data from you at that time. Such registration form information requests may change from time to time. Second, anytime you contact us for information (ex. Submitting a question via our “Request For Information” link), e-mail us for any reason or make a request for a product or service (ex. When you order the ErgoAccelerator™ Newsletter), we may require you to provide your name, e-mail address, company name, address and relevant financial data when appropriate. Finally, information you submit to us via surveys, questionnaires, chat groups, bulletin boards, forums, or other applications we make available on the Site will be treated consistent with all other personally identifiable information under this agreement.Remember, if you contact us for any reason, you are voluntarily releasing information to us and we may keep a record of that correspondence. You may choose to simply browse our Site and not provide us with any personal information. In such an event, you can still access and use much of the Site; however, you will not be able to access and use those portions of the Site or those functions on the site that require your personal information.
- Traffic Data Defined.
Like most web sites on the Internet, our Site automatically tracks and collects the following anonymous information when you visit, including your: (i) IP address; (ii) domain server; (iii) type of computer operating system (Mac or Windows); (iv) type of web browser (Netscape Navigator, Microsoft Explorer, etc.) and (v) the Internet Service Provider used to access the Site (collectively “Traffic Data”).
- Personal Information Defined.
- Uses of Information Collected
We use your Personal Information to provide you with the information, products and services you request. We may use your contact data to send you information about our company’s products or services, promotional material from some of our partners, checking your account status, or to contact you when necessary (exs. give you account status, online survey, changes to the Site, respond to your queries or requests, etc.). We may use your financial data to verify your qualifications for certain products or services and to bill you for products and services. We may use your demographic data to customize and tailor your experience on the Site, displaying content that we think you might be interested in and according to your preferences.We use the Traffic Data to enhance your experience on this Site. Specifically, we use the Traffic Data we automatically receive from your browser to see which pages our users visit within our site, which site our users may have visited before coming to ours, and where our users may go after they leave. We can then develop statistics that are very helpful to understanding how our visitors use this site. The statistical data allows us to present our users with more relevant content in a format our users will find most helpful. To be clear, this Traffic Data is anonymous information that does not personally identify you but is helpful for general marketing purposes and for improving your experience on the Site (i.e. troubleshooting and administration of the Site).
- Sharing of Personal Information
From time to time, we may share your Contact Data, on a limited and confidential basis, with our affiliates or trusted business partners who assist us in delivering our products and services to you or enhance our own product and services offerings. We otherwise do not share, lease, sell or voluntarily disclose any of your information to third parties for any purpose, except as otherwise set forth herein.
- User Choice Regarding Collection, Use and Distribution of Personal Information
You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Site; however you will not be able to access and use those portions of the Site that require your Personal Information. If you are receiving our newsletters or promotional e-mails from us, and do not wish to continuing receiving our newsletter or promotional material from us, you may “unsubscribe” from those services by sending an e-mail to us at firstname.lastname@example.org.
- Security and Confidentiality of Personal Information
Security is an important part of our Site. All of the information you provide to us in connection with the Site is stored on our secure servers and protected by firewalls. Access to our database is limited to specified employees and is monitored. Although we believe we exceed industry standard practices in protecting your privacy, due to the existing technological and legal environment, we cannot promise that your information or private communications can remain private one hundred percent of the time in ways not otherwise described in this Statement (ex. we cannot absolutely guarantee that our security measures will prevent third-party trespassers or “hackers” from illegally obtaining this information). Except as otherwise provided in this Privacy Statement, we will use commercially reasonable efforts to keep your personal information private and will not share it with third parties, except as set forth in section 3 above or unless such disclosure is necessary to: (a) comply with the law or other legal process ( for example, a court order, regulation, search warrant, subpoena, or administrative agency ruling, etc.); (b) protect our rights or property; or (c) enforce our Terms of Service.
- User Ability to Access, Update and Correct Personal Information
In order to ensure that all of your personal information is correct and up-to-date, at any time you may send us an e-mail at email@example.com.
- Lost or Stolen Information
You must promptly notify us if your credit card, user name or password is lost, stolen or used without permission. In such an event, we will cancel that credit card number, user name or password and update our records accordingly.
- Other Limits to Your Privacy
Like most sites on the Internet, this Site contains links to other Web sites not bound by our Statement. Once you select a link that takes you to one of these sites, we are not responsible for the privacy practices or the content of such third party Web sites. These third party Web sites have their own privacy practices and such practices may greatly differ from this one.We may also make chat rooms, forums, message boards, and news groups available to you. Please understand that any information you disclose in these areas becomes public information. We have no control over the use of your information in these mediums once you post it and you should therefore exercise caution when deciding to disclose your Personal Information or otherwise using such services.
- Updates and Changes to Privacy Statement, Site Maintenance
We reserve the right to modify this Policy at any time without prior notice. Any such change, update or modification will be effective immediately upon posting on this Site. Your continued use of the Site subsequent to changes to this Policy will mean that you accept the changes; therefore, you should bookmark this page and review it frequently.
Personal information that you voluntarily give us will be delivered electronically to computer servers located in the State of Michigan in the United States of America. Any legal issues you may have with us related to this Statement will be enforced in accordance with the laws of this jurisdiction and in the appropriate courts therein. Although this Site is intended for use by users located in the United States only, if you have accessed this Site, are located outside of the United States, and choose to use this Site anyway, you should be aware that all of your personal data will be processed by us in the U.S where data protection and privacy regulations may not offer the same level of protection as in other parts of the world.
- EU-U.S. Privacy Shield
This Personal Data Protection Policy (the “Policy”) applies to all Personal Data received by us in the United States from the EU and/or other applicable countries, recorded in any form (including electronic, paper or verbal).
The following definitions shall apply throughout this Policy:
“Agent” means any third party that uses Personal Data provided to us to perform tasks on behalf of and under the instructions of us.
“Personal Data” means Information or a set of information that identifies or could be used by or on behalf of us to identify an individual. Personal Data does not include information that is encoded, anonymous, aggregated or publicly available information that has not been combined with non-public Personal Data.
“Sensitive Personal Data” means Personal Data that reveals racial, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership or information that specifies the health or sex life of the individual. In addition, we will treat any information as Sensitive Personal Data which received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy are based on the Data Protection Directive and Privacy Shield Principles.
When we collect Personal Data directly from individuals in the EU and/or other applicable countries, we will inform them about the purposes for which we collect and use their Personal Data, the types of third parties (other than Agents), if any, to which we disclose that information, and the choices and means, if any, that we offer individuals for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to us, or as soon as practicable thereafter, and in any event before we use the information for a purpose other than that for which it was originally collected. If we receive Personal Data from our affiliates or other entities in the EU and other countries with which we do business, we will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such Personal Data relates.
We will offer individuals the opportunity to choose (opt-out) whether their Personal Data is (a) to be disclosed to a third party (other than an Agent), or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For Sensitive Personal Data, we will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to (a) the disclosure of the information to a third party, or (b) the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. We will provide individuals with reasonable methods to exercise their choices. We may disclose personal information to third parties in the following instances:
Website Consultants and Service Providers. We may disclose personal information to third party consultants and service providers (such as providers of hosting services, support, maintenance and remedial and repair services) to the extent that they require access to our databases, or the information contained in our databases, to service us and our customers under the conditions set out in the Principles.
Enforcement of Rights / Security. We reserve the right to release personal information (i) when we are under legal compulsion to do so (e.g. we have received a subpoena) or we otherwise believe that the law requires us to do so, (ii) when we believe it is necessary to protect and/or enforce the rights, property interests, or safety of us, our customers or others, or (iii) as we deem necessary to resolve disputes, troubleshoot problems, prevent fraud and/or enforce the Principles.
Reorganization or Sale. In the event that our company is merged with or becomes part of another organization, or in the event that our company is sold or it sells all or substantially all of its assets or is otherwise reorganized, the information you provide may be one of the transferred assets to the acquiring or reorganized entity.
As Otherwise Allowed by Law. We may transfer personal information to third parties where we are expressly authorized by applicable law and the Principles to do so. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
3. Accountability For Onward Transfers
We will obtain assurances from our Agents that they will safeguard Personal Data consistently with this policy. If we have knowledge that an Agent is using or disclosing Personal Data in a manner contrary to this policy, we will take reasonable steps to prevent or stop the use or disclosure. In cases of Onward Transfer we remain liable.
We will take reasonable precautions to protect Personal Data in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
5. Data Integrity & Purpose Limitation
We will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. We will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current.
Upon request, we will grant individuals reasonable access to Personal Data that we hold about them, and we will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
7. Resource, Enforcement And Liability
We will conduct compliance audits of our relevant privacy practices to verify adherence to this Policy. Any employee that we determine is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.
8. Dispute Resolution and Enforcement
Any questions or concerns regarding the use or disclosure of Personal Data should be directed to us at the address given below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the principles contained in this Policy within 45 days of receiving a complaint. For complaints that cannot be resolved between us and the complainant, we have agreed to participate in the dispute resolution procedures pursuant to the Privacy Shield Principles.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Should an individual be unable to resolve a complaint with us, they may contact the FTC at the following address:
Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
EU Persons (EU Data Subjects) may make complaints to their home data protection authority and can invoke binding arbitration for some residual claims not resolved by other redress mechanisms.
Questions or comments regarding this Policy should be submitted to us by mail or e-mail as follows:
Changes to Personal Data Protection Policy
This Policy may be amended from time to time, consistent with the requirements of the Data Protection Directive and/or Privacy Shield Principles. We will provide appropriate public notice about such amendments.
- Contacting Us
If you have any questions about this privacy statement, the practices of this site, or your dealings with this Site, you can e-mail us at firstname.lastname@example.org.