Effective December 01, 2018.
- On the Site.
- In emails, text, and other electronic messages between you and the Site.
- Other services offered on the Site.
WHAT INFORMATION WE COLLECT AND HOW WE COLLECT IT
Information You Voluntarily Provide to Us. The information we collect on or through our Site may include:
- Personal information (meaning information by itself or in combination that identifies or can identify an individual, such as name, physical address, email address, and phone number).
- Contact information (name, phone number, email address) when you fill out our Contact form, sign up for our “Tips & Best Practices” emails or register for a training course.
- Records and copies of your correspondence (including your email address), if you contact us.
- Your responses to surveys that we might ask you to complete for internal research purposes.
- Details of transactions you carry out through our Site and the fulfillment of any order you may place with us. (We use a third-party payment processor when, for example, you register for a training course or purchase any other product or service provided on the Site. Financial information you provide to the payment processor is subject to that third party’s terms and policies. We do not have access to this information at any time.)
Information We Automatically Collect About You. Our servers may automatically record certain information about how you when you access the Site, such as your Internet Protocol (IP) address, device and browser type, operating system, the pages or features of the Site that you viewed and the time spent on those pages or features, the frequency with which you use access the Site, search terms, the links that you click on or use, and other statistics. We collect this information in server logs and by using cookies to analyze trends, administer the Site, track users’ movements around the Site, or gather statistical information about our user base as a whole. There is no online behavioral advertising on the Site.
A cookie is a text file that is placed on your hard disk by a web page server. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. One the primary purposes of cookies is to improve the functionality of the Site, such as to pre-fill online order forms. The Site uses these “functionality” cookies. In addition, an “analytics” cookie is used to compile aggregate and statistical data about site traffic and site interaction so that we can offer a better website experience and tools in the future. Typically, “analytics” cookies do not need access to personal information for their operations. We may contract with third-party service providers to assist us in better understanding our Site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Site and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To protect our legitimate business interests.
- To notify you about changes to our Site or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Site.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may also use your personal information, such as an email address you provided, to send you offers or promotions about other goods and services from us that may be of interest to you. If you do not want us to use your personal information in this way, you can opt out at any time and at no cost. You can opt out by emailing us at: email@example.com
DISCLOSURE OF YOUR INFORMATION
- To fulfill the purpose for which you provide your personal information.
- To our subsidiaries and affiliates.
- To contractors, vendors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of OpFocus’s assets, including the lists of our users and subscribers.
- For any other purpose disclosed by us when you provide your personal information.
- With your consent.
We may also disclose your personal information:
- Comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of OpFocus, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We reserve the right to disclose aggregated or anonymous information (i.e., information that does not identify you) about our users without restriction.
ACCESS TO AND CORRECTION OF INFORMATION / OPT-OUT
We retain your personal information for as long as needed to provide you the requested services or information, to protect our legitimate business interests, comply with our legal obligations, resolve disputes and enforce applicable agreements. You may send us an email at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We can only process requests associated with the particular email address that you use to send us your request, and we need to verify your identity before implementing your request. We reserve the right not to accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Again, you can opt-out at any time and at no cost to receiving marketing or promotional emails from us by emailing us at email@example.com or by clicking on the “Unsubscribe” link at the bottom of these emails. We will process and honor such requests within 10 days after receipt. You can always choose not to disclose information. However, if you elect to do so, we will likely be limited in responding to your inquiry or providing services to you.
In accordance with Massachusetts Data Protection Law (201 CMR 17), we have implemented a Written Information Security Plan designed to protect personal information we collect from accidental low and from unauthorized access, use, alteration or disclosure. Any payment transactions will be encrypted using current SSL technology and are managed by a third-party payment processor.
Be advised that the transmission of information via the internet is not completely secure. Although We do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site, etc. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site and associated services.
LINKS TO OTHER SITES
The Site may contain links to other web sites and services. We do not control such third-party web sites and services and are not responsible for their actions or privacy practices. The existence of a link on our web site does not mean that we endorse or have vetted such third-party web site or service. You are encouraged to carefully review the policies and practices of every web site and service that you visit or use.
LOCATED IN THE UNITED STATES
We have an office and employees and operate in Canada. Accordingly, OpFocus takes appropriate steps to comply with applicable Canadian data privacy requirements, including the Canada’s Anti-Spam Legislation and the Personal Information Protection and Electronic Documents Act (PIPEDA).
For residents of the European Economic Area (EEA), OpFocus advises that your personal information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Our legal basis for collecting and using your personal information is to do so with your consent; where We need the personal information for performance of a contract or requested service, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If we collected your Personal Data with your consent, you may withdraw your consent at any time.
Residents of the EEA have the right to:
- Access your personal information;
- Delete, or request deletion of, your personal information;
- Object to or restrict processing of your personal information;
- Request portability of your personal information;
- Complain to your local data protection authority at any time;
- Object to automated decision making; and
- Update your personal Data.
Withdrawing your consent will not affect the lawfulness of any processing We conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
If We ask you to provide Personal Data to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your Personal information is required and if not, the consequences of not sharing your personal data with us.
Similarly, if OpFocus collects and uses your Personal Data in reliance on our or a third party’s legitimate interests and those interests are not already described above, We will let you know what those legitimate interests are.
To withdraw consent or exercise these rights, please:
- Contact us via email at firstname.lastname@example.org or
- Adjust your preferences through the Account preferences (if available).
We currently do not honor browser-based Do-Not-Track signals.
The Site and services are intended to be accessed and used by persons at least 18 years or older. OpFocus does knowingly not collect or maintain information on the Site or services from persons We know to be under age 13, and no part of our Site is designed to attract anyone under age 13. Please do not communicate with or contact Us if you are under age 13. If a child under the age of 13 has provided OpFocus with their personal information, we ask that their parent or guardian contact us as provided below to inform us of that fact. We will use reasonable efforts to delete such information from our systems and servers.
COMMENT AND QUESTIONS
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