In order to access or use the Services (including the Platform), you must be at least eighteen (18) years of age and must be located in the United States.
The Types and Categories of Personal Information We Collect
Identifiers, such as your name, email address, and telephone number.
Information provided when you register for an account to use the Platform, including usernames and passwords.
Online Identifiers (For more information, see “Technical Data” below)
Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.
Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services.
Business Contact Data
Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.
Marketing and Communications Data
Information with respect to your marketing preferences and your subscriptions to our publications and alerts. You may opt out from email marketing at any time by using the “unsubscribe” feature within an email marketing communication or by contacting us in accordance with the “Contact Us” section below.
Communications with us (such as recordings of calls with customer service representatives for quality assurance and training purposes), and other communications that occur through the Platform.
Internet and Electronic Network Data
Data pertaining to your access or use of the Platform, including browsing history, search history, and information regarding your interaction with the Platform or advertisements embedded on the Platform or other third-party websites, and information derived from any device that connects to our WiFi services.
Information you provide about our Services, which may include data gathered from any the Company surveys or reviews submitted by you.
Information about the general city, state, or region in which a user of the Platform is located.
Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below)
If you apply for a job with the Company, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.
Health and Disability Data
You may furnish us with health-related information in the event we undertake health screening or accommodate a disability when you seek employment with us.
Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.
When you access the Platform, we collect certain data automatically using technical means and tools. This data relates to your device, as well as your experience on the Platform and other websites, including the following:
Usage and Device Data. When you access and use the Platform, we automatically collect details of your access to and use of the Platform, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Platform (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Platform may collect “diagnostic” data related to your use of the Platform, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.
Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Platform. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Platform may become inaccessible or not function properly. In addition, the Platform may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Platform (e.g., recording the popularity of certain content and verifying system and server integrity). The Platform may collect data about the advertisements you have seen or engaged.
Non-Cookie Technologies. We may deploy on our Platform certain types of “Non-Cookie Technologies” provided by our service providers to support our digital advertising programs. These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically or with additional data specifically requested from your browser or device. For more information, see https://thenai.org/wp-content/uploads/2021/07/NAI_BeyondCookies_NL.pdf.
Sources of Information
First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., registering accounts, completing purchases, signing up for subscriptions), when you provide a Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.
Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Platform (see “Technical Data” above).
Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references.
How We Use your Information / Purpose of Collection
We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests.
How Your Personal Information Is Used
Provide, operate, maintain, improve, and promote our Services.
Enable you to access and use our Services.
Process and complete transactions, and send you related information, including purchase confirmations and invoices.
Send you messages and communications related to our Services (e.g., responses to your comments, questions, and requests, customer services).
Furnish technical notices, updates, security alerts, and support and administrative messages to you about our Services.
Provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, contests, and events).
Monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests.
Investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities.
Personalize our Services, including providing features or advertisements that match your interests and preferences.
Comply with applicable laws, protect our rights and interests and the rights and interests of our customers and partners, participate in legal and administrative proceedings and regulatory processes, defend ourselves and our interests, and respond to law enforcement, other legal authorities, and requests that are part of a legal process.
Comply with applicable due diligence laws and requirements regarding security, anti-terrorism, anti-bribery, customs, immigration, and similar matters.
The Company may collect and use your personal information for any other purpose for which we obtain your consent.
Sharing Information / Third-Party Disclosures
Category of Recipient
Purpose of Disclosure
We may share personal data with our parent company, and our affiliates, and subsidiaries.
We share personal data with third parties in connection with the delivery of our Services (e.g., credit card processing, customer service, business analytics, fraud prevention, legal compliance services, and advertising and marketing).
We may share personal data with third parties that deliver our Services and marketing materials.
Circumstances may arise where, for strategic or other business reasons, we decide to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal data to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of our assets.
Legal; Compliance; Legitimate Interests
We may disclose personal data (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, we may disclose your personal data with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests.
In addition to the reasons for disclosure set forth herein, we may also disclose personal data you disclose upon your consent.
In the event that you facilitate a transaction with the Company, or request information from or otherwise engage with us, and such activities require the Company to share personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct the Company to intentionally disclose such personal information to the service provider or third party.
According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified. If you would like Platform Data related to you deleted or modified, please contacts us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.
Links to Other Websites; Your Direct Third-Party Disclosures
Data Retention and Localization
The Company is based in the United States, and the personal information that we collect and process is retained and stored in the United States. The Company uses service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in such other third countries
We seek to protect the security of personal information and use a variety of security technologies and procedures to help protect personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF PERSONAL INFORMATION DISCLOSED ON THE PLATFORM. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE PLATFORM AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately (and in any event within twenty-four (24) hours) if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.
No Data Collected from Children
The Platform is not directed at, nor intended for use by, children. As a result, if you are under the age of eighteen (18), you are prohibited from accessing or using the Services (including the Platform) or with providing us with your personal information.
Publicly Posted Information; Product Reviews
You may, from time to time, have the ability to submit via the Platform a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”). In other circumstances, you may directly provide us feedback on our business, our business sector, or the Services (“Feedback”). Any information or content you post in a Product Review or in your Feedback may be available to other users of the Platform (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review and Feedback to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review and Feedback that you wish to remain confidential. Any third party with access to your information via the Platform will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Platform is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. As between you and the Company, any and all Product Reviews and Feedback shall be considered our confidential and proprietary information. In order for the Company to utilize such Product Reviews and Feedback, you grant to the Company a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Product Reviews and Feedback in any manner we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of the Company’s and our sub-licensees’ products or services embodying such Product Reviews and Feedback in any manner and via any media we choose, without reference to the source. The Company shall be entitled to use Product Reviews and Feedback for any purpose without restriction or remuneration of any kind with respect to you and/or your representatives.
You are permitted, and hereby agree, to only provide personal information to the Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO the Company, YOU EXPRESSLY REPRESENT AND WARRANT TO the Company THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE the Company WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT the Company’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY the Company FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO the Company.
Updating Your Information
It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email), and you must do so when such changes are warranted. You may review, update, or modify your personal data, including profile and contact information, at any time by contacting us in accordance with the “Contact Us” section below.
Email Marketing and Your Rights
You have the right to opt out of receiving email political marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email political marketing communications from us. You may also unsubscribe from such email political marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify the Company, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.
Your State Privacy Rights
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
Colorado, Connecticut, and Virginia also provide their state residents with rights to:
- Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
- Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. The Company does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others.
If you would like to exercise any of these right, please contact us in accordance with the “Contact Us” section listed below.
Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.
Persons with Disabilities
Employment Applications and Talent Management
Changes to the Policy