(last modified March 27, 2015)
SYPartners LLC complies with the U.S.–E.U. and U.S.–Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union member countries or Switzerland. SYPartners LLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view SYPartners, LLC’s certification, please visit http://www.export.gov/safeharbor/.
Information We Collect.
We may collect personal data (including, without limitation, age, birthdate, address, email address, zip code, phone number, Facebook account information, and geographic location) from you. Such information is referred to as “Personally Identifiable Information”. We may collect Personally Identifiable Information in a variety of ways, including, without limitation, in the following circumstances: (i) registering for an account, (ii) participation in surveys, sweepstakes, contests, and promotions (“Surveys and Promotions”), (iii) contacting us, (iv) visiting and browsing our Digital Tools, and (v) using our online products and services.
Our Digital Tools may require you to register with us or a third party partner in order to use our services or access certain features of our Digital Tools. Information collected during the registration process may include Personally Identifiable Information as well as other information and data, including without limitation, your company name, company address and Digital Tools username and account password. We may also collect your IP address when you register and use our Digital Tools.
Surveys and Promotions.
We also collect certain information about you and your web browsing sessions if you participate in Surveys and Promotions, which allows us to coordinate the marketing support that allows us to continue to share our knowledge, insights, and opinions. Participation in Surveys and Promotions is optional. Should you choose to participate, the information we collect for Surveys and Promotions may include your name, phone number, address, zip code, e-mail address, IP address, the website that referred you to our Digital Tools, and other data.
You may also contact us by filling out and submitting a form through our Digital Tools, or by submitting feedback when you are logged in to our Digital Tools. When you contact us through our Digital Tools, your full name and email address are transmitted to us. Any other information you choose to include in the form you submit would also be transferred to and stored on our servers.
We also collect “Anonymous Information”, such as demographic information (like profession, age, gender, and number of children), traffic statistics and general usage patterns regarding page views and activity, dates and times you use our Digital Tools, the website that referred you to our Digital Tools, and the method by which you accessed our Digital Tools, files accessed through our Digital Tools, responses sent to the browser, the length of data sent to the browser, and other data used in the communication between browser and our Digital Tools. It is optional for you to provide demographic information (such as profession, age, gender, and number of children), but providing this information is encouraged so we can provide a more personalized experience on our Digital Tools. We may also collect information regarding data and personal anecdotes that you input on our Digital Tools (such as your “stuck moment”), which may include your name, phone number, address, zip code, e-mail address and other Personally Identifiable Information.
Information from Other Sources.
We may also supplement the information we collect with information from other sources to assist us in evaluating and improving our Digital Tools and services to determine your preferences so that we can tailor our Digital Tools and services to your needs, and/or to study behavioral questions in general.
Cookies and Action Tags.
Cookies are small pieces of information stored on your computer or mobile device with information about your visit to a particular site. We use both session ID cookies and persistent cookies. Session ID cookies are erased when you close your browser and do not last beyond one visit to our Digital Tools. Session cookies help us keep track of information such as what service or product you are searching for. A persistent cookie is a small file stored on your hard drive for an extended period of time. These cookies are used to remember items like your login information if you have elected to have it remembered on your computer or mobile device, and are used to target you for our Digital Tools.
Cookies may be used to:
- personalize your experience on our Digital Tools (e. g., to dynamically generate content on webpages specifically designed for you)
- assist you in using our services (e. g., to save you time by not having to reenter your name upon each visit to our Digital Tools)
- allow us to statistically monitor how you are using our Digital Tools for purposes of improving our online offerings.
In addition to cookies that we place on your computer or mobile device, cookies may also be placed on your computer or mobile device by third parties that we may use to display or serve advertisements or to collect Anonymous Information in order to provide advertising-related services. For example, in the course of serving advertisements, our third-party ad servers may place or recognize a unique “cookie” on your browser. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
In addition to cookies that we place on your computer or mobile device, cookies may also be placed on your computer or mobile device by third parties that we may use to display or serve advertisements or to collect Anonymous Information in order to provide advertising-related services. For example, in the course of serving advertisements, our third-party ad servers may place or recognize a unique “cookie” on your browser.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. If you reject the cookie, you may not be able to fully use all of the functionality of our Digital Tools. In particular, session ID cookies are required to store relevant information as a user moves from page to page. Persistent cookies enable us to track and target the interests of our users to enhance the experience on our Digital Tools.
“Action tags,” also known as web beacons or GIF tags, are a web technology used to help track Anonymous Information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of our Digital Tools, including advertisements, or e-mail sent on our behalf, may contain action tags. Unlike cookies, action tags are not placed on your computer or mobile device.
We collect information, some of which may be Personally Identifiable Information, that you voluntarily provide to us when you choose to use some of our online services (available either for free or on a subscription basis) such as the Community Areas.
Information is also collected when you use our mobile applications and other handheld products, including the software application needed to utilize our handheld products on your handheld device (the “Application”). During the installation of the Application and subsequent synchronizations, we collect Anonymous Information concerning your device (such as the specific type of operating system and hardware you have, and the amount of free and total memory) and the Application’s files on your device. We do not collect geo location data through our handheld products.
Our handheld products also collect information about your usage of the Application (such as the dates you last synced with the Internet or the dates you last used certain features). When you sync your device with our Digital Tools, we store some of this information.
How We Use the Information We Collect.
We use your Personally Identifiable Information to provide our services and to communicate with you regarding such services. We may also use your Personally Identifiable Information to provide information you have requested or products you have purchased to resolve disputes, collect fees, and troubleshoot problems. We also may use your Personally Identifiable Information: to respond to specific inquiries made by you; to prevent potentially prohibited or illegal activities, and enforce our Terms & Conditions; and to customize, measure, and improve our services content, and layout. In addition, we may analyze and use your Personally Identifiable Information and supplement it with other information we obtain to notify you and target advertising to you regarding special offers, products, services, and information that we think may be of interest to you, and to measure the advertising effectiveness of advertisements on our Digital Tools.
We use your Anonymous Information for the purposes of system administration, providing certain site functionality and content, targeted advertising, site tracking, and collecting and reporting aggregate usage information. We may combine Anonymous Information with your Personally Identifiable information to notify you of special offers and target advertising and other content to you.
We do not and will not, at any time, request your credit card information, your username, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is our top priority. For more information about phishing, you may want to visit the Federal Trade Commission’s website at http://www.consumer.ftc.gov/articles/0003-phishing.
Opt-in Emails, Text Messages and Offers.
By registering as a user of our Digital Tools, you automatically grant us permission to contact you at your e-mail address. If you are not a registered user of our Digital Tools, you may elect to receive updates from us about special offers, new services, and other noteworthy news items by contacting us at firstname.lastname@example.org. If you have opted-in to receive e-mails from us through either of the foregoing methods, to stop receiving e-mails from us, please see our opt-out policy described below. We will never sell, rent, or share your Personally Identifiable Information, including your email or phone number with any third parties for marketing purposes without your express permission. We may share your personal information with our service delivery providers for the purpose of delivering our email and text messages to your or as required by law.
Our users are given the opportunity to opt-out of emails and text messages to which they have previously opted-in, either through registering as a user of our digital tools or contacting us at email@example.com as described in the “Opt-in Emails, Text Messages and Offers” section above. This does not apply to emails that relate to our Digital Tools information, Terms & Conditions, your account and purchases or that are automatically generated by the system (registration confirmation emails). For example, even if you have unsubscribed from our promotional email messages, we will still send you confirmations when you purchase any of our products or services. Users who no longer wish to receive our promotional communications may opt-out of receiving these communications by clicking on the Unsubscribe link provided in emails.
Third Party Service Providers.
Email or Refer a Friend.
Through our referral tools for informing a friend about our Digital Tools, or one of our products or services, we will automatically send your friend a one-time email containing the information you request to be sent. If you elect to use these referral tools, we will collect from you certain Personally Identifiable Information about your friend which you have provided, such as your friend’s name and email address. We do not store your friend’s information or use it for any other purpose.
Social Media Widgets.
Compliance with Laws and Law Enforcement.
We may choose to disclose some or all of your Personally Identifiable Information to the government, law enforcement officials, or private parties if we, in our sole discretion, believe it necessary or appropriate to comply with the law, to respond to legal complaints, to comply with legal process (including subpoenas), to protect our rights or the rights of a third party, to ensure the safety of the public or any person, or to prevent or stop any illegal, unethical, or legally questionable activity. Although we make every effort to preserve your privacy, we may be required by law to disclose information you have provided in obtaining our services or using our Digital Tools. We may also disclose information against someone who poses a threat to our interests (such as customer fraud) or whose activities could bring harm to others.
Changes in Corporate Ownership.
If any or all of our assets are acquired by, or merged with, another entity, we will share some or all of your Personally Identifiable Information with that entity. You will be notified via email and/or a notice on our Digital Tools of any change in ownership, as well as any choices you may have regarding your personal information.
Accessing and Changing Your Information.
If you are a registered user of our Digital Tools, you may always access and modify your Personally Identifiable Information you provide through our self-service e-commerce platform by visiting the “sign in” area at the home page. To delete your information, contact us at firstname.lastname@example.org. You may or may not be able to modify the Personally Identifiable Information you provide through other parts of our Digital Tools.
You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our systems. The need to back-up our systems to protect information from inadvertent loss means that a copy of your Personally Identifiable Information may exist in a non-erasable form that will be difficult or impossible for us to locate. We promise that promptly after receiving your request, all Personally Identifiable Information stored in databases we actively use and other readily searchable media will be updated, corrected, changed, or deleted, as appropriate, as soon as reasonably practicable.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We place great importance on the safety and security of your Personally Identifiable Information. We employ certain physical, procedural, and technological measures in an attempt to protect your Personally Identifiable Information from unauthorized access and use. Although we do attempt to keep your Personally Identifiable Information secure, no security measures are perfect; there is always a possibility that a security breach could occur, resulting in the release of Personally Identifiable Information.
Links to Other Sites.
Our Policy re Children; Parental or Guardian Permission.
Our Website is not directed toward persons under 13 years of age. The Content on our Digital Tools may not be appropriate for children. CHILDREN UNDER THE AGE OF 13 ARE NOT PERMITTED TO USE OUR DIGITAL TOOLS, and we strongly recommend that children between the ages of 13 and 18 obtain their parent’s or guardian’s consent before viewing our Digital Tools.
If a parent or guardian becomes aware that his or her child has provided us with Personally Identifiable Information without their consent, he or she should contact us at email@example.com. If we become aware that a child under 13 has provided us with Personally Identifiable Information, we will remove such information from our files.
California Privacy Rights.
California Do Not Track Notice: Because there are not yet common, industry accepted “do not track” standards and systems, our Digital Tools do not respond to Do Not Track signals. In addition, we may allow third party service providers to collect personal data from your activity on or use of our Digital Tools, as described in the “Third Party Service Providers” section above.
California Disclosure Information: Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please e-mail us at: firstname.lastname@example.org, or write to us at: SYPartners LLC, attn: Dan Pardes, 475 Brannan Street, Suite 100, San Francisco, CA 94107, with a reference to California Disclosure Information.
We will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.
If you are a California resident and do not want your personal data to be shared with third parties for direct marketing by such third parties, please contact us at email@example.com to unsubscribe from future communications and information from such third parties. Opting out of receiving communications and information from our third party partners is not the same as opting out of our newsletter or other communications. To stop receiving communications from SYPartners, please see our opt-out policy described above.
SYP Holdings LLC
218 W. 18th St., 10th Floor
New York, NY 10011