Privacy Policy
Effective Date : 7 October 2022
Alta Reality, Inc (" Alta", " we", " us", or " our") provides a virtual reality gaming experience to you through our websites, https://www.altavr.io, https://townshiptale.com, the subdomains of each of the foregoing; and our game, A Township Tale® (the " Game"), (collectively with our websites, the " Services").
This Privacy Policy sets forth how we collect, use, protect, store, and otherwise process your personal information. This Policy does not apply to information we collect about you offline or the information collected by third parties, except as otherwise provided below.
Region-Specific Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions, or states. Please refer below for disclosures that may be applicable to you:
If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
If you are a resident of the State of Nevada in the United States, please click here for additional Nevada-specific privacy disclosures.
Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at contact@altavr.io
If you are located in the European Economic Area, UK or Switzerland, please click here for additional disclosures.
Our Collection of Personal Information
From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services and sometimes, we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.
Personal Information You Provide
We collect the following personal information from you in connection with our Services:
Purchase History, including your sale history in our Services.
Sensory Information, including your physical characteristics and data from your head and hand movements. Please note that this information is not stored.
User Generated Content, including content you create and share publicly, information you choose to reveal through our voice chat or other public-facing features on our Services, and information you provide to us through any correspondence when you contact us, submit an inquiry or complaint, or respond to our surveys or questionnaires.
Other Identifiable Information, including account number.
We may also collect information from you that does not generally identify you but may become associated with your account on our Services. We may use this non-identifying information for any permissible business purpose under applicable law.
Personal Information Automatically Collected
As is true of most digital platforms, we collect certain personal information automatically when you visit our Services, including:
Log File Information , including your internet protocol (IP) address, play history, running/loaded dynamic link library ("DLLs") on your computer or data gathered from a "small memory dump."
Analytics and Usage Information , including the electronic path you take to our Services, through our Services and when exiting our Services, as well as your usage and activity on our Services, such as the links and object you view, click or otherwise interact with (also known as "Clickstream Data").
Personal Information from Other Sources and Third Parties
We may receive the same types of personal information as described above from third parties that help us provide or facilitate your access to our Services. For example, we may receive your personal information from:
Game Platforms, including Oculus and Discord
Multi-player platform providers
Cloud computing providers
Payment platform providers
Data analytics providers
We do not control the personal information that third parties collect about you or how they use that personal information. You should review the privacy policy of each third party for more information about how they collect, use, and share your personal information they obtain and use.
Our Use of Personal Information
We use personal information we collect to:
Communicate with you, including via email
Conduct research and analytics.
Request that you provide us feedback about our Services.
Address inquiries or complaints made by or about an individual in connection with our Services,
Market our Services to you, including, with your prior consent, we may send you news and updates about our products and Services, including special offers and promotions, email.
Administer, improve, and personalize our Services, including by recognizing you and remembering your information when you return to our Services.
Develop, operate, improve, maintain, protect, and provide features and functionalities of our Services.
Create and maintain user accounts.
Identify and analyze how you use our Services, including through analysis of body movement and voice data, and Game play.
Test, enhance, update, and monitor the Services, or diagnose and fix technology problems.
Help maintain and enhance the safety, security and integrity of our property, platform, Services, technology assets, and business.
Defense, protect, and enforce our rights or applicable contracts and agreements.
Prevent, investigate, or provide notice of fraud or unlawful or criminal activity.
Comply with legal obligations, including with a sale or other transfer of our business or assets.
If you choose to contact us, we may need additional information to fulfill your request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request or personal information we require fall outside the scope of this Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.
Our Disclosure of Personal Information
We disclose personal information in the following ways:
To Other Users: We may share your personal information with other users. For example, we may share your voice or body movements through your online avatar, your display name, and any information you choose to make public.
To Service Providers : We engage other third parties to perform certain functions on our behalf in connection with the uses of personal information described in the Our Use of Personal Informationsection above. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf.
Advertisers and Publishers : We may, at some point in the future, engage in advertising both on our Services and through third-party services. Advertisers and publishers may share personal information with us in connection with our advertising efforts. For example, we may obtain information about whether an advertisement on our Services led to a successful engagement between you and a third-party advertiser.
To Other Businesses as Needed to Provide Services : We may share personal information with third parties that you engage with through our Services or as needed to fulfill a request or transaction including, for example, payment processing services, financing providers.
Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
in connection with the establishment, exercise, or defense of legal claims;
to comply with laws or to respond to lawful requests and legal process;
to protect the rights and property of us, our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
to detect, suppress, or prevent fraud;
to reduce credit risk and collect debts owed to us;
to protect the health and safety of us, our customers, or any person; or
as otherwise required by applicable law.
Consent: We may disclose personal information about you to certain other third parties with your consent.
Third-Party Websites
Our Services may include links to third-party websites, plug-ins, and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy policies.
Updates to This Privacy Policy
The Company reserves the right to change this Policy from time to time consistent with applicable law. If we make changes to this Policy, we will notify you by revising the date at the top of this Policy, and in some cases, we may provide you with additional notice (such as adding a statement in the Game or the homepages of our Services, or sending you an email notification).
Contact Us
If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to contact@altavr.io.
Alternatively, inquiries may be addressed to:
Alta Reality, Inc.
251 Little Falls Drive
Wilmington, Delaware 19808
+61 466 824 649
ALTA PRIVACY POLICY
ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES
[Last Updated]: 7 October 2022
Scope of Disclosures
These Additional California Privacy Disclosures (the " CA Disclosures") supplement the information contained in our Privacy Policy and apply solely to individual residents of the State of California ("consumers" or "you").
These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (" CCPA").
Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Policyor as otherwise defined in the CCPA.
Personal Information Disclosures
When we use the term "personal information" in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
For the purposes of these CA Disclosures, personal information does not include:
Publicly available information from government records.
Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
Information excluded from the CCPA's scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Information relating to our job applicants, employees, contractors, and other personnel
Collection and Use of Personal Information
In the last 12 months, we have not sold personal information about you, but we may have collected and disclosed for a business purpose the following categories of personal information described in the Our Collection of Personal Informationand Our Use of Personal Informationsections of our Privacy Policy:
Identifiers : such as your name, email address, username, postal address, IP address, cookies and similar technologies, and display name.
Customer Records Categories : Name, social security number, physical characteristics, address, telephone number, and credit or debit card number.
Protected Classification Characteristics : such as date of birth or age.
Commercial Information : such as your purchase history.
Sensory Information : We may receive your voice through your microphone and animation data derived from your head movement and hand movement.
Internet or Network** Information**: We may collect your play history, running/loaded dynamic link library ("DLLs") on your computer or data gathered from a "small memory dump."
Other** Information**: We may collect information from the content that you create and share publicly in the Game, and information you choose to reveal in the Game through voice chat or other public functions.
We may collect this information directly from you, from our business partners and affiliates, from your browser or device when you visit our Services, or from third parties that you permit to share information with us.
Disclosure and Sale of Personal Information
In the last 12 months, we have not sold personal information about you, and we have not disclosed for a business purpose the following categories of personal information.
Recipients of Personal Information
As described in the Our Disclosure of Personal Informationsection of the Privacy Policy, we share personal information within Alta and with a variety of third parties for business purposes.
In addition to the categories of third parties identified in the Our Disclosure of Personal Informationsection of the Privacy Policy, we disclose personal information to the following categories of third parties: Meta, Bytedance and Xsolla.
YOUR CALIFORNIA PRIVACY RIGHTS
As a California resident, you may be able to exercise the following rights (subject to certain limitations at law):
The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
The specific pieces of personal information we have collected about you;
The categories of personal information we have collected about you;
The categories of sources of the personal information;
The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
The categories of personal information we have sold and the categories of third parties to whom the information was sold; and
The business or commercial purposes for collecting or selling the personal information.
The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
How to Exercise Your California Privacy Rights
You may submit a request to exercise your California Consumer Rights by emailing us at contact@altavr.io.
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your membership, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email, address, member number, product website name, and/or date of last interaction with customer service.
In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.
Authorized Agents
In certain circumstances, California residents are permitted to use an authorized agent to submit requests to know or delete personal information on their behalf through the designated methods set forth in this Policy, where we can verify the authorized agent's authority to act on their behalf by:
receiving a power of attorney valid under the laws of California from the consumer or their authorized agent; or
receiving sufficient evidence to show that the consumer has:
provided the authorized agent signed permission to act on their behalf;
verified the consumer's own identity directly with us pursuant to the procedures set forth in this Policy; and
directly confirmed with us that the consumer provided the authorized agent permission to submit the request on their behalf.
Request Statistics
Clickherefor annual statistics about the requests to exercise California privacy rights we receive, fulfill, and deny.
Updates to These CA Disclosures
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions or requests in connection with this Policy or other privacy-related matters, please send an email to contact@altavr.io.
Alternatively, inquiries may be addressed to:
Alta Reality, Inc.
251 Little Falls Drive
Wilmington, Delaware 19808
ALTA PRIVACY POLICY
ADDITIONAL EUROPEAN PRIVACY DISCLOSURES
Effective Date: [DATE]
Unless otherwise expressly stated, capitalized terms in these Disclosures have the same meaning as defined in the Privacy Policy.
Scope of Disclosures
These Additional European Privacy Disclosures (the " European Disclosures") supplement the information contained in our Privacy Policy, but unlike the Privacy Policy, these Disclosures apply to the processing of personal data in the European Economic Area (" EEA"), the United Kingdom (" UK"), or Switzerland (collectively, our " European Services").
Alta Reality, Inc., headquartered in Australia, and doing business in the U.S. and Europe, is the data controller responsible for the collection and use of such personal data.
Personal Data Disclosures
When we use the term "personal data" in these European Disclosures, we mean any information relating to an identified or identifiable natural person, or as otherwise defined by "personal information" in our Privacy Policy.
Personal Data We Collect From You and How We Use It
We collect the categories of personal data that you voluntarily submit directly to us when you use our European Services, as set forth in our Privacy Policy under the Our Collection of Personal Information section. The table at Annex 1 sets out in detail the categories of personal data we collect about you and how we use that information when you use our European Services, as well as the legal basis on which we rely to process your personal data and recipients of that information.
We also automatically collect personal information indirectly about how you access and use our European Services, and information about the device you use to access the European Services. For example, we may collect:
Information about the Game features you use;
Information about your device (such as your IP address, device identifier, device type, model, and manufacturer); and
Information about your usage patterns (such as your play history or language settings).
We use this information to provide you with the features and functionality of the European Services, to monitor and improve the European Services, and develop new services.
The table at Annex 2 sets out further information about the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis on which we rely to process your personal data and recipients of that information.
You are not required to provide personal data to us, but we do rely on your personal data to provide certain of our services and products. For example, we need your personal data to facilitate and deliver an order that you request. If you choose not to provide us with your personal data, we may not be able to provide you with a service or product you request.
Data Retention
We retain personal data about you for as long as is necessary for the purposes set out in these European Disclosures, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.
The criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:
Legitimate Interests | Where we are processing personal data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects. |
Consent | Where we are processing personal data based on your consent, we generally will retain the information for the period of time necessary to fulfill the underlying agreement with you, subject to your right, under certain circumstances, to have certain of your data erased (please see the Your Privacy Rightssection below). |
Contract | Where we are processing personal data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship. |
Legal Obligation | Where we are processing personal data based on a legal obligation, we generally will retain the information for the period of time necessary to fulfil the legal obligation. |
Legal Claim | We may need to apply a "legal hold" that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved. |
In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.
Recipients of Personal Data
In addition to the recipients outlined in Annexes 1 and 2, we may also share your personal data with the following (As required in accordance with the uses set out in Annexes 1 and 2 ):
Service Providers: We may share your personal data with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
Affiliates: Other companies owned by or under common ownership as Alta Reality, including any subsidiaries, holding companies, or related companies. These companies will use your personal data in the same was as we can under these European Disclosures.
Law Enforcement, Regulators, and Other Parties for Legal Reasons : We may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to: (i) comply with the law and reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; or (iii) exercise or protect the rights, property, or personal safety of Alta, its users, or others.
Marketing And Advertising
From time to time we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our Services. Most marketing messages we may send will be by email. For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.
We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by updating your preferences via your account on our Services.
Storing And Transferring Your Personal Data
Security
We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal data we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting credit or debit card information or national identification numbers.
International Transfers of your Personal Data.
The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the EEA, UK or Switzerland, your personal data may be processed outside of those regions, including in Australia and the United States.
In the event of such a transfer, we ensure that: (i) the personal data is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.
If you wish to inquire further about these safeguards used, please contact us using the details set out at the end of these European Disclosures or the Contact Us section if our Privacy Policy.
Your Rights In Respect Of Your Personal Data
In accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold:
Right of access. You have the right to obtain:
confirmation of whether, and where, we are processing your personal data;
information about the categories of personal information we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;
information about the categories of recipients with whom we may share your personal data; and
a copy of the personal data we hold about you.
Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal data is not justified.
Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
Right to withdraw consent. There are certain circumstances where we require your consent to process your personal data. In these instances, and if you have provided consent, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.
You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
Where we rely on your consent for processing of your personal data, you have the right to withdraw your consent to such processing, subject to certain limitations at law. You may withdraw your consent in the following ways:
MEANS OF WITHDRAWING CONSENT: Please send an email to contact@altavr.io.
You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner's Office (https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html).
If you wish to exercise one of these rights, please email us at contact@altavr.io.
Due to the confidential nature of data processing, we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.
Cookies And Similar Technologies Used On Our European Services
Our European Services uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together "_ cookies _") to distinguish you from other users of our European Services. This helps us to provide you with a good experience when you browse our European Services and also allows us to monitor and analyze how you use and interact with our European Services so that we can continue to improve our European Services. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements.
Cookies are pieces of code that allow for personalization of our European Services experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes.
We use the following types of cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our European Services. They include, for example, cookies that enable you to log into secure areas of our European Services.
Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our European Services when they are using it. This helps us to improve the way our European Services works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognize you when you return to our European Services. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Advertising cookies. Advertising or targeting cookies store your visit to our European Service, the pages you have visited and the links you have followed. They are used to track visitors to different websites. We use this information to better tailor our European Services and the advertising displayed on it, as well as the marketing messages we send to you, to your interests. We may also share this information with third parties who provide services to us for this purpose.
Third party cookies. Please be aware that other third parties may use their own cookies tags when you click on a link on our European Services. These third parties are responsible for setting out their own cookie and privacy policies.
Please see Annex 3 for more information about the cookies we use on our European Services.
Other than strictly necessary cookies, which are required for the operation of our European Services, we will only place cookies on your device if you give us your consent to do so. We will ask you to tell us which cookies you agree to receive when you first access our European Services.
Most browsers also allow you to change your cookie settings to block certain cookies. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our European Services. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.
Cookie settings in Internet Explorer
Cookies settings in Safari web and iOS.
If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org.
Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.
Updates to These Disclosures
We may update these European Disclosures from time to time. When we make changes to these European Disclosures, we will change the "Last Updated" date at the beginning of these European Disclosures. If we make material changes to these European Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions or requests in connection with this these European Disclosures or other privacy-related matters, please send an email to contact@altavr.io.
Alternatively, inquiries may be addressed to:
Alta Reality, Inc.
251 Little Falls Drive
Wilmington, Delaware 19808
Annex 1 – Personal Data You Provide To Us
Category of Personal Data | Our Use of Personal Data | Legal Bases for Processing | Recipients of Personal Data |
---|---|---|---|
Identifiers | Emails, IPs, Usernames, cookies | Internal systems, Analytics providers | |
Sensory Information | hand controller and headset positioning and other VR related data | Internal only | |
Internet or Network Information | TCP and UDP network traffic | Internal systems and Cloud providers | |
Other Information | In game communications such as server names | Internal systems only |
Annex 2 – Personal Data Automatically Collected
Category of Personal Data | Our Use of Personal Data | Legal Bases for Processing | Recipients of Personal Data |
---|---|---|---|
Log files and information about your device. | Device specifications for analytics, log files for debugging the application |
ANNEX 3 – COOKIES
Cookie Name | Type of cookie | When is the cookie set? | How long does the cookie stay on my device? | Purpose of the cookie |
---|---|---|---|---|
Login Session | Strictly necessary | On login | 1 hour expiry before refresh | To persist log in state and user information of the logged in user |
Analytics Cookie | Analytics / Performance | On page first visit | Depends on browser | To learn about general user behaviors with our web services and identify trends so we can cater to user better |
Login Session | Functionality | On Login | 1 hour expiry before refresh | To persist log in state and user information of the logged in user |
ALTA COOKIE NOTICE
Effective Date : 7 October 2022
Prior versions of this Cookie Notice are available here.
Unless otherwise expressly stated, capitalized terms in this Notice have the same meaning as defined in the Privacy Policy.
Scope of Notice
This Cookie Notice supplements the information contained in the PrivacyPolicyby explaining how we and our business partners and services providers use cookies and related technologies in the course of managing and providing our online services and our communications to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.
In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information, please review the PrivacyPolicy.
What Are Cookies and Related Technologies
Cookies are small data files that are stored on your computer that allow us and our third-party partners and providers to collect certain information about your interactions with our email communications, websites, and other online services. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies, and logging technologies (collectively, "cookies").
What We Collect When Using Cookies
We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications, websites, and other online services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure usage and activity trends for our online services and better understand our customer base.
[Third-party partners and providers may also collect personal information about your online activities over time and across different websites when you use our websites and online services.]
How We Use That Information
We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and online services; (b) provide and monitor the effectiveness of our websites and online services; (c) monitor online usage and activities of our websites and online services; (d) diagnose errors and problems with our websites and online services; (e) otherwise plan for and enhance our online services; and (f) facilitate the purposes identified in the Our Use of Personal Informationsection of our Privacy Policy. We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver ads and information about products and services that may be of interest to you.
Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in our Privacy Policy.
Your Choices About Cookies
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our online services, as some features and services on our online services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
[You can learn more about Google's practices with Google Analytics by visiting Google's privacy policy here. You can also view Google's currently available opt-out options here.]
Updates to This Cookie Notice
We will update this Cookie Notice from time to time. When we make changes to this Cookie Notice, we will change the "Effective Date" date at the beginning of this Notice. If we make material changes to this Notice, we will notify through appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
4153-2617-2983.1 9999-20884