Last Updated: June 15, 2018
WHAT INFORMATION WE COLLECT
Your provision of your Personal Information to us is completely voluntary. “Personal Information” is information that can specifically identify you. We do not collect Personal Information unless you submit or provide that information to us. Categories of Personal Information we may collect include:
- Identity Data, which includes name or other similar online identifiers, either for you or your agents or users.
- Contact Data, which includes work email address, work title and work department.
Additionally, we may also collect certain others types of information that, along with Identity Data and Contact Data, may be considered and specifically named “Personal Data” in certain jurisdictions, including the European Union (“EU”), such as:
- Technical Data, which includes internet protocol (IP) address, time zone, location data, your login data, and device and browser information.
- Profile Data, which includes your username and password, as well as your account preferences.
- Usage Data, which includes information about how you use our Service, including relevant behavioral information as well as descriptions and categorizations of issues or crises, messaging strategy and notes on the aforementioned items and their effectiveness.
- Marketing and Communications Data, which includes your preferences in receiving marketing from us.
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
HOW INFORMATION IS COLLECTED
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your information by registering an account on our Service or by contacting us. This includes information you provide when you:
- create an account on our Service;
- email or contact us; or
- give us feedback.
Automated technologies or interactions: As you interact with our Service, we may automatically collect Technical Data and Usage Data about your Service interactions. Some of the ways in which we or our Service may collect are further described below:
of information on a Service user’s computer or other device to permit a Service to, for example,
future visits using that computer or device. The Service may use other similar technologies (including,
limitation, tracking pixels, as described further below, and other anonymous identifiers) to gather
about you, such as IP addresses and location data, to customize your visit, to enable us to enhance our
or for other purposes. We use the following cookies and similar technologies:
COOKIE DURATION/TYPE PURPOSE MORE INFORMATION XSRF-TOKEN Session / 2 Hours First Party This randomly generated token helps to ensure requests to our site come from you. This helps us prevent third party attacks and keeps your requests safer. https://www.owasp.org/index.php/Cross-Site_Request_Forgery_(CSRF)_Prevention_Cheat_Sheet laravel_session Session / 2 Hours First Party The session token keeps track of your logged in status, so we know it’s you who is accessing the site and can present the correct information.
- Clickstream Data: As you use the Internet, a trail of electronic information is left at each site you visit. This information, sometimes referred to as "clickstream data," can be collected and stored by a Service’s server. For example, clickstream data can tell the type of computer and browsing software you use and the address of the Service from which you linked to the Service. The Service may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Service, how visitors navigate throughout the Service and how we may tailor our Service to better meet the needs of visitors. This information often will be used to improve our Service and our services. Any collection or use of clickstream data will be anonymous and aggregated, and will not intentionally contain any Personal Information.
- Location Data: The Service, when given permission, will collect the time zone of your device. We use this information to help us improve the Service and our services. If you would like to opt-out of location tracking, please see the Opt-out section below.
HOW INFORMATION IS USED AND SHARED
Subject to the section titled “Additional EU Disclosures” below, we use information about you to perform our services, provide our products and for other purposes outlined below. Specifically, we use your information:
- To perform the contract we are about to enter into or have entered into with you.
- To perform specific services that you have requested.
- To respond to your direct inquiries.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and your fundamental rights do not override those interests.
- To send you marketing materials (see below).
- Where we need to comply with a legal or regulatory obligation.
Subject to the section titled “Additional EU Disclosures” below, we may share the information we collect about you with certain third parties in the following ways:
- To provide and improve our Service;
- To respond to your direct inquiries and communicate with you;
- We may, from time to time, share your information with our business partners, clients, operational service providers, subcontractors and other third parties.
- We will share your information to any third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them, and share information with those third parties, if we are part of a bankruptcy proceeding or other change in control.
- We will share information with third parties to whom we need to share your information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the Service.
We have put in place appropriate security measures to prevent information about you from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. However, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We have put in place procedures to deal with any suspected data breach that will affect you and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements. Notwithstanding the foregoing, in some circumstances you can ask us to delete your data. See Request Erasure below for further information. In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.
ADDITIONAL EU DISCLOSURES
Our role as data controller and data processor
Maslansky + Partners, LLC generally acts as the data controller of information submitted through our Service.
If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us at the address below in the first instance and we will do our very best to resolve your concerns. If you are situated in the EU and have a complaint, please contact our privacy officer at DynamicResponse@maslansky.com.
Provision of personal data and failure to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services or complete the purchase of a product). In this case, we will not be able to provide services or products to you.
Legal basis for our processing of your Personal Data
Below are the types of lawful basis that we will rely on to process your Personal Data:
- Legitimate Interest means the interest of our business in conducting and managing the Company to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at DynamicResponse@maslansky.com.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at DynamicResponse@maslansky.com. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Collection of Personal Data from third party sources
As discussed above, we also obtain information through automated technologies (see section titled “Information Collection”)
Categories of third parties receiving Personal Data
In addition to the third parties disclosed in the section “Information Use and Sharing,” we may also provide your information to the following categories of third parties: business partners, clients, operational service providers, subcontractors and other third parties.
Withdrawing your consent
If we are relying on your consent to process your Personal Data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at DynamicResponse@maslansky.com.
Use of your Personal Data for marketing purposes
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising:
- Promotional offers from us: We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
- Third-party marketing: We will share your Personal Data with any company outside our company for our marketing purposes. Said third parties cannot use this Personal Data for their own purposes.
To see how you can opt out of marketing communications, please see the section titled “Opt-Out”.
Rights of EU Data Subjects
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. You have the right to:
- Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
To exercise your rights, please contact us at DynamicResponse@maslansky.com.
Opting out of messages from us
To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at DynamicResponse@maslansky.com. If you do not want your Personal Information or Personal Data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an email to DynamicResponse@maslansky.com. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of the Service may no longer be available to you.
Opting out of cookies
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Service or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge.
Opting out of location tracking
You may also adjust the settings on your mobile device to allow or restrict the sharing of location information. For example, the "location" permissions on your mobile device may allow you to elect whether to never share location information with us, to share location information only while you are using the Service, or always share location information even if you are not using the Service. If you elect to not share your location information, you may be unable to access some features of our Service that are designed for mobile devices.
DATA RELATING TO CHILDREN
Our Service is designed for those 18 years of age and older. We do not knowingly collect information from anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.
California Privacy: Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personally identifiable information, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us by DynamicResponse@maslansky.com. If you do not want your personally identifying information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at DynamicResponse@maslansky.com.
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