Last Updated: January 1st 2020
What Information Is Collected?
Personally Identifiable Information: We collect Personally Identifiable Information (as defined below) only when you provide such information directly to us in connection with the Service. We ask for Personally Identifiable Information when you register for a User account with the Service, or if you correspond with us (in which case we will also retain our responses). We may also retain any messages you send through the Service, and may collect information you provide in User Content you post to the Service. We may receive Personally Identifiable Information about you from third parties. For example, if you access our websites or Service through a third-party connection or log-in, for example, through Facebook Connect, etc., that third party may pass certain information about your use of its service to Verbling. If you reside or are located in the EEA, it can also include your IP address or device identifier. This information could include any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our websites or Service. "Personally Identifiable Information" means any information that may be used to identify an individual, including, but not limited to, a first and last name, home or other physical address, an email address, phone number or other contact information. By using paid aspects of the Service, you may be required to share billing and payment information with our third-party payment processor, and you expressly agree to the use of your billing and payment information by any such third-party payment processor.
Non-Personally Identifiable Information: We also collect and use information about your interactions with the Service in a manner and format that does not identify you as an individual ("Non-Personally Identifiable Information"). We may collect, use, and disclose the following types of Non-Personally Identifiable Information:
Analytics information: We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, your browser's width and height, and other information that assists us in improving the Service. We may collect and use this analytics information together with your Personally Identifiable Information to build a broader profile of our individual Users so that we can serve you better.
Cookies information: When you visit the Service, we may send one or more cookies -- a small text file containing a string of alphanumeric characters -- to your computer that uniquely identifies your browser and lets Verbling help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.
Log file information: Log file information is automatically reported by your browser each time you access a web page. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.
Clear gifs/web beacons information: When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users anonymously. In addition, we may also use clear gifs in HTML-based emails sent to our Users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.
How Is Such Information Used?
Personally Identifiable Information: We may use the Personally Identifiable Information we collect or receive to communicate directly with you. We will occasionally email you updates about technology, announce new features, remind you of events, or inform you about other important news. You always have the option to unsubscribe to these messages. We also use your Personally Identifiable Information to send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related e-mails.
Is The Information Shared or Disclosed?
Personally Identifiable Information: We will not rent or sell your Personally Identifiable Information to third parties outside Verbling and its controlled subsidiaries and affiliates without your consent, except as noted below:
Who you may choose to share your Personally Identifiable Information with: Any Personal Identifiable Information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. We may use a third-party service provider to manage payment processing. By using paid aspects of the Service, you agree to share your billing and other payment information with any such third-party payment processor for the purpose of processing your payments.
What happens to your Personally Identifiable Information in the event of a change of control: We may buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personally Identifiable Information such as customer names and email addresses, User Content, and other User information (and Non-Personally Identifiable Information) related to the Service will likely be among the items transferred in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.
Non-Personally Identifiable Information: We may share Non-Personally Identifiable Information, including information obtained through tools such as cookies, log files, and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.): (i) in any manner permitted for Personally Identifiable Information; and (ii) with our third-party business partners. We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.
Updating or Deleting Your Personally Identifiable Information You have certain rights in relation to your Personally Identifiable Information. You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by logging into the Site and visiting your user account page. If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via email@example.com. If you reside or are located in the EEA, you have the right to request that we:
- provide access to any Personally Identifiable Information we hold about you;
- prevent the processing of your Personally Identifiable Information for direct-marketing purposes;
- update any Personally Identifiable Information which is out of date or incorrect; delete any Personally Identifiable Information which we are holding about you;
- restrict the way that we process your Personally Identifiable Information;
- provide your Personally Identifiable Information to a third party provider of services; or
- provide you with a copy of any Personally Identifiable Information which we hold about you. We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personally Identifiable Information. Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
Company does not knowingly collect or solicit Personally Identifiable Information from anyone under the age of 13 or knowingly allow such persons to register as Users. The Service and its content are not directed at children under the age of 13. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
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California Privacy Rights
Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities).
To obtain this information, please send an email message to email@example.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
Under the California Consumer Privacy Act (“CCPA”), California residents have the right to know what personal information about them is collected, request deletion of their personal data, opt-out of the sale of their personal data, and not be discriminated against if they choose to exercise any of these rights. Verbling does not sell any of the data we collect about you. If you’d like to exercise any of the other rights afforded to you, contact us at firstname.lastname@example.org.
EU Data Subjects
This section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein, Norway and, where applicable, Switzerland).
Verbling is the data controller of Personal Data provided to, or collected by or for, our Website and the Service, but we may act as data processor on behalf of our customers for Personal Data that we process on their behalf when providing the Service.
Subject to applicable law, you have the following rights in relation to your Personal Data:
Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies of the data, we may need to charge a reasonable fee.
Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so if we are processing your Personal Data for direct marketing and otherwise. However, if we are relying on a legitimate interest to process your Personal Data and we demonstrate compelling legitimate grounds for the processing we may continue.
Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, that produce a significant legal effect on you, unless such profiling in necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent.
Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to unsubscribe.
Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
You may exercise your rights by contacting via email@example.com.
Contacting Verbling Corporation