Effective Date: September 1, 2020
What Information We Collect
Personal Information We Collect Directly From You
The Personal Information we receive and collect directly from you includes, without limitation, the following:
(1) contact data (such as your e-mail address and phone number);
(2) demographic data (such as your gender, your date of birth and your zip code); and
(3) other identifying information that you voluntarily choose to provide to us, including without limitation unique identifiers, and Personal Information in emails or letters that you send to us.
We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent. You may still access our Site and use some of the Services if you choose not to provide us with any Personal Information, but if you elect not to share Personal Information it may affect our ability to provide you with certain portions of our Site or our Services.
Information From Third Party Sources
Some third parties, such as our business partners and service providers, provide us with Personal Information about you. If you interact with a third party service when using our Services or if you share content from our Services through a third party social media service, the third party service will send us certain information about you if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.
Information we automatically collect when you use our Services
Some information, which may include Personal Information, is automatically collected when you use our Services, such as the following: (i) IP address; (ii) domain server; (iii) type of device(s) used to access the Services; (iv) web browser(s) used to access the Services; (v) referring webpage or other source through which you accessed the Services; (vi) geolocation information; and (vii) other statistics and information associated with the interaction between your browser or device and the Services (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be Personal Information.
How We Collect Information
We collect information (including Personal Information and Traffic Data) when you use and interact with the Site and the Services, and in some cases from third party sources. Such means of collection include:
(1) When you use the Services’ interactive tools;
(2) When you voluntarily provide information in free-form text boxes through the Services;
(3) If you use the Services on our Site, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Service, such as information regarding when you are logged on and available to receive updates or alert notices;
(4) If you use a location-enabled browser, we may receive information about your location and mobile device, as applicable;
(5) Through cookies, web beacons, analytics services and other tracking technology (collectively, “Tracking Tools”), as described below; and
(6) When you contact us at email@example.com or otherwise contact us.
Tracking Tools, Behavioral Advertising, and Opt Out Options
Tracking Tools: We may use tools outlined below in order to provide our Services to, advertise to, and to better understand users.
Some cookies are placed by a third party on your device and provide information to us and third parties about your browsing habits (such as your visits to our Site and use of our Services, the pages you have visited, and the links and advertisements you have clicked). These cookies can be used to determine whether certain third party services are being used, to identify your interests, and to serve advertisements relevant to you. We do not control third party cookies.
(2) Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of our Services, the websites of selected advertisers and the emails, special promotions or newsletters that we send. The information collected by Web Beacons allows us to analyze how many people are using the Services, using selected publishers’ websites or opening emails, and for what purpose, and also allows us to enhance our interest-based advertising (discussed further below).
(3) Web Service Analytics: We may use third-party analytics services in connection with the Services, including, for example, to register mouse clicks, mouse movements, scrolling activity and text typed into the Site and/or Services. We use the information collected from these services to help make the Services easier to use and as otherwise set forth in the “How We Use Your Information” section below. These analytics services generally do not collect Personal Information unless you voluntarily provide it and generally do not track your browsing habits across web services that do not use their services.
(4) Mobile Device Identifiers: As with other Tracking Tools, mobile device identifiers help OX learn more about our users’ demographics and internet behaviors in order to personalize and improve the Services. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location) and Traffic Data.
Behavioral Advertising: We may use a type of advertising commonly known as interest-based or online behavioral advertising. This means that some of our partners use Tracking Tools, such as cookies, pixel tags, and web beacons, to collect information about a user’s online activities to display OX ads to the user based on the user’s interests (“Behavioral Advertising”). Such partners may include third-party service providers, advertisers, advertising networks or platforms, traffic measurement service providers, marketing analytics service providers, and other third party service providers (collectively, “Advertising Service Providers”). Other Tracking Tools used by our partners may collect information when you use the Services, such as IP address, mobile device ID, operating system, browser, web page interactions, geographic location and demographic information, such as gender and age range. These Tracking Tools help OX learn more about our users’ demographics and internet behaviors.
Options for Opting out of Cookies and Mobile Device Identifiers: Some web browsers allow you to reject cookies or to alert you when a Cookie is placed on your computer, tablet or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept OX’s cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.
You may opt out of receiving certain cookies and certain trackers by visiting the Network Advertising Initiative (NAI) opt out page or the Digital Advertising Alliance (DAA) consumer opt-out page, or by installing the DAA’s AppChoice app (for iOS; for Android) on your mobile computing device. When you use these opt-out features, an “opt-out” Cookie will be placed on your computer, tablet or mobile computing device indicating that you do not want to receive interest-based advertising from NAI or DAA member companies. If you delete cookies on your computer, tablet or mobile computing device, you may need to opt out again.
For information about how to opt out of interest-based advertising on mobile devices, please visit http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device. You will need to opt out of each browser and device for which you desire to apply these opt-out features.
Even after opting out of Behavioral Advertising, you may still see OX advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that OX is no longer using Tracking Tools — OX still may collect information about your use of the Services even after you have opted out of Behavioral Advertising and may still serve advertisements to you via the Services based on information it collects via the Services.
How OX Responds to Browser “Do Not Track” (DNT) Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to web services that a visitor does not want to have his/her online activity and behavior tracked. If a web service operator elects to respond to a particular DNT signal, the web service operator may refrain from collecting certain Personal Information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many web service operators, including OX, do not proactively respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.
Our Legal Bases; Our Legitimate Interests and How We Use Your Information
We rely on a number of legal bases when you access or use the Services and we collect, use, share, and otherwise process your personal information for the purposes described in this policy. These legal bases include where:
(1) Necessary to provide the Services to you;
(2) You have consented to the processing, which you can revoke at any time;
(3) Necessary to comply with a legal obligation, a court order, or to exercise or defend any impending or asserted legal claims;
(4) Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners (described in more detail below);
(5) You have expressly made the information public;
(6) Necessary in the public interest, such as to prevent crime; and
(7) Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).
How We Use Your Information and Our Legitimate Interests
We may use information that is not Personal Information (including Personal Information that has been de-identified and/or aggregated) to better understand who uses our Site and Services and how we can deliver a better client experience or otherwise at our discretion.
We use information, including Personal Information, to provide the Services and to help improve the Services, to develop new services, and to advertise (for example, to display OX ads on other web services). Specifically, such use may include:
(1) Providing you with the products, services and information you request;
(2) Responding to correspondence that we receive from you;
(3) Contacting you when necessary or requested;
(4) Providing, maintaining, administering or expanding the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
(5) Customizing or tailoring your experience of the Services, which may include sending customized messages or showing you Sponsored Results;
(6) Sending you information about OX or our products or Services;
(7) Sending emails and other communications that display content that we think will interest you and according to your preferences;
(9) Showing you advertisements, including interest-based or online behavioral advertising;
(10) Using statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
(11) Fulfilling our legally required obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities;
(12) Resolving disputes;
(13) Protecting against or deterring fraudulent, illegal, or harmful actions; and
(14) Enforcing our other agreements.
How We Share Your Information
In certain circumstances, and in order to perform the Services, we may share certain information that we collect from you, as described in this section:
(1) Third Parties: We may share your Personal Information obtained through your use of our Site and/or Services with third parties. For example, we use a third-party social sharing tool called AddThis that allows you to share news articles or job postings.
(2) We do not sell email addresses to third parties. We may share your Personal Information with our partners to customize or display our advertising.
(3) We may share your Personal Information and/or Traffic Data with our partners who perform operational services (such as hosting, billing, fulfillment, data storage, security, web service analytics, or ad serving) and/or who make certain services, features or functionality available to our users.
(4) Cross Device Matching: To determine if users have interacted with content across multiple devices and to match such devices, we work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we also provide de-identified data to these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of Services across devices.
(5) Business Transfers: We may transfer your Personal Information to another company in connection with a proposed merger, sale, acquisition or other change of ownership or control by or of OX (whether in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
(6) Public Information and Submissions: You agree that any information that you may reveal in a review posting, online discussion or forum (such as comments to our Better By blog) is intended for the public and is not in any way private. Carefully consider whether to disclose any Personal Information in any public posting or forum. Your submissions may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.
(7) Protection of OX and Others: We also may need to disclose your Personal Information or any other information we collect about you if we determine in good faith that such disclosure is needed to: (1) comply with or fulfill our obligations under applicable law, regulation, court order or other legal process; (2) protect the rights, property or safety of you, OX or another party; (3) enforce the Agreement or other agreements with you; or (4) respond to claims that any posting or other content violates third-party rights.
(8) Other Information: We may disclose information that is not Personal Information at our discretion.
Storage and Security of Information
The security of your Personal Information is important to us. We endeavor to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and in storage. For example, when you enter sensitive information on our Site and/or our Services, we encrypt that information (both at rest and in transit) using Secure Socket Layer (SSL) technology.
We store and process your information on our servers in the United States. We maintain industry standard backup and archival systems.
Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, we do not and cannot guarantee the security of your Personal Information. If at any time during or after our relationship we believe that the security of your Personal Information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us. If you are unsure of the email address we have for you, please contact us at firstname.lastname@example.org. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at email@example.com. Please include your address when you submit your request. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.
Your Privacy Choices
You can always opt not to disclose information to us, but keep in mind some information may be needed to use certain features of our Site and our Services.
Note that OX cannot control or guarantee these rights with regard to Personal Information obtained by third parties who have requested and received your Personal Information through our Services and with your consent.
We believe it is important for you to be able to: (1) find out what Personal Information you have provided to us through our Services; (2) update your information; or (3) “opt-out” of receiving future marketing communications. To inquire about your Personal Information, update your Personal Information, or “opt-out” of receiving future marketing communications or any other collection or use practice based on your consent, please send an email with your request to firstname.lastname@example.org. Please include your complete name, e-mail address and mailing address. Note that it may take up to fourteen (14) business days to remove you from our marketing lists and after this point, you may still receive customer service-related communications from us.
GDPR and CCPA
You may have certain rights to your Personal Information as a result of privacy laws around the world, such as the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). If those laws apply to you, OX gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct the Personal Information that OX retains about you, please send an email with your request to email@example.com . You may also remove certain optional information that you no longer wish to be available through the Services, such as your name. You can also request to permanently delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.
(1) Right to Access & Portability: You can request access certain Personal Information that OX retains about you and request a copy of that Personal Information in an easily accessible format and information explaining how that information is used by send an email with your request to firstname.lastname@example.org.
(2) Right to Correction: You have the right to request that we rectify inaccurate information about you by send an email with your request to email@example.com.
(3) Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
(4) Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of OX.
(5) Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications.
(6) Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or by send an email with your request to firstname.lastname@example.org.
If you are a resident of California, the CCPA provides you the following additional rights:
(1) Right to Know: if you are a California resident, you may request disclosure of the specific pieces and/or categories of personal information that we have collected about you, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed about you, and the categories of third parties with which the information was shared.
(2) Right to Opt-Out: To the extent that OX “sells” personal information (as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (which can be done to by contact us at email@example.com).
How Long We Retain Your Information
Please note, OX does not dictate how long third parties retain your Personal Information obtained through our Services. Each of those parties will have their own privacy policies and retention periods and you should review those policies.
Personal Information of Children and Information Provided on Behalf Others
The Services are not intended for use by children and children under the age of 13 are prohibited from using the Services. OX does not knowingly collect any information from children, nor are the Services directed to children.
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