Effective Date: July 1, 2020
If you are a California resident, additional information applicable to California residents is below in the Section titled “Your California Privacy Rights.”
1. INFORMATION COLLECTION
When you interact with us, we may ask you to supply us with information that expressly identifies you as an individual. For example, when you order your subscription online, subscribe to newsletters or promotional materials, fill out a survey, or otherwise use our service, we may ask you to provide information that personally identifies you (“Personal Information”) such as your name, email, mailing address, and phone number. If you share Personal Information, we will collect, use, and share it pursuant to this Policy and applicable law.
Although you may visit our Site without expressly providing us Personal Information, Personal Information is required to use certain Site features, for example, to request information online, contact us via email, phone, or our Contact Us form (where we may retain your message’s content and our response), and respond to communications from us (e.g. surveys and promotional offers).
Marketing Communications; Opt Out.
If you opt in to receive marketing communications from us, you may need to submit your name, email, and zip code. We use this data to send you promotional and other electronic communications. We may use third-party providers to deliver communications to you. You may opt out of such emails by using the unsubscribe link in the email or contacting us at email@example.com with “Unsubscribe” in the subject line. To opt out of other communications, please contact us. Opting out of marketing communications does not opt you out of communications related to transactions you request or enter into with us.
Payment Card Information.
When you make a purchase online, we use a PCI-compliant payment processor to help us facilitate payment. We have contracted with payment processors to help ensure they protect and limit the use of your Personal Information. We do not receive your credit card, debit card or other financial information when you make a payment as such information is provided directly to our payment processor. However, we do receive information about your purchase and your contact information (e.g. name, email address, mailing address, phone number). We will keep a record of your purchases and we may collect tax identification numbers you submit for tax-exempt purposes.
Sweepstakes & Contests.
We may offer sweepstakes or contests. To participate you must submit certain data, which may include your name, email, phone number, physical address, and other Personal Information. Data collected via sweepstakes and contests will be (i) used to contact you with promotional and related communications, (ii) shared with third-party vendors, and (iii) subject to additional terms provided to you at such time.
When you provide comments or feedback about our Site, the content on the Site, or our products or services ("Feedback"), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
IP Addresses, Cookies, & Similar Tracking Technologies.
When you use the Site, we and our Site vendors use technologies such as cookies (i.e., small pieces of data stored on your device’s hard drive by your browser), web beacons, pixel tags, and similar technologies to automatically collect internet protocol addresses assigned to the computers and other devices you use, your internet service provider, device ID number, approximate geographic location, browser type, Site pages visited, websites you access before and after visiting the Site, and data related to how and when you use the Site (e.g., date and time stamps, clickstream data, and data about search terms and websites that direct you to the Site). We may combine this collected data with other collected data (including Personal Information).
The Site may use session, persistent, and flash cookies (local stored objects) to collect and store data about your preferences and navigation to, from, and on our Site. Session cookies are used to complete transactions and for other purposes such as counting visits to certain webpages. Session cookies are eliminated when you exit your browser. Persistent cookies may be stored on your computer by your browser. When you log in, persistent cookies tell us if you have visited the Site before or if you are a new visitor.
Flash cookies differ from browser cookies regarding the amount and types of data collected and how the data is stored. Cookie management tools provided by your browser will not remove and cannot manage Flash cookies. To learn about managing your Flash cookie settings, visit the Flash player settings page on Adobe’s website here.
Most browsers automatically accept cookies. You can disable this function, but disabling cookies may impact your use and enjoyment of the Site.
Do Not Track Requests. Due to the automatic collection of data using cookies, we do not honor “do not track” requests.
We may occasionally enable and implement various analytics tools, such as Google Analytics, which is an analytics tool provided by Google to collect and process collected data consisting of certain telematics about your use of the Site. Google sets and reads cookies to collect such collected data and your web browser will automatically send such collected data to Google. Google uses this data to provide us with reports that we use to improve the Site’s structure and content.
Online Behavioral Advertising.
We may use advertising networks and services provided by third-party vendors. These services collect data about your interactions with the Site and other websites across the internet and use such data to target personal content and advertisements for goods and services. The collected data may be associated with your Personal Information. The targeted content and advertisements may appear on the Site and on other websites and may be sent to you via email. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables the delivery of advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.”
To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Your device may also include a feature (“Limit Ad Tracking” on iOS or either “Opt Out of Interest-Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through apps used for interest-based advertising purposes. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may occasionally still see our ads.
We are active on social media, including Facebook, Twitter, Pinterest, Instagram, and YouTube (“Social Media”). You may comment on Social Media regarding Altstream, our products and our services.
Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on our Social Media pages. You agree to hold Altstream and its affiliates harmless and without liability for the results of any and all content you post on Altstream’s Social Media.
Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
The Site may use advertising networks and services offered by Social Media to deliver advertising content. Use of these services requires Social Media to implement cookies or pixel tags to deliver ads to you while you access the Site.
Videos; Embedded Content.
2. USE OF PERSONAL INFORMATION
Our Use of Your Personal Information
We use any Personal Information or other information that you voluntarily provide to us to provide you with information, products, or services that you may request from us. We also use your Personal Information, either alone or in combination with other information, so that we can provide, enhance and personalize our Site and related content, products, and marketing efforts.
· to provide you with the best user experience possible;
· to provide the products and services you purchase, respond to your questions, and carry out the transactions you have requested;
· to communicate with you regarding Site updates, offers, orders, alerts, promotions, and events;
· to help us develop, customize, deliver, support and improve our Site, products, content, and advertising;
· to administer promotions and contests;
· to protect the rights or property of Altstream or our users, and prevent fraud and other prohibited or illegal activities;
· to process and respond to Digital Millennium Copyright Act (DMCA) complaints contemplated by our Terms of Service.
· to protect the security of our products, services, and business;
· for our internal purposes (such as auditing, data analysis, and research to improve our products, services, and communications); and
· otherwise, as disclosed to you at the point of collection.
If you decide at any time that you no longer wish to receive marketing or promotional communications from us, please follow any unsubscribe instructions that may be provided in our communications to you. Please note that we may use your Personal Information to contact you with important notifications, such as notices with respect to purchases, safety, or changes to our terms, conditions, and policies; you may not opt out of these notifications. If you have any questions or would like to remove your Personal Information from our databases, please let us know by contacting us at firstname.lastname@example.org and we will assist you with the process.
We may aggregate your Personal Information, either alone or with other data, to create anonymous “aggregate data” regarding the users of our Site. Aggregate data is information that describes the habits, usage patterns, or demographics of users as a group but does not reveal the identity of particular users. This data will not identify you but will be used by us internally as statistical information to determine such things as user demographics and usage patterns of our Website. We may use aggregate data to understand the needs of our community of users, to determine what kinds of programs and services we can help provide, and to improve and enrich our products, services, marketing, and Site content.
3. INFORMATION SHARING AND DISCLOSURE
Our Service Providers and Other Third Parties
Compliance with Laws, Legal Process and Authorities
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas and DMCA complaints), to protect the property and rights of us or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.
Circumstances may arise where, whether for strategic or other business reasons, we may sell, transfer or otherwise disclose some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. It is Altstream’s practice to seek protection for information in these types of transactions.
We do not sell, rent, or loan any of your Personal Information to any third party for money. Regardless, you may notify us at our designated request address below to opt-out of monetary sale of your information. Our designated request address for such requests is at email@example.com.
4. DATA RETENTION
We will keep Personal Information for the period necessary to fulfil the purposes described in this Policy, unless a longer retention period is permitted or required by law.
Data Transfer and Access from Outside the United States
Altstream processes personal information on our servers in the United States of America. If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.
Changing or Deleting Your Information
Altstream makes good faith efforts to provide individuals with reasonable access to Personal Information that they have provided to Altstream and the reasonable ability to review and correct it, as applicable. Access requests may be sent via e-mail to firstname.lastname@example.org. Please note we may retain server/backup copies of all such data, and that we may decline to process change requests that we deem to be unreasonable, or require disproportionate technical effort, or jeopardize the privacy of others.
We employ reasonable security measures to help protect your Personal Information from unauthorized access, alteration, disclosure, or destruction. These security measures include administrative, technical, and physical precautions to safeguard your Personal Information against loss, theft, and misuse. Please be advised, however, that while we strive to protect your Personal Information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction or inadvertent disclosure of your Personal Information.
Third Party Products and Services
Our products and services may contain links to, or content from, third party websites and other products and services. The fact that we link to a website or display an advertisement or other third party content is not an endorsement, authorization or representation of our affiliation with any of those third parties, nor is it an endorsement of their privacy or information security policies or practices.
We do not exercise control over third party websites, products or services including, without limitation, third party payment service providers. These other products and services may place their own cookies or other files on your computer or other device, collect data or solicit personal information from you. Other persons and entities, including, without limitation, third party payment processors, follow different rules regarding the use or disclosure of the information you submit to them or they collect from you. We encourage you to learn about the privacy practices of those third parties.
We do not knowingly collect Personal Information from children under 13 via our services, and do not target our online services to children under 13. We encourage parents and guardians to take an active role in their children’s online activities and interests.
Three Stamford Plaza
301 Tresser Blvd, 13th Fl
Stamford, CT 06901
6. CALIFORNIA PRIVACY RIGHTS
Subject to certain limitations, if you are a California resident you may make the following requests with regard to your Personal Information.
Right to Request Access. You have a right to request access to the following information: (a) the categories of Personal Information we collected about you in the prior 12-month period, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for which we collected your Personal Information, (d) the categories of Personal Information we disclosed in the prior 12-month period, and (e) the categories of third parties with whom we shared your Personal Information. You also have a right to request disclosure of the categories of Personal Information that we have sold or disclosed for a business purpose (each as defined by California law) in the prior 12-month period and the categories of third parties to whom that Personal Information was sold or disclosed.
Right to Request Disclosure. You have a right to request that we disclose to you the specific pieces of Personal Information that we have collected about you in the prior 12-month period.
Right to Request Deletion. You have a right to request that we delete Personal Information we collected about you.
Right to Opt-Out of Sales. You have a right to opt-out of the sale of your Personal Information. However, based on current California laws, we do not believe that we sell Personal Information. Furthermore, we do not believe that we have sold any Personal Information of an individual under 16 years of age, nor any other Personal Information in the last 12 months.
Non-discrimination. You have a right to exercise the above requests and we will not discriminate against you for exercising these rights.
How to Exercise Your Rights. To exercise your rights described in this Policy, you may submit your request to us by contacting us at:
Who May Exercise Your Rights. You may make a request to exercise the above rights on behalf of yourself or on behalf of a child if you are a parent or legal guardian of the child. In addition, you may authorize an agent to exercise your rights on your behalf, if you provide the agent with written permission and, if the agent is a business, the agent is registered with the California Secretary of State. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to act as your agent and to submit the particular request, unless the agent is subject to a Power of Attorney under California probate laws.
Verification of Your Request. Once we receive your request, we will contact you to confirm receipt of your request. In addition, we may contact you to provide us with additional information to allow us to verify your identity based on the Personal Information we have in our systems. In order to verify your request, you must provide sufficient information that allows us to reasonably verify you are the person that is the subject of the Personal Information you have requested or that you have the right to make the request as an agent. This information may vary depending on the Personal Information we already have. Certain types of requests may require additional verification to ensure you are who you say you are. If you have used an agent to make your request, we will also need to verify the identity of the agent. Verification of your request may require you, or your agent if applicable, to sign a declaration verifying identity under penalty of perjury. We may deny your request as permitted by law, if we are unable to verify your identity, or if an agent makes the request on your behalf, if we are unable to verify their identity or proof of their authorization.
When We Will Respond. We will confirm receipt of your request within 10 business days. We will try to respond to your request within 45 calendar days. If we require additional time to respond, we will inform you of the reason and may take an additional 45 calendar days to respond. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Based on the categories required by California law, below are the lists of Personal Information collected, where they are sourced, why they are collected, and if we disclose them, the categories of service providers or other third parties to whom we disclose them:
Although the categories of information above are collected for the designated purposes, Personal Information may be otherwise used for the purposes set forth in this Policy.