1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
- Collecting Personal Information
2.1 We may collect, store and use the following kinds of personal information: (a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths); (b) information that you provide to us when registering with our website (including your email address); (c) information that you provide when completing your profile on our website (including your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details); (d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address); (e) information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use; (f) information relating to any purchases you make of our goods / services / goods and/or services or any other transactions that you enter into through our website (including your name, address, telephone number, email address and card details; (g) information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts); (h) information contained in or relating to any communications that you send to us or send through our website (including the communication content and meta data associated with the communication); (i) any other personal information that you choose to send to us; and (j) provide details of other personal information collected.
2.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
- Using your Personal Information
3.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to: (a) administer our website and business; (b) personalize our website for you; (c) enable your use of the services available on our website; (d) send you goods purchased through our website; (e) supply to you services purchased through our website; (f) send statements, invoices and payment reminders to you, and collect payments from you; (g) send you non-marketing commercial communications; (h) send you email notifications that you have specifically requested; (i) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter); (j) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications); (k) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information); (l) deal with enquiries and complaints made by or about you relating to our website; (m) keep our website secure and prevent fraud; (n) verify compliance with the terms and conditions governing the use of our website and (o) other uses.
3.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us.
3.4 Your privacy settings can be used to limit the publication of your information on our website.
3.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
- Disclosing Personal Information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3 We may disclose your personal information: (a) to the extent that we are required to do so by law; (b) in connection with any ongoing or prospective legal proceedings; (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); (d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and (e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
- International Data Transfers
5.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
5.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: The United States of America.
5.3 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
5.4 You expressly agree to the transfers of personal information described in this Section
- Retaining Personal Information
6.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.4 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data: (a) to the extent that we are required to do so by law; (b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
- Security of Your Personal Information
7.1 We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
7.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
- Third Party Websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
10.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10.5 We use both session and persistent cookies on our website.
10.7 Most browsers allow you to refuse to accept cookies; for example: (a) in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”; (b) in Firefox (version 24) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and (c) in Chrome, you can block all cookies by accessing the “Customize and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
10.8 Blocking all cookies will have a negative impact upon the usability of many websites.
10.9 If you block cookies, you will not be able to use all the features on our website.
10.10 You can delete cookies already stored on your computer; for example: (a) in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835); (b) in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and (c) in Chrome (version 29), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.
10.11 Deleting cookies will have a negative impact on the usability of many websites.
California Consumer Privacy Act (CCPA)
Our privacy practices are aligned with the requirements of the California Consumer Privacy Act (CCPA). If you reside in California, we are required to provide additional information to you about how we use and disclose your personal data, and you may have additional rights with regard to how we use your personal data.
Personal data. Consistent with the “How we use Personal Data” section above, we might collect certain categories and specific pieces of information about individuals that are considered “personal information” under the CCPA. Specifically, we may collect the following types of personal data:
- Identifiers: contact details, identification information.
- Commercial information: information required to purchase our products and services online, information about profile, role, and preferences.
- Internet or other electronic network activity information: login credentials, digital activity information.
- Other personal information: records of good standing, comments, and feedback from online forums and surveys, CCTV footage, information about alleged misconducts, information included in enquires and complaints, information made publicly available on professional social networks.
Sources. We may collect certain categories of personal data from you and other third parties as described in the “How we use personal data” section above. The categories of third parties from whom we may collect personal data include the following:
- Partners, resellers, and/or distributors;
- Public authorities;
- Third-party applications (such as social networks);
- Advertising networks; and
- Other companies or organizations (such as market research firms and data aggregators).
Purposes. We collect your personal data for the business and commercial purposes described in the “How we use personal data” section above. We also share and/or disclose your personal data as follows:
- Sharing your personal data for business purposes: As described in the “How we use personal data” section above, we may share your contact details, login credentials, information from publicly available resources and information from your complaints and/or inquiries, within the Ragan Thomson group of companies, with third parties, with partners, resellers and/or distributors, and with public or government authorities. As described above, examples of business purposes include product and service fulfillment, due diligence screening, security and authentication, prevention of misconduct, and resolving complaints.
- Sale of personal data: By using Automatic Data Collection Tools on our websites and applications, we may share some of your digital activity information with third parties in order to receive information about the performance of our marketing campaigns. Sharing personal data in this manner may constitute a “sale” under the CCPA.
Your rights in relation to your personal data. Subject to certain exceptions, as a California resident, you have the right to:
- Request that we disclose the access to your personal data;
- Request deletion of your personal data;
- Request information about the personal data we have disclosed for a business purposes and/or “sold” (as such term is defined under the CCPA) to third parties within the past 12 months; and
- Opt-out of the “sale” of your personal data, as detailed above and below.
“Do Not Sell My Personal Information”. You have the right, as a California resident, to opt-out of the “sale” of your personal data, i.e. our use of Automatic Data Collection Tools. If you wish to exercise this right, please email [email protected] and exercise your opt-out right.
If you are a California resident and wish to exercise any of the rights described in this section, you may use the following methods to submit a request in relation to your personal data:
- Contact the Ragan Thomson Tech Team by sending an email to [email protected]
You must include your name, street address, city, state, and zip code in your request. You may be asked to provide additional proof of identification so that we can verify your identity and validate the request. Please note that in order to opt-out from Automatic Data Collection Tools you need to email Ragan Thomson as we do not have the ability to connect your name with your device(s).
To the extent that you elect to designate an authorized agent to make a request on your behalf, the above methods to submit a request apply. Please note that you are limited by law in the number of requests you may submit per year.