ALEXANDER BABBAGE INC
- We collect offline.
- Collected on any third party apps, services or websites, including websites you may access through the Services.
- You provide to, or that is collected by, any third-party data controller.
Those third parties may have their own privacy policies, which we encourage you to read before providing information to or through them. We do not accept any responsibility or liability for their privacy policies or any information you provide to or through them.
Please note that if you choose not to provide us with your information, we may not be able to provide some or all of the Services or respond to your other requests.
2. DATA CONTROLLER
A “data controller” is a person or organization who alone (or jointly) determines the purposes for which, and the way that, any personal information is, or is likely to be, processed. Alexander Babbage is the data controller of your personal information collected through or otherwise provided to the Services.
3. INFORMATION WE COLLECT AND HOW WE COLLECT IT
3.1. Categories of Information
When you use the Services, the categories of personal information about you that we collect may include:
- Your contact information (such as your name, work email address and telephone number).
- Your business information (such as the name, size, and location of your company).
- Other personal profile information.
- Your mobile device and (when enabled) your location information.
- Information about you provided by our customers.
- Other information provided by third parties.
- Any information you may choose to provide when you fill out a “free text” box on forms available through the Services (for example, your comments and opinions that you express when you participate in a survey, comment on a blog post or other content posted through the Services, or when you contact us by email, mail or phone).
If you are a resident of the European Union (EU), please consult Attachment 1 for more information on the categories of personal information we collect about you when you use the Services, how (for which purpose) we use that information, and the legal basis on which we rely to process the information.
3.2. Information You Provide to Us
When you download, register with, access or use the Services, or when you otherwise contact us, we may ask you to provide, or you may voluntarily provide, information, including personal information, to provide you with Services or the support you request.
- Account information: An Alexander Babbage account is required for certain features of the Services. If you register for an Alexander Babbage account, we may require certain information, such as your first and last name, email address, and password.
- Additional Profile Information: You may choose to provide us certain additional information as part of your Alexander Babbage account profile.
- Other Information You Provide: You may choose to voluntarily provide additional information to us (for example, by filling out and submitting online and other forms for events, webinars, or whitepapers; responding to surveys; participating in contests, promotions or other marketing activities; providing suggestions or improvements; posting User Content via the Services or applications; or which you otherwise choose to submit through the Services).
3.3. Information Automatically Collected and Tracked
When you download, access, or use the Services, they may use technology to automatically collect information, including personal information, about the Services and how you use them.
- Usage Details. When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services.
- Device Information. We may collect information about your device (including mobile, computer, wearable or other devices) and internet connection, including the device’s unique identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
- Stored Information and Files. The Services may also access metadata and other information associated with other files stored on your device.
- Location Information. The Services may collect information about the location of your device.
- Behavioral Information: We also may use technologies to collect information about your activities over time and across third-party websites, apps, or other online services, a practice which is often called behavioral or interest-based tracking.
The technologies we use for automatic information collection may include:
- Web Beacons. Certain pages or Sites in the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, or single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
- Flash Local Shared Objects (LSOs). When we post videos or other media on the Services, third parties may use LSOs, also known as Flash cookies, to store your choices for things like volume control or to further personalize certain features. Cookie management tools provided by your browser will not delete Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, visit the guide here.
We use the information collected automatically to present the Services to you on your device; to determine news, alerts and other products and services that may be of interest to you for marketing purposes; to monitor, support and improve the Services and our business; and to help us develop new products and services. If you are a resident of the EU, please consult Attachment 2 for more information on the categories of personal information we collect about you when you use the Services, how (for which purpose) we use that information, and the legal basis on which we rely to process the information.
Please note that certain unique identifiers used to track usage information of our Services will remain the same even after you delete cookies and web data, reset the data associated with the application, and uninstall or reinstall the Service. These unique identifiers consist of a number or an alphanumeric string and may be unique to your device, but do not include personal information.
3.4. Information We Collect from Third Parties
We may collect information, including personal information, that others provide about you when they use the Services, or obtain information from other sources (including social media networks) and combine that with information we collect through the Services. Any information request regarding the disclosure of your personal information to us by these third parties should be directed to them.
- Third Party Services. When you use the Services or any content made available through the Services, certain third parties may use automatic information collection and tracking technologies to collect information about you or your device. These third parties may include advertisers, ad networks, and ad servers; analytics companies; your mobile device manufacturer; your mobile service provider; and other third parties. We do not control third parties’ collection or use of your information to serve advertisements tailored to your interests or preferences (often called interest-based advertising). This information varies and is controlled by those third-party services or as authorized by you via your privacy settings with those services.
- Marketing Service Providers/Customers/Business Partners. We may also receive information collected by our marketing service providers on our behalf, including marketing lead generation service providers, databases, marketing opt-in lists or other data aggregators, as well as information shared with us by our customers and business partners.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data, identity or account verification information, or fraud detection information, from third party service providers and/or partners, and combine it with other information we have about you.
4. HOW WE USE YOUR INFORMATION
This section (Section 4) describes in general terms how we use your personal information. Please see Attachment 1 for more detailed information on the categories of personal information we collect about you when you use the Services, how (for which purpose) we use that information, as well as the legal basis on which we rely to process the information.
4.2. Provide Our Services
We use your personal information to provide or facilitate:
- Access to, and use and support of, the Services.
- Payment processing and account management.
- Order fulfillment.
- Customer service and support.
- Updates, security alerts, and account notifications.
- Other services requested by you as described when we collect the information.
4.3. Understand and Improve Our Services
We use your personal information to analyze, operate improve, and customize the Services and user experience, such as by performing data analytics and studying how the Services are used.
4.4. Administer and Protect the Services
We use your personal information to administer and protect the Services, including to:
- Prevent, detect, investigate, and mitigate fraud, security incidents, abuse, or other potentially harmful or illegal activities.
- Maintain the network and information security to protect information against loss, damage, theft or unauthorized access.
- Perform troubleshooting, testing, and system maintenance.
- Conduct security investigations and risk assessments.
- Verify your identity.
- Conduct checks against databases and other information sources, to the extent permitted by applicable laws and with your consent where required.
4.5. Legal and Contractual
We use your personal information for legal and contractual purposes, including to:
- Comply with our legal and contractual obligations, including managing legal and regulatory requests and requirements.
- Resolve any disputes with any of our users and enforce our agreements with third parties.
4.6. Provide and Improve Our Marketing
We use your personal information to:
- Send you promotional messages, marketing, advertising, and other information that we think may be of interest to you.
- Personalize, measure, and improve our marketing and advertising.
- Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Alexander Babbage or its third-party partners.
- Analyze, operate, protect, improve, and customize the Services and user experience, such as by performing data analytics and studying how the Services are used.
Generally, and unless you are a resident of the European Economic Area (EEA), we do not rely on your consent as a basis for processing your personal information other than in relation to sending third-party direct marketing communications to you via email or text message. Where we collect your personal information with consent, you may withdraw your consent for us to use your information at any time by unsubscribing, managing your preferences through your account, following any instructions provided in our communication with you, or contacting us (See “Your Choices About our Marketing Activities” below).
5. DISCLOSURE OF YOUR PERSONAL INFORMATION
We will only share personal information collected through the Services as follows:
- With your consent.
- To contractors, service providers, and other third parties we use to support our Services, and only for the purposes for which we disclose it to them.
- To our corporate family of companies that are related by common ownership or control, to enable or support us in providing the Services.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Alexander Babbage’s assets, whether as a going concern or as part of bankruptcy, insolvency, liquidation, or similar proceeding, in which personal information held by Alexander Babbage about the Services and users are among the assets transferred.
- To third parties to market their products or services to you if you have consented to or not opted out of these disclosures.
- For any other purpose disclosed by us when you provide the information.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our customers or others.
- We may also share aggregated information (information about our users that is combined so that it no longer identifies an individual user) and other pseudonymized or anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
6. YOUR CHOICES ABOUT OUR MARKETING ACTIVITIES
6.1. Marketing Communications for Non-EEA Residents
From time to time, you may receive marketing communications from us if you have requested information from us or purchased services from us and, in each case (unless you are a resident of the European Economic Area), you have not opted out of receiving such communications. If you are a resident of the EEA, you will not receive such communications from us unless you have specifically opted in to receive them, as described further in Section 6.4 (EEA Residents) below. In any case, most such communications we send will be by email. For some communications, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
You can ask us to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org, or by using the contact information set forth below.
6.3. Third Party Marketing
We will get your express opt-in consent before we share your personal information with any company outside Alexander Babbage for marketing purposes.
6.4. EEA Residents
If you are resident in the EEA, we will send you marketing messages only if you have given us your consent to do so. If you do not want to receive messages from us, you will be able to tell us by taking certain actions on forms or screens we use when we first collect your contact details or by refusing or withdrawing your consent after you have provided it. You can also change your preferences later by clicking on the unsubscribe link at the bottom of our messages or by emailing us at email@example.com.
6.5. Non-Marketing Messages
Please note that if you do opt out of or do not grant (or withdraw) consent to receiving marketing-related messages from us, we may still send you non-marketing messages.
6.6. Affiliate Usage
7. INTEREST-BASED ADVERTISING
7.1. Interest-Based Advertising
7.2. Online Resources
To learn about interest-based advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Network Advertising Initiative (NAI) online resources currently available at http://www.networkadvertising.org/choices, the Digital Advertising Alliance (DAA) resources currently available at www.aboutads.info/choices, or Your Online Choices, currently available at www.youronlinechoices.com/uk. Please note that opting out of receiving interest-based advertising through the NAI, DAA, or Your Online Choices online resources will only opt out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use. In addition, some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt out again.
8. USER CONTENT
9. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION
If you are resident in the European Economic Area (EEA), under the General Data Protection Regulation (GDPR), you have the following rights in respect of your personal information that we hold:
- Right of access. You have the right to obtain:
- confirmation of whether, and where, we are processing your personal information;
- information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
- information about the categories of recipients with whom we may share your personal information; and
- a copy of the personal information we hold about you.
- Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information 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 information to another person.
- Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information 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 information 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 information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
- Right to object. You have a 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 information, and we will assess and inform you if that is the case. You can object to the user of your personal information in connection with marketing activities for any reason.
If you are resident in France, you also have the right to set guidelines for the retention and communication of your personal information after your death.
10. DATA RETENTION
We will retain your personal information for no longer than necessary for the purposes for which it was collected (as described in further detail in Attachments 1 and 2), and if necessary to comply with our legal obligations and legitimate business interests. If you no longer want us to use your personal information to provide the Services to you, you may request that we erase your personal information and close your account. Please be aware that because we maintain the Services so as to protect information from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
11. DATA SECURITY
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. If you have any questions about the security of our Services, please contact us at firstname.lastname@example.org.
12. CHILDREN UNDER THE AGE OF 16
The Services are not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email@example.com or by using the contact information set forth below.
13. YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Information regarding the information we collect and how it is used is described in Attachment 3. To make such a request, please contact us at firstname.lastname@example.org.
14. INTERNATIONAL DATA TRANSFER
Your personal information may be transferred to, stored, and processed in the United States or a country that is not regarded as providing the same level of protection for personal information as the laws of your home country. By using the Services, you consent to the transfer of your personal information to countries outside your country of residence, including the United States, whose protection of personal information may differ from that offered by your country of residence. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information.
Whenever we transfer the personal information of individuals resident in the European Economic Area (EEA) to countries outside the EEA, we extend a similar degree of protection to that information by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.
- Where we use certain service providers, we may use specific contractual provisions approved by the European Commission which give personal information the same protection it has in the EEA.
You have the right to lodge complaints about the data processing activities carried out by Alexander Babbage before your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. In addition, residents in other jurisdictions may also have similar rights to the above. Please contact us at email@example.com if you would like to exercise one of these rights, and we will comply with your request to the extent required under applicable law.
PERSONAL INFORMATION WE COLLECT WHEN YOU USE THE SERVICES
We generally rely on the following three main bases to process your personal information:
- for our legitimate interests or those of a third party, where your rights and interests do not override those interests; or
- to comply with a legal or regulatory obligation.
Sometimes, we may rely on other legal bases to process your information, such as where you have given us consent to use your personal information in certain ways or to protect a user’s vital interest. We also may process your personal information relying on more than one legal basis, depending on the specific purpose for which we are using your personal information.
The table below provides further details on the categories of information we collect about you when you use the Services, how (for which purpose) we use that information, and the legal basis we rely on to process that information. You can also contact us at firstname.lastname@example.org for more information about the specific legal ground we are relying on to process your personal information where more than one ground has been set forth below.
|Category of Personal Information||How We Use It (Purpose of Use)||Legal Basis for Processing|
| Contact information
Personal information, such as your name, phone number, address, and email address.
| We use this information to address your inquiries or complaints you make (or are made about you) regarding the Services.
We may also use this information to contact you with offers regarding our products or services.
|This processing is necessary for our legitimate interests, namely administering the Services and addressing inquiries and complaints regarding the Services.|
| Mobile device and location information
Information identifying your mobile device and the location from which you access and use the Services.
|We use this information to provide market research services to our clients and customers.||This processing is necessary for our legitimate interests, namely providing services to our clients and customers.|
| Information about you provided by our clients
Information about you provided by Babbage’s clients and customers.
|We use this information to provide market research services to our clients and customers.||This processing is necessary for our legitimate interests, namely providing services to our clients and customers.|
| Other information provided by third parties
Information about you we receive from third party data providers.
|We use this information to provide market research services to our clients and customer||This processing is necessary for our legitimate interests, namely providing services to our clients and customers.|
| Other information you choose to provide
Information you provide when you fill out a “free text” box on the Services (examples might include responses to consumer surveys, comments on blog posts or other content posted through the Services, or when you contact us by email, mail or phone).
|We use this information to provide market research services to our clients and customers.|
|CATEGORY OF PERSONAL INFORMATION||HOW WE USE IT
(Purpose of Use)
|LEGAL BASIS FOR THE PROCESSING|
Information about how you access and use the Services
For example, our Services collect:
We use this information to address your inquiries or complaints you make (or are made about you) regarding the Services. We may also use this information to contact you with offers regarding our products or services.
This processing is necessary for our legitimate interests, namely administering the Services and addressing inquiries and complaints regarding the Services.
We use this information (like your IP address) to enhance the security of the Services (for example, so that we can potentially block malicious IP addresses).
The processing is necessary for our legitimate interests, namely to improve the Services generally; to monitor and resolve issues; and for the detection and prevention of fraud.
Alexander Babbage, Inc.
1349 West Peachtree St. NW, Suite 1525
Atlanta, Georgia 30309
YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT
This California Privacy Notice supplements the Alexander Babbage Privacy Notice (the “Notice”) and contains the disclosures required under the California Consumer Privacy Act (CCPA). For individuals who are California residents, the CCPA requires covered businesses to make certain disclosures about the categories of personal information they collect and how they use it, the categories of sources from which they collect personal information, and the third parties with which they share it. You also have the right to exercise certain rights regarding your personal information. Please note that for California residents, the term “personal information” means 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 as defined in the CCPA. Unless otherwise defined in this document, all capitalized terms have the same meaning as given them in the Notice.
If you are a California resident who has provided personal information to Alexander Babbage, or a California resident who reasonably believes that Alexander Babbage collected or stores your personal information, you have the right to request Alexander Babbage to:
- Disclose the categories of personal information we collected about you in the preceding twelve months; categories of sources from which the personal information was collected; the business or commercial purpose for which we collected or sold the personal information; the categories of third parties with which we have shared your personal information; categories of personal information that we sold in the preceding twelve months, and for each category identified, categories of third parties to which we sold that particular category of personal information; and the categories of personal information that we disclosed for a business purpose in the preceding twelve months, and for each category identified, the categories of third parties to which we disclosed that particular category of personal information (“Request to Know”)
- Disclose the specific pieces of personal information that we have collected on you (“Request to Know”)
- Delete personal information we have collected on you (“Request to Delete”)
You can only make to Requests to Know in a twelve-month period, and the information provided need only cover the twelve-month period prior to the receipt of your request.
WE DO NOT “SELL” YOUR PERSONAL INFORMATION AS “SELL” IS DEFINED IN THE CCPA.
Methods for Submitting Request
You may submit Requests to Know and Requests to Delete in one of the following methods: (1) by submitting an online form; (2) sending an e-mail to email@example.com; or (3) by calling the following number: [404-961-7600] and ask for the Privacy Officer.
Verification of Requests
We will need to verify your identity to respond to Requests to Delete and Requests to Know. If you have an account with us that is password-protected, we can request from you two data points of personal information to verify your identity. If you do not have an account with us, and your request concerns specific pieces of personal information, we can request from you at least three data points of personal information as well as a signed declaration under penalty of perjury to verify your identity.
If a request concerns household information, and the household does not have a password-protected account with us, we will not comply with a Request to Know specific pieces of personal information about the household or a Request to Delete household personal information unless all of the following conditions are satisfied:
- all consumers of the household jointly request access to specific pieces of information for the household or the deletion of household personal information;
- we have individually verified all members of the household in accordance with the CCPA; and
- we have verified that each member making the request is currently a member of the household.
Time for Response
Please note that one you have submitted a Request to Know or Request to Delete, we will acknowledge your request within ten business days. If, for some reason, you do not receive such a receipt within ten business days of your submitted request, please send an email to firstname.lastname@example.org, as an error may have occurred.
We will respond to Requests to Know and Requests to Delete within forty-five calendar days after they are received. If we cannot verify you within the forty-five-day (45) period, we may deny the request. If necessary, we may take up to an additional forty-five calendar days to respond to your request, for a maximum of ninety calendar days from the day the request is received, provided that we provide you with notice and an explanation of the reason that we will take more than forty-five calendar days to respond to your request.
As a California resident, you have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us at email@example.com for more information if you wish to submit a request through an authorized agent.
Right to Non-Discrimination for the Exercise of CCPA Rights
You have a right not to receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA. We hereby inform you that if you exercise any of your rights under the CCPA, we may not deny you goods or services for that reason, or subject you to different prices than those paid by other consumers, except to those permitted under the CCPA.
If you have any questions about our privacy policies or practices or this document, please contact us at firstname.lastname@example.org. Notice at Collection Pursuant to California Civil Section 1798.100(b), this serves as notice of the categories of personal information that we collect through the Services, the business or commercial purposes for which such personal information was collected, the categories of sources of such personal information, and the categories of third parties to which such information was disclosed in the past 12 months.
|Category||Collected||Business or Commercial Purpose||Categories of Sources||Categories of Third Parties to Which Disclosed|
We collect such items as your real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, or other similar identifiers.
|We collect and store these personal identifiers in order to:
• provide you a better experience
|We may provide this information back to the same client that provided it to us. Otherwise, we do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|
|Personal Information Categories Listed in the California Consumer Records Statute (California Civil Code Section 1798.80(e))||YES
We may collect a User’s name, signature, address, business telephone number, employment information, bank account number, credit card number, debit card number, or any other financial information.
| We collect and store these categories of personal information in order to:
• provide you a better experience
|USERS||We do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|
|Protected Classification Characteristics Under California or Federal Law||NO|
|Commercial Information|| YES
We store records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
|We collect and store commercial information to provide services to our clients and to improve our Services.||Clients provide us information about their customers so that we can provide services to our clients. Users interact with the Services. These interactions sometimes create a history, such as an indication of interest in one of our goods or services, a request for more information, or a request to download material.||We may provide this information back to the same client that provided it to us. We do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|
|Biometric Information|| NO
We do not collect genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints; iris or retina scans; keystroke; gait or other physical patterns; and sleep, health, or exercise data.
|Internet or Other Similar Network Activity|| YES
We may store and use browsing history, search history, information on your interaction with a website, application or advertisement.
|We monitor and may store information about the way you interact with the Services in order to provide you a better experience, find flaws in our interface and improve our business process.||Users Third parties (e.g., Bombora and Leadfeeder)||We do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|
|Geolocation Data|| NO
We do not collect your physical location.
|Sensory Data|| NO
We do not collect audio, electronic, visual, thermal, olfactory, or similar information.
|Professional or Employment-Related Information|| YES
We collect current or past job information.
|We collect this information in order to market our goods and services to existing and prospective clients.||Clients||We store and maintain this information in our customer relationship management (CRM) platform. Otherwise, we do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|
|Non-Public Education Information (Pursuant to the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))|| NO
We do not collect education records directly related to a student maintained by an educational institution that receives federal funds or a party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
|Inferences Drawn from Other Personal Information|| YES
We create profiles reflecting our clients’ customers’ preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|We collect this information in order to provide services to our clients.||Clients provide us information about their customers so that we can provide services to our clients.||We may provide this information back to the same client that provided it to us. We do not share this information with third parties unless we are required to do so by applicable laws, rules or regulations.|