Last revised: 2/7/20 12:58 AM
Terms not defined herein shall have the meanings as set forth in terms of service (the “Agreement”). By using the website or Hoekenga & Machado, LLC services, you consent to the privacy practices described in this policy.
We reserve the right, at our sole discretion, to change, modify or otherwise alter this policy at any time. You can find the most recent version of this policy at http://www.hdmlegal.com/privacy, with the date of last modification noted above. Such modifications shall become effective immediately upon the posting thereof. Therefore, we encourage you to check the date of this policy whenever you use the application or access the site to check if they have been updated. You must review this policy on a regular basis to keep yourself apprised of any changes. If you do not agree to the revised policy, your sole recourse is to immediately stop all use of the website. Your continued use of the website following the posting of modifications will constitute your acceptance of the revised Policy. Should you have any questions regarding the use of the Policy, please contact us at the contact information listed at the end of this policy. None of our employees or agents has the authority to vary any of our policies.
Our Policy Towards Children
Our services are not directed to people under the age of 13. If you become aware that your child has provided us with personal information without your consent, please contact us at email@example.com. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information and terminate the child’s account. By using the website you are representing to us that you are not under the age of 13. If you are under 13 years of age, please do not use the website and immediately delete it from your user devices. We recommend that minors 13-18 years old ask their parents for permission before sending any information about themselves to anyone using the website.
I. WHAT KIND OF INFORMATION WE COLLECT
We collect the following types of information below whenever you use the website.
Personal Information. “Personal Information” is personally identifying information that you transmit or receive when you use the website which identifies you or your friends, such as names, emails, addresses, websites, telephone and fax numbers, files, content, photographs, or whatever information you transmit or receive using the website.
Session and Usage Data. “Session and Usage Data” is collected anonymously and includes, without limitation, all connection and service-related data submitted to us through your use of the application relating to the connection request, server communication and data sharing, including network measurements, quality of service, date, time and location of use. Session and usage data does not include personal information or content you may share through the website (Photos, Contacts, Calendar Appointments, Demographics, etc.). We use session and usage data to improve the functionality and features of the site. We also may aggregate session and usage data as described in aggregate information below.
We also collect personal information if you provide it to us via e-mail or the contact sections of the website. We may collect information that identifies you personally when you send us comments, questions or suggestions. Also, we automatically receive certain types of information whenever you interact with us or use our website. For example, our systems may automatically collect your IP address and the type of browser or operating system you use.
Aggregate Information. “Aggregate Information” is data we collect about a group or category of services or users from which individual user identities have been removed. In other words, information on how you use the website may be collected and combined with information about how others use the website, but no personal information will be included in the resulting data. Aggregate data helps us understand trends in our users’ needs so that we can better consider new features or otherwise tailor the website We may share aggregate information about our users with third parties for various purposes, including helping us better understand and improve our services, and for advertising and marketing purposes. This website uses Google Analytics and Google Search Console to better understand and service its users.
Security. The website developer, Tactical Success, LLC d/b/a Axon Digital Media Solutions, is very concerned about safeguarding the confidentiality of your personal information. We limit access to personal information to employees or contractors who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. Please be aware that no security measures that we take to protect your information are perfect or impenetrable.
II. HOW WE USE YOUR INFORMATION
For our internal business operations. In general, we use session and usage data internally to serve our users and enable them to take maximum advantage of the website. We also store personal information to improve the functionality of the website. All information collected is stored in our database and may be archived elsewhere. Access to your personal information other than session and usage data will be limited to our employees and contractors. If you use our “Share” feature to tell your friends about the website , your friends will be sent an email to invite them to visit the Site.
We may use information about you for our own internal purposes, such as to estimate our audience size, measure aggregate traffic patterns as well as to understand demographic, customer interest, and other trends among our users.
We may engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, database storage and management, and direct marketing campaigns. We will share your personal information with these third parties, but only to the extent necessary or useful to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.
Information about our users, including personal information, will be disclosed as part of any merger or acquisition, creation of a separate business to provide the site or the application, or fulfill products, sale or pledge of company assets as well as in the event of an insolvency, bankruptcy or receivership in which personal information would be transferred as one of the business assets of the company.
For marketing purposes. We do not disclose your personal information (other than aggregate information) to third parties for the third parties’ direct marketing purposes, unless you first affirmatively agree to that disclosure.
We do not rent, sell, or share personal information about you with other people or non-affiliated companies except to provide products or services you’ve requested, when we have your permission, or under the following circumstances: (i) as may be necessary to perform internal analyses and business functions; (ii) as part of a business transfer; or (iii) when required by law or permitted to protect our rights, property, or safety.
If you use the website, you consent to our collection of your session and usage data. We may use this information for internal analyses and external marketing purposes as described in this policy.
We may display targeted advertisements based on personal information. Advertisers (including ad serving companies) may assume that people who interact with, view, or click targeted ads meet the targeting criteria. For example, women ages 18-24 from a particular geographic area. We do not provide any personal information to the advertiser when you interact with or view a targeted ad. However, by interacting with or viewing an ad you are consenting to the possibility that the advertiser will assume that you meet the targeting criteria used to display the ad.
For legal enforcement. We may release your personal information in the good faith belief that release is appropriate and necessary to comply with legal process or authority (e.g., a lawful subpoena, warrant or court order); to enforce or apply our policies; to initiate, render, bill, and collect for amounts owed to us; to protect our rights, property, or personal safety, our users, our employees, or the public; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay. This may include sharing information with other companies, lawyers, courts or other government entities.
We may disclose information pursuant to subpoenas, court orders, or other requests (including criminal and civil matters) if we have a good faith belief that the response is required by law. This may include respecting requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law under the local laws in that jurisdiction, apply to users from that jurisdiction, and are consistent with generally accepted international standards.
III. THIRD-PARTY SITES
Please be aware that we may provide links to third-party websites, such as Facebook, as a service to our users. When you click on links of third parties on the website, you may leave the site. The site may also carry advertisements from other companies. We are not responsible for the privacy practices of websites operated by third parties that are linked to the website or for the privacy practices of third party or national Internet advertising companies, which differ from ours. You are solely responsible for reading and accepting their privacy and related policies.
III(A). FACEBOOK (VISITOR ACTION PIXEL)
We use the “visitor action pixels” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our website.
This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
III(B). GOOGLE ANALYTICS
We use Google Analytics only with IP anonymization enabled. This means that Google will truncate the IP address of users within Member States of the European Union or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.
The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent cookies from being stored by adjusting the settings to their browser software accordingly.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. Users can prevent the collection of data generated by cookies by downloading and installing the browser plug-in that is available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
III(C). GOOGLE MARKETING SERVICES
On our website we use the marketing and remarketing services of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). These services allow us to display advertisements in a more targeted manner in order to present advertisements of interest to users. Through remarketing ads and products are displayed to users relating to an interest established by activity on other websites within the Google Network. For these purposes, a code is used by Google when our website is accessed and what are referred to as (re)marketing tags are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies may also be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which apps users have visited, which content they are interested in and which offers have been used. In addition, technical information about the browser and operating system, referring websites, the length of the visit as well as any additional data about the use of the online products and services are stored. The IP address of users is also recorded, although we would like inform you that within the framework of Google Analytics, IP addresses within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area are truncated.
All user data will only be processed as pseudonymous data. Google does not store any names or e-mail addresses. All displayed ads are therefore not displayed specifically for a person, but for the owner of the cookie. This information is collected by Google and transmitted to and stored by servers in the USA.
One of the Google marketing services we use is the online advertising program Google AdWords. In the case of Google AdWords, each AdWords customer receives a different conversion cookie. Cookies can therefore not be tracked through the websites of AdWords customers. The information collected by the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they will not receive any information that personally identifies users.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. If you wish to object to interest-based advertising by Google marketing services, you can do so using the settings and opt-out options provided by Google: http://www.google.com/ads/preferences.
Google is certified under the Privacy Shield Agreement and thus guarantees its compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
IV. ACCESS AND CONTROL OF PERSONAL INFORMATION
You may view, correct, and request deletion of your personal information at any time. Generally, you should be careful when making any personal information available to the public. We reserve the right to send you certain communications relating to the website, such as customer service responses and other administrative messages. If you want to opt-out, download and install the extension for your web browser. In order to function, the opt-out extension must be able to load and execute properly on your browser. Updates to your browser or operating system may affect the functionality of the opt-out extension. More information about managing your extensions for Chrome can be found at https://support.google.com/chrome/answer/187443?hl=en. By installing this extension, you agree to the Chrome Web Store Terms of Service at https://ssl.gstatic.com/chrome/webstore/intl/en/gallery_tos.html and the Google Analytics Opt-out Browser Add-on Terms of Service at https://tools.google.com/dlpage/gaoptout/intl/en/eula_text.html.
V. INTERNATIONAL USERS
By using the website and providing us with data, you acknowledge and agree that we may use the data collected in the course of our relationship for the purposes identified in this policy or in our other communications with you, including the transmission of information outside your resident jurisdiction. Please note that your personal information will be stored and processed on our computers in the United States. The laws on holding personal data in the United States may be less stringent than the laws of your country. If you object to your personal information being transferred or used as described in this policy, please do not use the website and immediately delete it from your devices.
VI. YOUR PRIVACY RIGHTS – FOR CALIFORNIA RESIDENTS
We do not disclose your personal information to third parties for the third parties’ direct marketing purposes, unless you first affirmatively agree to that disclosure.
California Civil Code Section 1798.83 permits customers who are California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. If you would like more information with respect to your privacy rights under California law, you may contact us at the contact point below. Please reference your request as “California Disclosure Information.”
VII. CONTACTING US / REPORTING VIOLATIONS
If you have any questions or comments about this policy or our privacy practices, or to report any violations of the agreement or abuse of the application, please contact us at firstname.lastname@example.org.