LAST UPDATE: [Feb. 18th, 2016]
1. COLLECTION AND USE OF PERSONAL INFORMATION
Personal Information You Provide
The privacy and security of the personal information that RCL collects from you is a priority for RCL. Generally you can visit this Site without providing personal information. However there may be circumstances when you may be asked or choose to provide personal information that could reasonably be used to contact you or to identify you personally including, but not limited to, your name, email address, and inquiry information. By submitting personal information to RCL at this Site, you hereby consent to RCL’s collection, use and disclosure of such personal information.
We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as available information sources (including information from your publicly available social media profiles), and other third parties.
Passive Information Collection and Use
As you navigate around this Site, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies. We and our third party service providers passively collect and use information in a variety of ways, including:
· Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access this Site through a mobile Device.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. 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) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies.
· IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits this Site, 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 web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering this Site.
· Do Not Track Requests: At this time RCL does not respond to Do Not Track signal requests.
Integrated Accounts and Social Media Information
We may implement applications or “widgets” from third party providers (e.g., Facebook, Twitter, etc.) that allow interaction, integration or content sharing with third party services. These widgets or applications may be visible on a page you visit on our Site or may require log-in through the third party provider’s service. The third party providing the widget or integration may offer controls for you to manage your interactions. Any interaction with a third party widget or application typically allows the third party to collect some information about you (whether through cookies, registration information or otherwise). These third parties may even track you when you do not interact with the widget. If you have engaged any of these third party service providers, their respective privacy policies will govern their tracking and collection of information. You should review these third party policies to understand these practices.
How We Use and Disclose Information
We use and disclose personal information you provide to us as described to you at the point of collection, such as when you (1) send us an inquiry through the Contact page, and (2) send e-mail messages or feedback, or transmit other information by e-mail. If you elect to engage in such activities, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), e-mail address, and telephone numbers.
We also use and transfer personal information from or about you:
· to respond to your inquiries and fulfill your requests, such as to send you documents you request or e-mail;
· to send you important information regarding our relationship with you or regarding this Site, changes to our terms, conditions, and policies and/or other administrative information; and
· for our business purposes, such as data analysis, audits, developing new products or services, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our Site.
· to our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, IT services, auditing services, and other services, in order to enable them to provide services; and
· to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
We also use and disclose information we collect passively as described above, under “Passive Information Collection and Use,” and for any other purpose, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as personal information). In addition, we may use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.
2. GENERAL PRINCIPLES FOR THE PROCESSING OF PERSONAL INFORMATION
Personal information will be collected, stored, processed and transmitted in accordance with RCL’s established policies and applicable federal, state, local and foreign laws, rules and regulations.
The principles of RCL with respect to the processing of personal information are as follows: (1) personal information will be processed fairly and lawfully, (2) personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal information collected by RCL will be adequate, relevant, and not excessive in relation to the purposes for which it is collected, (4) personal information collected by RCL will be accurate and, where necessary, kept up to date to the best of our ability, and (5) personal information collected by RCL will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected.
If RCL engages in the processing of personal information for purposes other than those specified in this Policy, RCL will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.
3. THIRD PARTY SITES AND SERVICES
This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property on this Site does not imply endorsement of it by us or by our affiliates.
4. CHOICES AND ACCESS
We give you choices regarding our use and disclosure of your personal information. You may opt-out of our collection of your personal information at any time by contacting us as specified below in the CONTACT section. We will seek to comply with your request(s) as soon as reasonably practicable.
How You Can Access, Change, or Delete Your Personal Information
If applicable and you would like to review, correct, update, or delete the personal information that you have provided via this Site, please contact us as specified below in the CONTACT section. We will try to comply with your request as soon as reasonably practicable.
It is your responsibility to provide RCL with accurate personal information. Except as otherwise set forth in this Policy, RCL shall only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, RCL shall take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.
6. RETENTION PERIOD
We retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.
We use reasonable organizational, technical, and administrative measures to protect personal information under our control. 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, please immediately notify us of the problem by contacting us in accordance with the CONTACT section below.
8. USE OF SITE BY MINORS
The Site is not directed to individuals under the age of 13 and we request that these individuals not provide personal information through this Site.
9. COMPLIANCE WITH LOCAL LAWS
This Policy is meant to guide RCL with respect to personal information collected from or about you at this Site. While this Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to RCL (“Local Laws”) may require standards which are stricter than this Policy and, in such event, RCL will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions.
10. CROSS-BORDER TRANSFER
Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Site or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules, and a lower standard of required protection, than in your country.
We may change this Policy. Please take a look at the LAST UPDATE legend at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on this Site. Your use of this Site following these changes means that you accept the revised Policy.
RCL will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.
If you believe that your personal information has been processed or disclosed in violation of this Policy, RCL encourages you to raise any concerns using the contact information provided in this Policy. RCL will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.
13. CONTACTING US
If you have any questions about this Policy, please contact us via one of these methods:
On this Site, via the CONTACT section, if available
or by phone please call [(212) 655-0282] (Monday to Friday, 8am – 5pm EST)
or by e-mail at info@RealClearLife.com
or please write to the following address: RealClearLife, [787 Seventh avenue 48th Floor
New York, NY 10019]