40Act.com, LLC is concerned about privacy issues, and we want you to be familiar with how we collect, use and disclose information. In general, it is our policy to use Personal and Other Information to assist you and to provide you with a good Site and 40Act.com Services user experience. We do not sell your Personal Information to third parties. The rest of this document details this policy.
40Act.com, LLC publishes the 40Act.com™ Site and research database (the “Site” or “40Act.com”). The Site has an associated information and news feed service through which 40Act.com distributes email messages, newsletters, updates and/or alerts on Site subject matter-related matters. The Site and associated news and data services are referred to collectively as "40Act.com Services". Any data or materials displayed on 40Act.com Services are referred to collectively as "Content." All Content that is uploaded, submitted, posted, or otherwise supplied by Site subscribers and users is referred to collectively as "User-Contributed Content".
Personal Information We May Collect
We collect two types of information in connection with the Site: (1) "Personal Information," which is information that identifies you or relates to you as an individual; and (2) "Other Information," which is any information that does not reveal your specific identity or does not directly relate to an individual.
How We May Use Personal Information
In general, it is our policy to use Personal and Other Information to assist you and to provide you with a good Site and 40Act.com Services user experience. We do not sell your Personal Information to third parties. For example, we may use Personal Information:
to respond to your inquiries and fulfill your requests, such as to send you newsletters, updates or alerts that you request, to register you for events, and to sponsor events and evaluate sponsorship requests;
to keep a record of your contact information and correspondence, if you contact us through the Site, and to use such information and correspondence to respond to you;
to send you administrative information, including renewal reminders and information regarding the Site and changes to our terms, conditions and policies;
to facilitate social sharing functionality;
for our internal business purposes, such as improving or modifying the Site and operating and expanding our business activities; and
as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, or that of, you or others; or (g) to allow us to pursue available remedies or limit the damages that we may sustain.
How Personal Information May Be Disclosed
Your Personal Information may be disclosed:
to our third-party service providers which provide services such as website hosting, data analysis, IT services and infrastructure, customer service, email delivery, auditing and other similar services;
to a third party (whether affiliated or unaffiliated with us) 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 proceeding);
by you, when you upload, submit, post, or otherwise supply User-Contributed Content to us or on message boards, blogs and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public information, and may be available to visitors to the Site and to the general public (we urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Site);
as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, or that of you or others; or (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Other Information We May Collect
"Other Information" is any information that does not reveal your specific identity or does not directly relate to an individual, such as browser information; information collected through cookies, pixel tags and other technologies; demographic information and other information provided by you; and aggregated information.
How We May Collect Other Information
We and our third-party service providers may collect Other Information in a variety of ways, including:
Through your browser: Most internet browsers transmit certain information to websites that you visit, such as your computer's type (Windows or Macintosh) and its Media Access Control (MAC) address and screen resolution, and the type and version of your computer's operating system and browser. We use this information to ensure that the Site functions properly.
Using cookies: Cookies are text files, containing small amounts of information, which are downloaded to your browsing device (such as a computer or smartphone) when you visit a website. Cookies allow us to recognize your browsing device to assist with your use of the Site. This can include helping us understand how our Site are being used, letting you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience. Cookies can also help ensure marketing you see online is more relevant to you and your interests.
Using applications: We may use applications, including mobile applications or widgets, to collect information from you.
Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Site pages and HTML-formatted email messages to, among other things, track the actions of Site users and email recipients, measure the success of marketing campaigns and compile statistics about Site usage and response rates.
IP Address: Your "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 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 websites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems and administering the Site.
From you: We collect information when voluntarily provided by you, such as your company, title, interests and preferred means of communication. Unless combined with Personal Information, such information does not personally identify you or any other user of the Site.
By aggregating information: Aggregated personal information does not personally identify you or any other user of the Site. For example, we may aggregate personal information to calculate the percentage of our users who have a particular telephone area code.
How We May Use and Disclose Other Information
Please note that we may use and disclose Other Information for any purpose, except where we are required to treat Other Information as Personal Information under applicable law. In those situations, we may use and disclose Other Information for the purposes for which we use and disclose Personal Information, as well as for the uses listed in the "How We May Collect Other Information" section above.
In some instances, we may combine Other Information with Personal Information. If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is so combined.
We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data storage system or method of data transmission over the internet can be guaranteed to be 100% secure. Please do not send sensitive or confidential information to us by email or by any other means in connection with the Site. If you have reason to believe that your communications with us have been compromised in any way, please immediately notify us of the problem by contacting us by email at contactus@40Act.com and by postal service at 40Act.com, LLC, P.O. Box 383, Westborough, MA 01581-0383.
CHOICES AND ACCESS
Your choices regarding our use of your Personal Information for 40Act.com marketing purposes
If you no longer wish to receive marketing-related emails from us, you may opt-out by following the unsubscribe instructions in any such message or by emailing us at contactus@40Act.com. We aim to comply with such request(s) as soon as reasonably practicable. Please note that if you do opt-out of receiving marketing-related emails from us, we may still send you administrative messages; you cannot opt-out from receiving administrative messages.
How you can access, change or suppress your Personal Information
You may request to review, correct, update, suppress or otherwise modify any Personal Information that you have previously provided to us through the Site. To do so, please log-in to your account at the Site and modify your Personal Information accordingly.
You may also email us at contactus@40Act.com to make your request. In your request, please make clear what information you would like to have changed, and 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. For your protection, we will only implement 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. We aim to comply with requests as soon as reasonably practicable.
Please note that we may need to retain certain information for record keeping purposes, and there may also be residual information that will remain within our databases and other records. Such information will not be removed. We may, from time to time, re-contact former users of the Site. Finally, we are not responsible for removing information from the databases of third parties (such as service providers) with whom we have shared your Personal Information.
USE OF SITE BY MINORS
The Site is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Site.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Site you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those in your country.
REVISIONS TO THIS POLICY
Last Revised: January 17, 2014