Last Updated: September 20, 2021
As with most websites and other digital platforms where a business or organization has a presence, our Sites may collect information about you and your use of the Sites in two different ways: through the collection of User Submitted Data and Browser Derived Data.
“Personal Information” is information that identifies you as an individual, such as:
In some cases, we may collect additional information, such as information about your location, income level, etc., which does not identify you personally, in combination with your Personal Information. We will treat all such information as Personal Information as long as it is combined with Personal Information.
We will not provide your personal information to third parties for their use in marketing third-party products or services to you without your consent.
Once collected, we may use your Personally Identifiable Information in a variety of ways including, but not limited to the following:
When fulfilling service requests initiated by you, we may share your Personally Identifiable Information with certain third parties to fulfill the requests. We may also share Personally Identifiable Information with service providers that perform business functions for us. For example, Ethis may occasionally hire other companies to provide limited services on our behalf including, but not limited to, packaging, mailing and delivering promotional offers, answering subscriber questions about products or services, consulting services, data modeling, printing, sending postal mail and processing subscriptions or event registrations. In such cases, Ethis may share your Personally Identifiable Information to the entities performing these functions on Ethis’s behalf.
When you submit Personal Information to us that includes your telephone number for the purpose of obtaining goods or services you have expressly sought, you understand and agree that your submission constitutes your making an “inquiry” to us and our affiliated entities, asking us to contact you or to allow our vendors to contact you by telephone for a limited period. You expressly consent to receive phone calls under these circumstances whether or not you are on any Do Not Call list (federal or state). By including your telephone number and/or email address in any submission, you are extending an express invitation and providing your express written consent to us and any vendors whose goods or services you have sought (i) to contact you by telephone at the numbers you have provided (including through auto-dialed, pre-recorded, artificial voice and/or text messages) so that we or they may assist you with your request, and you hereby consent to any such calls even if your phone number is on any Do Not Call list, and (ii) to contact you by email at any email address you provided. You understand that you are not required to provide this consent to contact you as a condition of purchasing any goods or services. You represent that all of the information you have provided in your submission is true and complete. By submitting your Personal Information to us, you are providing us with your written and signed consent to receive these calls, and you agree that Ethis’s Sites have obtained your consent to receive a prerecorded message sales call in a manner permitted by the Electronic Signatures in Global and National Commerce Act (E-SIGN Act).
We may also use User Submitted Data as we believe to be necessary or appropriate under applicable law, including laws outside the United States: (a) to comply with legal process; (b) to respond to requests from public and government authorities including public and government authorities outside the United States; (c) to enforce our terms and conditions; (d) to protect our operations or those of any of our affiliates; (e) to protect our rights, privacy, safety, interests, or property, and/or that of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.
User Submitted Data you provide through the Site may also be combined with other information you provide to us (via online or offline means), with demographic information and other information that is publicly available, or with other information about you that we may otherwise obtain online or offline.
Your Personal Information may be disclosed:
“Non-Personal Information” is any information that does not reveal your specific identity, such as:
Because Non-Personal Information does not personally identify you, we may use and disclose Non-Personal Information for any lawful purpose. However, without your affirmative express consent, we will not share with third parties your information of a sensitive nature (such as information about your age or about your precise physical location) combined with a device-specific identifier (like your IP address) so that they can target ads to you on multiple Sites or track your Internet behavior over time. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.
Your “Internet Protocol Address” or “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP).
An IP Address is identified and logged automatically in our server log files whenever a user visits the Sites, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many Sites.
We may use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, geographic mapping and administering the Sites. We may also use and disclose IP Addresses for all the purposes for which we use and disclose Personal Information. Please note that we treat IP Addresses, server log files and related information as Non-Personal Information, except where we are required to do otherwise under applicable law.
Our Sites may include social media features, such as the Facebook Like or Tweet This Button. These features may collect your IP Address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. These features are either hosted by a third party or hosted directly on our Sites. Your interactions with these features are governed by the privacy policies of the companies providing them. PLEASE NOTE THAT WE ARE NOT RESPONSIBLE OR LIABLE FOR THE ACTS AND/OR OMISSIONS OF THIRD PARTY PARTNERS AND VENDORS.
The security of your Personal Information is important to us. We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. For example, with regard to our internal operations, only authorized officers and employees and authorized third party service providers are permitted to access Personal Information, and they may do so only for permitted business functions. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “How To Contact Us” section below.
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
If you would like to review, correct, update, suppress or delete, on a going-forward basis, our use of your Personal Information that has been previously provided to us, you may do so by contacting us as set forth at “How To Contact Us,” below, and providing the name of the service for which information was provided, your full name, mailing address, phone number and email address so that we may identify you in the opt-out process. For your protection, we will only implement such requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. We will respond to your request within 30 days. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required.
Our Site is not directed to individuals under the age of eighteen (18). We request that these individuals do not use the Sites and do not provide Personal Information through the Sites. If we acquire actual knowledge that we have collected Personal Information from a specific individual under the age of eighteen (18), we will delete this information, unless we are required to retain it by law.
Your Personal Information may be stored and processed in any country where we have facilities (at present, only the United States). By providing any Personal Information to us, you consent to the transfer of such Personal Information to countries outside of your country of residence, including the United States, where Ethis develops a presence, which may have different data protection rules from your country of residence.
In general, with regard to sensitive Personal Information (e.g., Social Security number, driver’s license number, credit card number (unless necessary to make a purchase), information related to racial or ethnic origin, political opinions, religion or other beliefs, criminal background or trade union membership) and health-related Personal Information, we ask that you submit only that information which is required by us either directly or on our forms, and that you do not provide us with these types of Personal Information on or through the Sites or otherwise, unless we specifically request it from you.
California has passed legislation requiring certain specific disclosures be made available to California residents who use the Internet and provide Personal Information that may be used for marketing purposes. That legislation requires any business that discloses a customer’s Personal Information (as defined by the legislation) to any third party for direct marketing purposes to provide the customer a method for obtaining the names, addresses and certain other specified details of anyone who might have received that Personal Information. If you are a California resident you may request this information by writing to us at the address listed at the end of this Policy. Ethis is not obligated to respond to more than one such request from you per calendar year.
California law also provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. The Sites do not currently respond to “Do Not Track” signals, as there is currently no industry or legal standard for doing so.
Ethis Communications, Inc.
44 Church Street, Suite 200A
White Plains, NY 10601