Early Stage Agency Challenges: Preparation, Anticipation, Acceleration
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Thur, Nov 12, 2020 4:00 pm ET (1:00 pm PT)
Last Updated: April 22, 2020
Collection of Information
Traject collects information about you in several ways: information you directly provide to us, information we collect automatically when you use or access our Services, information collected from unaffiliated third parties or sources, and by using and combining personal data to derive additional personal data from or about you.
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services, fill out a form, participate in a contest or promotion, make a purchase, apply for a job, communicate with us via third party social media sites, request customer support or otherwise communicate with us.
The types of information we may collect include:
Information About Your Use of the Services
We collect information about your use of the Services, such as the search terms you enter, the pages and messages you click, etc.
Automatically Collected Information
When you access or use our Services, we automatically collect information about you, including:
Information We Collect from Other Sources
We may obtain information from other sources and combine that data with information we collect through our Services. For example, we use a third party to gather information to know how many users access a specific webpage and the links clicked.
Use of Information
We use the information we collect to identify and research opportunities and businesses that we may be interested in doing business with. We also use the information we collect to:
Sharing of Information
In the preceding 12 months we have disclosed the following categories of personal data for commercial or business purposes: (1) identifiers, (2) demographic information, (3) internet or other electronic network activity information, and (4) commercial information such as order history and marketing preferences. We have not sold any personal information to third parties for business or commercial purposes in the preceding 12 months.
We will not share data except in the following circumstances:
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
We will not sell, share, or rent your personal information to any third party. If we change this policy in the future, we will alert you and also provide individuals with an opt-out or opt-in choice before we share their data with third parties, or before we use it for a purpose other than which it was originally collected or subsequently authorized.
Social Sharing Features
The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button). Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please review your privacy settings and the privacy policies of the entities that provide these features.
Advertising and Analytics Services Provided by Others
Traject takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Transfer of Information to the U.S. and Other Countries
Traject is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries.
In compliance with the Privacy Shield Principles, Traject commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Traject at email@example.com.
Traject has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/ for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the FTC. If we share EEA Data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of EEA Data in violation of the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.
Rights Specific to the European Economic Area, United Kingdom, and Switzerland
If you are a resident of the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland (collectively “European Country” or “EC”), you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing
If you are a resident of an EC, when we process your personal data we will only do so in the following situations:
Data Subject Requests
If you are a resident of an EC, you may have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.
Questions or Complaints
If you are a resident of an EC and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your EEA local Data Protection Authority, please see http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. To contact the UK’s Information Commissioner’s Office (“ICO”), please see https://ico.org.uk/global/contact-us/. To contact the Swiss Federal Data Protection and Information Commissioner (“FDPIC”), please see https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html.
You may update, correct or delete information about you at any time emailing us at firstname.lastname@example.org. If you wish to delete or deactivate your account, please email us at email@example.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
In accordance with Privacy Shield principles, you may opt out of receiving promotional emails or text messages for purposes other than the services provided from Traject by following the email preference instructions in those emails or text messages, or by emailing us at firstname.lastname@example.org. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations. Please note that changes made to these communication preferences may take sufficient time to effectively reflect your changes.
Your California Privacy Rights
California law permits residents of California to request certain details about how their information is collected and shared. Your rights under California law include:
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Thur, Nov 12, 2020 4:00 pm ET (1:00 pm PT)