Last modified: March 2020
Effective date: March 2020
- Personal information and our business model
- The personal information we collect
- Your consent to our collection of personal information
- How we collect personal information
- How we use your personal information
- How we use other information
- How we disclose personal information
- How we secure your personal information
- Retention of personal information
- “Do Not Track” browser settings, tracking by other parties and child privacy
- Your rights to your personal information
- How to contact us
The Personal Information We May Collect
We collect the following personal information about you when you access our Products or our Site:
- contact information (for example, when you sign up for updates, subscribe to attend events or webinars, request information from us or otherwise contact us, we may collect information such as your first and last name, title, organizational affiliation, related industry, email address, phone number, state of residence and zip code);
- communications with us (such as for product support);
- payment information (this is collected through a third-party service provider which may store your information in order to process payments – we will have access to transaction reference numbers pertaining to each payment);
- transaction information and information/details related thereto, including market or business data and related information you upload to our servers during use of our application;
- information about you provided by third party services (if you link to or connect with third party services, such as for the purpose of applying for a job with us, they may send us information, all of which will be controlled by such third party);
- usage information (we collect information about your interactions with the Services, such as searches and location information);
- log data (when you access our Products or Site, our servers automatically receive and log information from your browser, including information from your device (such as your hardware model, operating system version, unique device identifiers, location, and available mobile network information), IP address, cookie information, and the pages and functionality you request, and may relate it to the information you provide);
An Internet protocol (“IP”) address is the unique number assigned to your server or Internet Service Provider (“ISP”). Like many web sites, we may track such IP addresses for system administration, to report aggregate information, site tracking, or to prevent our servers from being abused.
- information about you from other sources (to the extent permitted by applicable law we may receive additional information about you, such as demographic data or fraud detection information and warnings, or other information about you from partner networks).
- when the collection, use or disclosure of personal information is permitted or required by law;
- in an emergency that threatens an individual’s life, health or personal security;
- when the personal information is available from a public source;
- when we require legal advice from a lawyer;
- for the purposes of collecting debt;
- to protect ourselves from fraud; or
- to investigate an anticipated breach of an agreement or a contravention of law.
How We Collect Personal Information
Like most website operators, we collect personal information about you from a variety of sources, including:
- directly from you (when you register for or use our Services);
- from government and third-party public information repositories;
- from our business partners; and
- automatically from devices that you use to connect to the Site.
How We Use Personal Information
Technical Site Data
As discussed above, our web servers may collect information including the IP address of visitors to our Site, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We use this information for the following purposes:
- To measure the use of our Site, including number of visits, average time spent on the Site, pages viewed, page interaction information (such as scrolling, clicks, and mouse-overs), and to improve the content we offer;
- For retargeting programs, to personalize future experiences, to gain awareness of visitors, to score leads;
- To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
- As part of our efforts to keep the Site safe and secure.
We may share this information or other data with third parties on an aggregated basis without the use of any personal information.
Contact Information and Communications
As discussed above, we may collect your contact information or your personal details in connection with, among other things, your general questions, product support requests and job applications. We may use this information in the following ways:
- to respond to your questions and comments;
- to deliver requested evaluation materials;
- to coordinate webinars and events;
- to evaluate candidates for potential employment opportunities;
- to send email notifications and reminders related to the Products and Services;
- providing the Products and Services and operating our business;
- to send you communications, including newsletters, service announcements, administrative messages, marketing messages or other marketing information;
- for email marketing, retargeting programs and prospecting;
- establishing and maintaining relationships with our customers;
- conducting investigations, detecting fraud, abuse, security breaches and other harmful activity; and
- meeting and complying with legal and regulatory requirements.
We and our third-party payment processor will collect data in connection with the processing of payments for our Services, including credit card information and information relating to each unique transaction. This information is collected to complete or confirm the transaction or series of transactions for which the personal information was collected, and for our internal purposes related to financial record-keeping and marketing of our Products.
How We Disclose Personal Information
- within our organization;
- at your request or with your consent;
- with our service providers and business partners or other third party services providers such as Google Analytics who carry out tasks on our behalf (we use third party service providers to provide the Services and we may share your personal information with them so they may carry out tasks on our behalf, each provider has its own rules and privacy policies and we encourage you to review these rules and policies);
- certain information may be shared with third parties or published when you follow links to third party websites, we do not own or control these third parties and when you interact with them you may be providing information to them directly – such parties will have their own rules and policies in respect of the collection, use and disclosure of personal information and we encourage you to review these rules and policies;
- publicly, for example, information you choose to share (such as testimonials) may be visible to the public and may be indexed through third party search engines – we do not control the practices of third-party search engines;
- in connection with a merger, acquisition or other corporate transaction, including if one of our business units are acquired by, sold to, or merged with another company.
How We Secure Your Personal Information
We have taken steps to ensure that all personal information collected will remain secure and in its original form, i.e. free from any alteration. Access to all personal information (except publicly available information) is strictly controlled. We have put in place appropriate physical, electronic, and managerial procedures in an effort to safeguard and help prevent unauthorized access and to maintain data security.
Retention of Personal Information
We retain personal information that we collect for 24 months or as long as is necessary to fulfill identified legal or business purposes.
Your Rights to Your Personal Information
You may request (i) access to your specific personal information collected, (ii) to know the categories of personal information we have collected; (iii) to know the categories of sources from which your personal information is collected, (iv) to know how we use your personal information, (v) to know to whom it has been disclosed, and (vi) that we delete your personal information, subject to limited exceptions prescribed by law.
Requests should be made in writing and we must be able to verify your identity before we are able to release your personal information to you. We will respond to requests within 45 days or provide notice if we require longer but will respond within 90 days of receiving the request. We will provide you with your personal information in a portable, readily useable format free of charge, but we may charge a reasonable fee for excessive requests. Providing you with your personal information more than twice in a 12-month period is at our discretion.
We may not discriminate against you for exercising any of your rights permitted by law, including your right to request your personal information as described above.
“Do Not Track” Browser Settings, Tracking by Other Parties, and Child Privacy
We do not use technology that recognizes a “do-not-track” signal from your web browser, because we do not track users other than for aggregate statistical purposes.
Your use of the Site will not result in other parties collecting your personal information about your online activities over time and across different websites.
If you are under the age of sixteen (16), please do not use or access the Site. It is not our intention to collect or use personal information from anyone under the age of sixteen, and we will not knowingly do so. If we are made aware that we have collected any personal information from minors and are asked to delete such information from our databases, we will promptly do so.
How to Contact Us
The full name of our company is LightBox Holdings, L.P. , located at 6 Armstrong Road, Suite 4, Shelton, CT 06484.
California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit www.lightboxre.com/privacy-policy/ccpa.
Additional Terms for Users Based in Mexico
The Company provides services in Mexico in accordance with the applicable laws in Mexico, including the Federal Law for Protection of Personal Data in Possession of Private Individuals (Ley Federal de Protección de Datos Personales en Posesión de Particulares) (the “Mexico Data Protection Law”) and its Regulations.
In Mexico, the following are the limited circumstances in which we may collect, use or disclose personal information without your consent:
- if it is permitted or required by law;
- if the information is published in sources of public access;
- if the personal data is subject to a prior dissociation procedure;
- if the purpose is to fulfill obligations which result from the legal relationship between the owner of the data and the responsible party;
- in an emergency that could potentially harm an individual or his/her person or property;
- if the information is essential for medical care, prevention, diagnosis, or the provision of health care or medical treatment, even if the owner is not able to give his/her consent, provided that it is done in accordance with the terms established in the General Health Law and other applicable laws and that said treatment is carried out by a person subject to professional secrecy or an equivalent obligation; or
- if a decision of a competent authority is issued.
How to Exercise Your Rights of Access, Rectification, Cancellation or Opposition (the “ARCO Rights”)
You and/or your legal representative may exercise any of the aforementioned rights by submitting a request to The Company, which must include the following, as set forth in Article 29 of the Mexico Data Protection Law:
- name and contact information of the data owner for the purposes of communications related to the request;
- documents that prove your identity or, if applicable, proof of legal representation;
- · a clear description of the personal data that is the subject of the request; and
- any other information or document that may be necessary to facilitate the location of the personal data in question.
To exercise any of the ARCO rights, or to limit the use or disclosure of your personal data, you can visit our address as set out above or send an email to email@example.com.
In order for us to confirm the identity of the data owner or the applicable legal representative, it may be necessary for you to present any of the following documents upon request: (i) official ID; (ii) passport; (iii) military card; (iv) profession license; or (v) identity card from the country of your birth. If you are a legal representative for the owner of the information, you will be required to submit the necessary powers of attorney or a proxy letter executed before two witnesses.
The Company will respond to you request within 20 business days from the date of your submission of complete documentation. The Company reserves the right to request additional information, within 5 business days, if it considers any documentation or request submitted to be incomplete or insufficient. Any requested documentation or information should be provided to The Company within 10 business days if you wish to continue with the process.