PRIVACY POLICY

Updated: December 29, 2019

This Privacy Policy describes how your information is collected, used, and shared when you visit http://www.unionlinx.com (the “Site”).

INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, the referring web address, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about your activity on the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type and version, Internet service provider, referring/exit pages, and date/time stamps.
  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

HOW DO WE USE YOUR INFORMATION?

We use the Device Information collected to:

  • Help us screen for potential risk and fraud (in particular, your IP address); and
  • More generally to improve and optimize the Site (for example, by generating analytics about how our users browse and interact with the Site).

SHARING YOUR INFORMATION

We may utilize third party companies and individuals to provide our Service, or for any of the functions described above. Disclosure of your Device Information to such third parties may occur only to perform such and for no other purpose. We may also share your Device Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

DO NOT TRACK

Unless otherwise required by law, please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

You have the right to access information we hold about you and to ask that your information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident, we note that we are processing your Device Information to pursue our legitimate business interests as noted above. Additionally, please note that your Device Information will be transferred outside of Europe, including to Canada and the United States, you consent to such transfer.

CHILDREN

We do not target children, including those under the age of 13, and do not knowingly collect any personally identifying information about children. To the extent that you believe that we have collected personally identifying information regarding a child under the age of 13, please contact us so that we can rectify the situation.

YOUR CALIFORNIA PRIVACY RIGHTS

This section is specific and applies only to web visitors who are California residents, under the meaning of Section 17014 of Title 18 of the Cal. Code of Regulations. Under the California Consumer Privacy Act of 2018 (“CCPA”), up to twice in a twelve (12) month period, a consumer has the right to request that a business disclose what personal information it collects, uses, discloses, and sells. Information regarding our collection, disclosure, and sale practices are detailed below, in addition to instructions on how to exercise your rights regarding your personal information.

What Personal Information Do We Collect?

We collect, and have collected personal information about our visitors in the preceding 12 months in the following categories:

Categories of Personal Information Types of Personal Information Collected
Identifiers, or information that identifies, relates to, describes, or is capable of being associated with, a particular individual Email address;
Internet Protocol address
Internet or other electronic network activity information Time and date of your visit to the Site;
Time spent on the Site;
Referring and exit web pages;
Specific webpages you visited, including any third party sites reached through the Site;
Internet service provider;
Domain name servers;
Types of computers or devices accessing the Site;
Web browser type and version;
Behavioral data (opens, clicks)
Geolocation information Geographic region based on IP address;
Area code and zip code associated with your web server
Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behavior, etc. Inferences about an individual’s propensity to respond to a particular email advertisement

The above personal information is required to provide you with the ability to access and interact with the Site. We collect the above personal information directly from you via the Site, including from cookies, log files, tags, web beacons, and tracking pixels on the Site. We use and store cookies on your computer to facilitate and customize your use of our Site. A cookie is a small data text file, which is stored on your computer's hard drive (if your web browser permits) that can later be retrieved to identify you to us. Cookies make your use of the Site easier, make the Site run more smoothly, and help us to maintain a secure Site. The cookies may collect information about you, such as the referring website address, your IP address, your browser type and version, your Internet service provider, the area code and zip code associated with your server, the time and date of your visit, and the time spent on the Site.

The above personal information is required to provide email advertising services to you, and to allow you to access and interact with email advertisements. The above personal information is used to track consumer interaction with our email advertisements (counting ad impressions, verifying positioning, and verifying quality of ad impressions). We collect the above personal information directly from you when you open and/or click on the email advertisements which we send you, as well as if you request to unsubscribe from receiving future email advertisements from us.

We also collect the above personal information through advertising networks, data analytics providers, operating systems and platforms, and consumer data resellers/brokers.

The collection of personal information in the categories of capable of being associated with, a particular individual”, “Internet or other electronic network activity information”, “geolocation data”, and “commercial information” are required to: 1) provide you with the ability to access and with the Site and with our email advertisements (counting ad impressions, verifying positioning and quality of ad impressions); 3) advertising/marketing services, including affiliate marketing; and 4) analytics and internal research.

The collection of personal information in the category of “inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behavior, etc.” is required for: 1) advertising/marketing services, including affiliate marketing; and 2) analytics and internal research.

What Personal Information Do We Disclose?

If you elect to unsubscribe from receiving future email advertisements from us, we disclose your email address to our third party advertisers through a suppression file, to comply with CAN-SPAM. To the extent legally required to comply with applicable laws and regulations,or to respond to a lawful request, or to otherwise protect our rights, we may also disclose any of the above personal information. As we continue to develop our business, we might sell or buy assets. In such transactions, personal information collected through the Site may be one of the transferred business assets. Also, in the event that we, or substantially all of our assets, are acquired, such personal information will be included within the transferred assets.

What Personal Information Do We Sell?

Under the definitions of “Sell” and “Sale” in the CCPA, we do not sell your personal information, nor do we sell the personal information of minors under 16 years of age, without affirmative authorization. There are no financial incentives to disclose.

Your Right to Request to Know and How to Submit a Verified Request to Know

A “request to know” is request related to the personal information that a business has about such consumer. It may include a request for any or all of the following from us:

  1. specific pieces of personal information that we have about you;
  2. categories of personal information we have collected about you;
  3. categories of sources from which the personal information was collected;
  4. categories of personal information that we have sold or disclosed for a business purpose about you;
  5. categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  6. the business or commercial purpose for collecting or selling the personal information.

The CCPA permits requests to know from the same consumer up to twice in a twelve (12) month period.

To submit a request to know, please click here, or email your request to [email protected] To process your request, you may be required to submit your name and email address in conjunction with your request. The name and email address which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for information, proof of your consent to utilize such authorized agent as well as verification of your own identity may be required before processing the request. The information which you submit in conjunction with your request to know will be used for the express purposes of verification and providing you with responsive information to your request, if required.

Your Right to Request Deletion and How to Submit a Verified Request to Delete

You have the right to request the deletion of any personal information which we have collected about you, or which we maintain. To submit a verifiable request to delete, please click here, or email your request to [email protected] To process your request, you may be required to submit your name and email address in conjunction with your request. The name and email address which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for deletion, proof of your consent to utilize such authorized agent as well as verification of your own identity may be required before processing the request. The information which you submit in conjunction with your request to delete will be used for the express purposes of verification and fulfilling your request, if required.

A two-step process must be utilized for online requests to delete, whereby you clearly submit your request to delete, and second, you separately confirm that you want your personal information deleted.

To the extent that your personal information is necessary for us to maintain for a reason delineated in Cal. Civ. Code § 1798.105(d), including but not limited to complete a transaction for which the personal information was collected, provide a good or service you have requested, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug, etc., or to comply with a legal obligation, we are not required to comply with your request for deletion. For instance, we are not required to delete personal information which is necessary to maintain suppression files for those individuals who have opted out of receiving email marketing from us. If we are unable to verify your request, we will notify you as well.

Your Right to Non-Discrimination for the Exercise of Your Privacy Rights

California affords consumers with the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA. This means that you cannot be denied goods or services; be charged different prices or rates; be provided with a different level or quality of goods or services; or have it suggested that you will receive a different price or rate or different level or quality of goods or services. Notwithstanding the above, a business can charge a consumer a different rate or price, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to the consumer by the consumer’s data. Further, notwithstanding the above, a business may offer financial incentives for the collection of personal information, the sale of personal information, or the deletion of personal information, and may also offer a different price, rate, level, or quality of goods or services to the consumer if that different is directly related to the value provided to the consumer by the consumer’s data.

CHANGES

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. Upon updating, we will post an updated date.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail at: 31 Union Square, Somerville, MA, 02143, United States. Further, if you have a disability which interferes with your ability to access this policy, we can make accommodations to present the policy in an alternative format, to assist you. If you would like to receive this information in another format that is accessible to your needs (for example: audio, large print, etc.) please contact us.