Privacy Policy

INTRODUCTION

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".

We are pleased to provide this Privacy Policy to inform you of our practices in connection with information that we collect through our 40Act.com Services. If you have any questions or comments about the Privacy Policy or our privacy practices, please contact us at contactus@40Act.com.

By accessing or using the Site and 40Act.com Services, you signify that you agree with all the terms of this Privacy Policy. So please do not access or use the Site and 40Act.com Services if you disagree with any part of this Privacy Policy. In addition, you acknowledge and agree to the Terms and Conditions posted on the Site from time to time and incorporated in this Policy by reference.

PERSONAL INFORMATION

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.

Personal Information is data that users and subscribers voluntarily provide to us, including your name, email address, billing and payment information and all other information provided on the membership form. 40Act.com, LLC uses the payment and merchant processing services of Stripe, Inc. and Wells Fargo Bank, N.A. Such services are subject to Stripe’s Terms of Service, including their Privacy Policy, which can be accessed at their website, https://stripe.com/us/terms.

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);

  • if you access the Site via a social media site, to your friends associated with your social media account, to other Site users as well as to your social media account provider, in connection with your social sharing activity. By connecting your use of the Site to your social media account you authorize us to share information with your social media account provider and you understand that the use of the information we share will be governed by the social media site’s privacy policy. If you do not want your Personal Information shared with other users or with your social media account provider, please do not connect your social media account with your use of the Site and do not participate in social sharing on the Site; 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.

OTHER INFORMATION

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.

If you do not want information to be collected through the use of cookies on your computer, there is a simple procedure in most browsers that allows you to automatically decline the transfer of cookies to your computer, or to be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. If cookies are disabled, however, some features of the Site may not operate as intended. Information about procedures to disable cookies can be found on your Internet browser provider's website.

  • 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.

THIRD-PARTY SITE

This Privacy 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 to which this Site contains a link. Please read the terms, conditions and policies of such third-party sites before accessing or using such sites. The inclusion of a link on the Site does not imply any endorsement of the linked site by us or by our affiliates.

SECURITY

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.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

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.

CROSS-BORDER TRANSFER

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

40Act.com, LLC may change this Privacy Policy at any time in its sole discretion by publishing the revised Privacy Policy on this page, so you should review this page regularly. The date of the most recent revision will appear at the bottom of this page. The revisions are not applicable to disputes arising, or arising out of events occurring, before such publication. Your continued use of 40Act.com Services or the Content is always an acceptance of any changes in this Privacy Policy.

Last Revised: January 17, 2014

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