A Cookie is a small piece of code that is sent from a website You browse, and stored in Your web browser. Cookies relay certain information to us or to third parties that enables us to: (a) recognize Your computer; (b) store Your preferences and settings; (c) understand the web pages You have visited; (d), enhance Your user experience by delivering content and advertisements specific to Your inferred interests; (e) perform searches and analytics; and (f) assist with security administrative functions.
Pixels or web beacons
Pixels or web beacons may also communicate information from Your Internet browser to a web server. Pixels can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from Your browser, check whether You have viewed a particular web page or email message, and determine, among other things, the time and date on which You viewed the Web beacon, the IP address of Your computer, and the URL of the web page from which the Web beacon was viewed.
We sometimes work with third parties to advertise, provide or complement our Services, and these partners may set and access their own Cookies, pixel tags and similar technologies on Your device. Likewise, if You receive email from us, we may use these technologies to capture data such as when You open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
The information collected and stored through these technologies includes IP address, unique identifiers, time stamps, browser type and other browser information, referring website, and more generally, what web pages You visit and how You interact with them, and what ads You view and how You interact with them. We and our partners, including Google Analytics, may also use these technologies for analyzing usage trends, assisting with fraud prevention, and providing certain features to You. To prevent Google Analytics from using Your information for analytics, You may install the Google Analytics Opt-out Browser Add-on by clicking here.
Twitter Tweet Button, Facebook Like Button and LinkedIn Button, YouTube and Instagram:
6. Notice Concerning Do-Not-Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. You can learn more about Do Not Track here.
7. Links to Other Sites
Our Website may contain links to other websites. Therefore, it is important that You know that our Privacy Statement does not extend to those third-party Websites, as their policy(ies) may differ from ours.
We have implemented administrative, technical, and physical security measures designed to protect against the loss, misuse, and/or alteration of Your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose Your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
Whenever we collect or process Your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, we will either deleted Your data completely or anonymized it, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
9. Data Transfers
Our computer systems are currently based in the both the United States and EEA and we may process and store Your information in one or both of these locations. As such, we may not provide the same level of protection as the privacy laws of Your jurisdiction. By providing us with Your information, You understand that Your personal information will be processed in the United States or the EEA.
Additionally, we will ensure, through contractual clauses that Your data receives at least the same protection as if it were being processed inside the US and EEA.
10. Your Choices and Rights
You can review and update certain information by contacting us as described below. You can unsubscribe from marketing emails by clicking the “unsubscribe” link they contain.
California Law permits visitors who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. To make such a request, please email us as described below with “Shine the Light” in the subject line or write to us at the contact information below.
11. Children’s Privacy
Our Website and services are intended for general audiences and not for children under the age of 13. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 13, we will take reasonable steps to delete it as soon as practical.
12. How to Contact Us
If You would like to limit the disclosure of any personal information we collect about children not related to the completion of a commercial transaction, please reach out to the contact above or email.
13. General Data Protection Regulation
The EU General Data Protection Regulation (or the “GDPR”) requires LIBERATE and those using our services to provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, Cookie identifiers, mobile device identifiers, precise location data and biometric data.
To comply with the GDPR, we provide the below representations and information, which are specific to persons located in EEA countries or Switzerland (so please don’t rely on the below, if You’re not):
a. Legal Grounds for Processing Your Personal Data
When we act as a “data controller”, the GDPR requires us to tell You about the legal basis we’re relying on to process any Personal Data about You. The legal basis for us processing Your Personal Data for the purposes set out in the “Types of Information We Collect and How We Use It” section above and will typically be because:
Legitimate Interests. In some cases, we use legitimate interest as a legal basis for processing Personal Data. We rely on legitimate interest when we use Personal Data to maintain the security of our services, and when we communicate with or otherwise manage our client data.
You provided Your consent.
Contractual Relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our client records and contact information);
Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.
b. Personal Data Retention
As a general matter, we retain Your Personal Data for as long as necessary to provide our Website and services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements, as well as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.
c. Your Rights as a Data Subject
The GDPR provides You with certain rights in respect of Personal Data that data controllers hold about You, including certain rights to access Personal Data, to request correction of the Personal Data, to withdraw Your consent where we process Your Personal Data pursuant to Your consent, to request to restrict or delete Personal Data, and to object to our processing of Your Personal Data (including profiling for online ad targeting). To exercise those rights, You may contact us as described above, in Section 12.
However, where we process Personal Data on behalf of a client (which is often the case), we may refer the request to the relevant client and cooperate with their handling of the request, subject to any special contractual arrangement with that client. Many of the rights described here are subject to significant limitations and exceptions under applicable law. For example, objections to the processing of Personal Data, and withdrawals of consent, typically will not have retroactive effect. You also have the right to lodge a complaint with a supervisory authority. However, we hope that You will first consult with us, so that we may work with You to resolve any complaint or concern You might have.
If You reside in the EU, following is a more detailed overview of Your rights under GDPR, if it applies to You.
You have the right to request:
Access to the personal data we hold about You, free of charge in most cases.
The correction of Your personal data when incorrect, out of date or incomplete.
That we stop using Your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of Your personal data after You withdraw that consent.
You can contact us to request to exercise these rights at any time by emailing info@Liberate.com.
If we choose not to take action on Your request we will explain to You the reasons for our refusal.
Your right to withdraw consent
Whenever You have given us Your consent to use Your personal data, You have the right to change Your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing Your personal data on the basis of our legitimate interest, You can ask us to stop for reasons connected to Your individual situation.
We must then do so unless we believe we have a legitimate overriding reason to continue processing Your personal data.
You have the right to stop the use of Your personal data for direct marketing activity through all channels, or selected channels. We must always comply with Your request.
Checking Your identity
If You have authorized a third party to submit a request on Your behalf, we will ask them to prove they have Your permission to act.
Contacting the Regulator – EEA UK and Switzerland Only
If You feel that Your data has not been handled correctly, or You are unhappy with our response to any requests You have made to us regarding the use of Your personal data, You have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)
If You are based outside the UK, You have the right to lodge Your complaint with the relevant data protection regulator in Your country of residence.
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