This Policy was last updated on August 12th, 2019.
HTHM Operations LLC (referred to herein as "we," "us," and "our") is committed to protecting the privacy and security of the personal information we receive and collect from you. We also believe in transparency, and we are committed to informing you about how we treat your personal information.
This Policy does not apply to (1) information collected by us offline, or (2) information collected through any third party (including our affiliates and subsidiaries) and any third party application, website, or content (including advertising) that may link to or be accessible from or on the Site.
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE WEBSITE.
BY USING, ACCESSING, VISITING, OR REGISTERING WITH THE SITE, OR BY SUBMITTING YOUR INFORMATION THROUGH IT, YOU CONSENT TO THIS POLICY AND TO OUR COLLECTION AND SHARING OF YOUR INFORMATION IN ACCORDANCE WITH THE TERMS OF THIS POLICY.
WHAT INFORMATION DO WE COLLECT?
We may collect and process the following personal information from you for the purposes set forth below:
Contact Information: When you visit the Site, request our services, or purchase products from us, we may ask you for your name, address, telephone number, email address, or other contact details in order to respond to your request or inquiry.
User Account Information: In order to access and use certain features of the Site, you must first complete a registration. When you create an account or register with us, we collect your contact information, other identity information (e.g., age, date of birth), other demographic information (location), username and password, and other registration information, including payment information. This information is necessary to enable us to provide you the account you have requested and to maintain the account and your profile. You may update your account information by editing the information associated with your account.
Business Information: When you seek services from us in the course of contractual or customer relationships between you, and/or your organization, and us, we may collect business contact information and other personal information in order to provide you with the services you have requested.
Cookies and Similar Technologies: Please see the Cookies and Similar Technologies section of this Policy below. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly.
Automated Information: When you visit our Site, we automatically collect information from your browser or your mobile device, which includes the date and time of your visit, your Internet Protocol (IP) address or unique device identifier, domain server, your browser type, cookies and data about which pages you visit in order to allow us to operate and provide the Site and our services. This information is used to understand how you interact with the Site and to provide you with advertising and a more personalized experience. To learn more about our collection of technical data, please see the Cookies and Similar Technologies section of this Policy below.
Email Interconnectivity: If you receive email communications from us, we may use certain tools to capture data related to if/when you open our message and if/when you click on any links or banners it contains. Other information collected through this email tracking feature includes: your email address, the date and time of your "click" on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page. We use this information to enhance our marketing efforts. We do not sell or distribute this information to third parties.
Feedback / Support / Inquiries: If you provide us with feedback or contact us for support or to ask us questions, we will collect your name, address, telephone number, email address, and other information needed to respond to your feedback, or request for support, or to answer your question.
Your Communications: When you communicate with us, we may retain your communications in order to process and respond to them, as well as to improve our services. We may use your email address to communicate with you about our services or send you periodic emails. If at any time you would like to unsubscribe from receiving future emails, you may unsubscribe.
Financial and Payment Information: If you choose to purchase goods or services from us, we may collect your name, address, telephone number, bank account number, bank routing information, and other data necessary to process payments, including credit card numbers, security codes, expiration dates, and other related billing information. By submitting your payment card information, you expressly consent to the sharing of your information with third-party payment processers and other third-party services (including but not limited to vendors who provide fraud detection services to us and other third parties). Please note that credit card numbers and account information are not stored on our servers.
Third Party Information: In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly-available sources.
Is entry of Personal Information required?
You may choose not to provide us with any personal information. Even if you choose not to provide any personal information, you may still access and use much of the Site. However, you will not be able to access any portions of the Site that require your personal information.
COOKIES AND SIMILAR TECHNOLOGIES
A "cookie" is a small file created by a web server that can be stored on a user's device for use either during a particular browsing session (a "session" cookie) or a future browsing session (a "persistent" cookie). This file may include information about your internet protocol (IP) addresses, browser type, internet service provider (ISP), URLs of any referring or exited webpages, operating system, and/or date and time stamps.
What similar technologies are in use and why do we use them?
Like most websites, as you navigate through and interact with the Site, we may passively collect information about your browsing activities using cookies and other automatic data collection technologies, such as Internet tags, web beacons (clear gifs., pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) in order to improve website functionality and analytics.
• Web beacons: These are tiny graphics with unique identifiers that are used to understand browsing activity. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are rendered invisible on web pages when you open a page.
• Social Widgets: These are buttons or icons provided by third-party social media providers that allow you to interact with social media services when you view a web page or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.
• UTM Codes: These are strings that can appear in a URL (the "Uniform Resource Locator," which is typically the http or https address entered to go to a web page) when a user moves from one web page or website to another, where the string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.
The aggregate data collected by these passive technologies typically does not target any personally identifying information, but personal information we store about you may be linked to information stored in and obtained from cookies in order to improve our marketing, analytics, or website functionality.
Google Analytics and Similar Technologies
Other Third Party Technologies
Some third parties may use automated data collection technologies to collect information about you when you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.
Choices About Cookies
When you visit the Site, it will prompt you to confirm whether you approve of the use of a cookie. You may adjust your browser settings to opt out of accepting a "persistent" cookie and to only accept "session" cookies, but you will need to log in each time you want to enjoy the full functionality of the Site.
Please be aware that adjusting the Cookie Settings on the Site may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your Cookie Settings on the Site.
HOW WE USE YOUR INFORMATION
We may collect and use the types of personal information listed above in an effort to improve your experience on the Site, to provide services to you, and to communicate with you about the information you have requested. We may also use personal information to help target specific offers to you and to help us develop and improve the Site and our services. Additionally, we may use your personal information in the following ways:
• To provide you with the services you have requested and to manage our relationship with you, including administering your account, processing payments, accounting, auditing, billing and collection and taking other steps necessary to the performance of our business relationship with you;
• To present and improve the Site's content and functionality;
• To personalize your experience (Your information helps us to better respond to your individual needs.)
• To improve customer service (Your information helps us to more effectively respond to your customer service requests and support needs.)
• To respond to visitor, subscriber, and customer inquiries;
• To determine user interests, needs, and preferences;
• To provide notice of changes to the Site or the services and products we offer or provide through it;
• To deliver services and products to you and honor our contract with you, including, but not limited to, providing you with access to updates and;
• To conduct research and analysis;
• To develop new products and services;
• To manage and maintain the security of the Site and our services;
• To market our services and products to you. We will only provide you with marketing-related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time. We do not sell or distribute this information to third parties or use it for any other purpose;
• To send periodic emails including information and updates pertaining to your order. We will also use your contact information to respond to your requests or inquiries. We may use your contact information to send you information about our company, including our affiliates, or our products or services, or to contact you when necessary. You may opt out of receiving emails by choosing to opt out on our Website.
SHARING AND DISCLOSING OF YOUR PERSONAL INFORMATION
We may share your information in the following contexts:
Subsidiaries and Acquisitions: We may share your personal information with our corporate subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents. In addition, we may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Site’s users is among the assets transferred. For example, if another company acquires us, we will share your personal information with that company.
Disclosures With Your Consent: We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent.
Disclosures Without Your Consent: We may disclose your personal information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our legal rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property or a violation of our Terms of Service.
Service Providers: We may share your personal information with our service providers that need access to your information to provide operational or other support services on our behalf. Among other things, service providers may help us to administer the Website, support our provision of services requested by you; provide technical support; send marketing, promotions and communications to you about our services; provide payment processing; and assist with other legitimate purposes permitted by law.
All such third-party service providers are required to maintain the confidentiality of your information and are prohibited from using your personal information except for the purposes for which we disclose it to them or as required by law.
Aggregated Data: We may disclose aggregated information about our users, and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, for new product and marketing development.
HOW LONG DO WE STORE YOUR PERSONAL INFORMATION?
We will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as long as necessary to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.
When we no longer have a purpose to retain your personal information, we will securely destroy your personal information in accordance with applicable law and our policies. We take reasonable steps to delete the personal information we collect if your registration to use the Site lapses and you opt out of receiving further communications from us, or if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. To the extent permitted by law, we may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.
HOW DO WE PROTECT YOUR INFORMATION?
We have put in place reasonable and appropriate security measures to protect the personal information that you share with us from being accidentally lost, used, altered, or disclosed or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technology and methods.
While our security measures seek to protect your personal information in our possession, no security system is perfect, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you do so at your own risk. We cannot promise that your personal information will remain absolutely secure in all circumstances. We are not responsible for circumvention of any privacy settings or security measures we provide.
The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone.
If a security breach causes an unauthorized intrusion into our Site or systems that compromises your data, we will notify you and any applicable regulator when we are required to do so by applicable law.
RIGHTS AND CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
Please use the Contact Us details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit, or delete your personal information or if you no longer want to receive any email, postal mail, or telephone contact from us or our affiliates in the future, such requests may be submitted via the Contact Us details at the end of this Policy.
Disclosure of Your Information for Third-Party Advertising. We do not share your personal information with unaffiliated third parties for promotional purposes.
Updating Your Personal Information. If any of the personal information you have provided to us changes, please let us know. For instance, if your email address changes, you may wish to cancel any request you have made of us; or, if you become aware of inaccurate personal information about you, you may use the "Contact Us" details provided at the end of this Policy to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
Right of Access. If required by law, upon request, we will grant reasonable access to the personal information that we hold about you.
Accuracy. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.
Right to Object. In certain circumstances, if permitted under applicable law, you have the right to object to processing of your personal information and to ask us to erase or restrict our use of your personal information. If you would like us to stop using your personal information, please contact us, and we will let you know if are able to agree to your request.
Right to Erasure and Deletion of Your Personal Information. You may have a legal right to request that we delete your personal information when it is no longer necessary for the purposes for which it was collected, or when, among other things, your personal information has been unlawfully processed. All deletion requests should be sent to the address noted in the Contact Us section of this Policy.
We may decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete personal information, it will be removed from our active servers and databases and the Site; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.
Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. To withdraw your consent, please notify us using the information in the Contact Us section of this Policy, and you may follow opt-out links on any marketing communications sent to you. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.
Right to Complain. If you believe that your rights relating to your personal information have been violated, you may lodge a complaint with the applicable enforcement authority, or seek a remedy through the courts. You may also lodge a complaint with us by contacting us using the information provided in the Contact Us section of this Policy.
Online Tracking. We do not currently recognize browser settings or signals of tracking preferences, which may include "Do Not Track" instructions. "Do Not Track" is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to "Do Not Track" signals on the Site or on third-party websites or online services where we may collect information.
California Residents. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our site may make any changes to their information at any time by contacting us at firstname.lastname@example.org.
THIRD PARTY SITES
This Policy is applicable only to the Site, and it does not apply to any third party websites.
The Site may contain links to, and media and other content from, third-party websites. These links are to external websites and third parties with which we have no relationship. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to the Site and which are to external, third party websites. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left this Site.
We cannot and do not (i) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (ii) control third parties’ independent collection or use or your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Site.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
We are committed to protecting the privacy of children. The Children’s Online Privacy Protection Act ("COPPA"), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Site and services are not directed to children aged 18 or younger, nor is information knowingly collected from children under the age of 18. No one under the age of 18 may access, browse, or use the Site or provide any information to or on the Site. If you are under 18, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, and username). If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 18, please contact us using the contact information provided below.
UPDATES AND CHANGES TO THIS POLICY
You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so you are aware of any changes. Your continued use of the Site after the "Last Modified" date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your PII according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, do not access, view, or use any part of the Site.
In Writing: HTHM Operations LLC, 289 Elm Street (Suite 104), Marlborough, Massachusetts 01752
By Telephone: +1 (617) 870-8128
By Email: email@example.com