AtlasGuru Inc.
Privacy Policy
Effective Date: July 28, 2019
This Privacy Policy describes the information that we collect through the Services, including the Website, and our policies and procedures surrounding our collection and processing of Personal Data and certain other Information. Capitalized terms that are used but not defined in the main body of this Privacy Policy have the meanings assigned in the Glossary of Terms at Section 12 of this Privacy Policy.
This Privacy Policy applies only to our Services. It does not apply to: (a) any third-party site or service linked to or recommended or referred by our Services, including the Website, or by our staff, or (b) any of our offline activities.
Please read this Privacy Policy carefully. If you have any questions about our practices concerning our collection and processing of your Personal Data, please feel free to reach out to us using our Contact Page.
1. Children
The Services are not intended to collect Information from children or from anyone under the age of 16. If you are aware of children’s Information collected through the Services, please contact us immediately through our Contact Page.
2. Information We Collect
We may collect the following Information through the Services:
- Personal Data, including:
- first name;
- last name;
- e-mail address;
- postal address;
- zip code;
- Usage data;
- telephone number;
- credit card number;
- information about transactions you complete; and
- other information requested through forms you complete.
- Information that cannot be linked to, identify, distinguish, or trace a particular identifiable individual or device, even if combined with other information.
3. How We Collect Your Information
As discussed below in Sections 3(A)-(D), we collect your Information:
- directly from you when you provide it to us or when you make it publicly available using certain functionalities of the Services (e.g., User Contributions);
- automatically as you use the Services (e.g., Usage Data and other Information collected through cookies, web beacons, and other tracking technologies);
- from third parties and otherwise outside of the Services; and
- through integration with social networks.
A. Information You Provide to Us
We may collect Information directly from you, including, without limitation, when you:
- fill in forms on the Website;
- create an account;
- correspond with us;
- respond to surveys or customer questionnaires;
- report a problem with the Services;
- enter a contest or promotion sponsored by us;
- publish or post on public areas of the Services; or
- otherwise provide us with Information in direct communications.
Certain Services contain features that enable users to disclose or publish User Contributions. Although an account is usually required to publicly create and disclose User Contributions using the Services, an account is usually not necessary to view such User Contributions. We can’t control the actions of other users of the Services or anyone else that may view your User Contributions and do not guarantee that your User Contributions will not be viewed by unauthorized persons or used for purposes other than intended. If you choose to make your User Contributions available to others, you do so at your own risk.
B. Information we automatically collect
We may also automatically collect Information, including Personal Data, about you through the Services. This Information may be about you, your online behavior and/or the devices you use to access the Services (“Device(s)”). The Information we collect automatically about may include, without limitation, the make, model, settings, specifications and geographic location of you and/or your Devices. Additionally, we may automatically collect Usage Data. We may collect your information through the Services even if you are not currently using them (e.g., you’re not logged in, or the Services aren’t open on your device). For more information about our use of automatic tracking technologies and certain choices we offer you with respect to them, please see Section 6 below.
C. Information acquired through other means
We may also acquire your Information offline or otherwise outside of the Services. For instance, we may purchase or otherwise acquire Information from third parties. We reserve the right to merge or co-mingle this other Information with your Information collected on or through the Services.
D. Integration with Social Networks
If you use any third-party social networking services (e.g., Facebook, Instagram, etc.) that are integrated with the Services, we may receive your Information that has been made available through those services (e.g., your list of “friends” or other contacts on those services). We may use, transfer, assign, share, and provide access to all of your Information that we receive through third-party social networking services in the same ways as all of your Information we collect through our Services as described in this Privacy Policy.
4. How We Use Your Information; Our Legal Bases for Using Your Personal Data
A. Our Use of Your Information
We use your Information:
- to provide the Services. We use your Information to process your requests to access the Services and certain of their features and to generally present the Services to you. For example, we may use your e-mail address to send you a confirmation notice of transactions you conduct through the Services. Similarly, if you enter a contest that we host, we will use your Personal Data to notify you if you are a winner. Additionally, if you submit User Content through the Services, we may publish your name, screen name, and other Personal Data.
- to administer the Services. We also use your Information for any lawful business purpose in connection with administering the Services. This may include using your Information to provide customer service, diagnose issues with the Services, improve the Services by tailoring them to your preferences, gather broad demographic information, analyze trends, seek compatible advertisers, sponsors, clients and customers, and track users’ movements around the Services and elsewhere on the web or across apps and/ devices. Information that pertains to your geographic location may be used to show you content or features (e.g., advertising and sponsored messaging) based on geographic location.
- to communicate with you about new features, events, products or services offered by us, Third-Party Providers, our advertisers, and other companies and individuals that we have a relationship with.
- in furtherance of legal, health, and safety objectives. We may access, use, and share with others your Information for purposes of health, safety and other matters in the public interest. We may also provide access to your Information to cooperate with official investigations or legal proceedings (e.g., in response to subpoenas, search warrants, court orders, or other legal processes). We may also provide access to protect our rights and property and those of our agents, customers, and others including to enforce our agreements, policies, and the Terms of Service.
- to respond to employment inquiries. If you provide Personal Data to us in connection with an employment inquiry, without limiting the applicability of the rest of this Privacy Policy, we will use your Personal Data to evaluate your job application and for related recruiting, reporting and recordkeeping purposes. We may maintain your Personal Data on file, whether we hire you or not, to administer your relationship with us and/or for job applicant-related reporting and recordkeeping for as long as required or permitted under applicable law.
- in connection with a sale or other transfer of our business. In the event all or some of our assets are sold, assigned, transferred to or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or otherwise, your Information, including your Personal Data, may be among the transferred assets.
C. Access to Information by Third-Party Providers
In order to provide and administer the Services, operate our business, and achieve the other objectives described in this Privacy Policy, we may give certain Third-Party Providers access to your Information, including Personal Data. These Third-Party Providers may assist us with, among other things, improving and providing the Services and tracking how our customers use the Services. Independent contractors that work for us are obligated to keep Personal Data confidential and use it only in accordance with our express instructions. However, we are not responsible for the conduct of any of our independent contractors.
The following is a list of some of our Third-Party Providers:
- Google Analytics. One of our independent contractors is Google Analytics. Google Analytics tracks and reports website traffic and monitors use of our Website. Information collected may be shared with other Google services and used to target the ads of its own advertising network. It is our understanding that you can opt-out of Google Analytics tracking on our Services by installing the Google Analytics opt-out browser add-on that prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page.
- Amazon Web Services (“AWS”). AWS provides cloud host services, including web hosting, storage, compute, database management, and security. AWS stores and processes data collected on the AtlasGuru platform.
- Segment. Segment is a cloud-hosted data integration platform that ingests real-time event data from multiple sources (e.g., Google Analytics) to multiple destinations (e.g., AWS or advertising platforms). Segment helps us collect information, including Personal Data, about our users and organize that information. For more information about Segment’s privacy practices, please visit Segment’s privacy policy.
D. Combination of Personal Data with non-Personal Data
We reserve the right to merge or co-mingle Information about you, your offline and online behavior, and/or your Device that is not your Personal Data with your Personal Data for any lawful business purpose.
E. Our Legal Bases for Using Your Personal Data
When we use your Personal Data, we rely on the following legal bases:
- Fulfilment of our contractual obligations to you;
- Exercise of our legitimate interests in:
- Endeavoring to create an enjoyable experience for all users of our Services;
- Providing customer service;
- Improving our Services and business;
- Protecting our users, personnel, and property;
- Marketing (e.g., sending communications to let you know about new features);
- Reviewing job applications; and
- Addressing legal issues.
- Your consent;
- Compliance with applicable law;
- Protecting the vital interests of the individual or others (e.g., resolution of urgent medical situations); and
- Endeavoring to protect users of our Services.
5. Sharing Personal Data for Marketing Purposes
A. Sensitive Data
We will not sell or rent your Sensitive Data; however, we may transfer Sensitive Data to Third-Party Providers who need access to fulfill a transaction.
B. Sharing Your Personal Data for Marketing
Unless otherwise specified on the Services, we may disclose your Personal Data to, or share it among, our parents, subsidiaries, and affiliates and with other third parties (e.g., as described in Section 4(C)) that support our efforts to notify you of products or services that may be of interest to you and serve you with marketing information and a user experience that are tailored to your interests (e.g., through the use of OBA).
C. Opting Out of Marketing Messages from Us
If you do not want us to send you marketing or other commercial messages, please adjust the applicable setting on the “Your Profile” page of your Account through the Services. However, even if you unsubscribe from receiving such commercial communications from us, we may continue to send you certain communications relating to our administration of the Services (e.g., renewal notifications, invoices, technical notices, updates, security alerts, etc.)
D. How to update your information
If you have registered on any part of the Services, please use the mechanism or contact information on the Services that allows you to change or update your account preferences, if available, to keep all such Personal Data accurate and up-to-date. If no such mechanism or contact information is available on the Services, please send us an email through the Contact Page with your changes and/or adjust the applicable setting on the “Your Profile” page of your Account through the Services.
6. Automatic Data Collection Technologies; Online Behavioral Advertising; Opting Out
A. Our Use of Automatic Data Collection Technologies; Do Not Track
As you use the Services, we may use automatic data collection technologies to collect certain information about you and your equipment, browsing actions, and usage patterns, including:
- details about your use of the Services, including the Website, such as Usage Data, traffic data, location data, logs, and other communication data; and
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
We may use these technologies to collect Information about your online activities over time and across third-party websites or other online services (i.e., behavioral tracking). See Section 6(C) for more information about opting out of behavioral tracking.
The Information we collect automatically may include Personal Data. Additionally, we may associate information that we collect from you that is not Personal Data with Personal Data we collect in other ways. Using Personal Data collected through automatic data collection technologies helps us to improve our Services and to deliver a better and more personalized experience, including by allowing us to:
- understand who uses our Services and how they use the Services;
- retain information about your preferences and customize the Services based on your individual interests;
- optimize your searches;
- recognize you when you come back to our Websites; and
- deliver online behavioral advertising (“OBA”).
The following are some of the technologies we use for automatic data collection, including behavior tracking:
- Cookies (or browser cookies), including session storage and local storage. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to use certain functionalities of the Services or access parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.
- Web Beacons. Certain parts of our Website and our e-mails and other correspondence with you may contain small electronic files known as web beacons (sometimes called clear gifs, pixel tags, and single-pixel gifs) that enable us to, by way of example, count users that have visited those pages or opened an email and for other related website statistics (e.g., recording the popularity of certain website content and verifying system and server integrity).
B. Third-Party Use of Cookies and Other Tracking Technologies
Certain Third-Party Providers (as described in Section 4(C)) may use automatic data collection technologies in our Services, including our Website, in order to assist us with the collection, organization, and other processing of your Information, including to help us deliver a personalized experience to our users. These third parties may use cookies alone or with other tracking technologies to collect Information about you when you use the Services. The Information they collect may be associated with your Personal Data, and they may collect Information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with OBA or other targeted content. Generally, we do not allow third-parties to use tracking technologies through our Services for such third parties’ marketing or advertising purposes.
We do not control these third parties’ tracking technologies or how they may be used. For information about how you can opt out of receiving targeted advertising based on information collected by third parties, see Section 6(c) below.
C. More Choices About Your Information
The following mechanisms may give you more choices about the collection, use, and disclosure of your Information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Services, including the Website, may then be inaccessible or not function properly.
- Online Behavioral Advertising (OBA). If you wish to opt out of OBA, you may be able to do so by visiting http://optout.aboutads.info/, http://www.youronlinechoices.com/uk/, or the NAI Website and/or by clicking the “Ad Choices” icon that appears in certain advertisements that are served through OBA. You may also send us an e-mail through our Contact Page if you wish to opt out of OBA. Please note that the option to opt-out applies only to tracking by Third-Party Providers across the Services and other sites, applications, destinations and services, and not tracking among pages within the Services.
- Third-Party Collection and Use of Your Personal Data. We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative by visiting the NAI Website.
- Do Not Track. Please visit https://allaboutdnt.com/ for information on how you can opt out of behavioral tracking and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
7. Transfer of Your Personal Data among Jurisdictions
We’re based in the State of Washington in the United States of America. We may process and transfer your Personal Data in and to the United States of America and other countries, regardless of where you are. Note that the laws regulating the collection, use, disclosure, and disposal of Personal Data vary from country to country, so applicable law in the country where your Personal Data may be processed may not be as comprehensive or strict as the laws of the country where you’re located.
8. Data Security; Breach Notification
We implement a variety of security measures to maintain the safety of your personal data when you use the Services. We offer the use of a secure server. Any sensitive/credit information that you may supply is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database. Such information is only accessible by those authorized with special access rights to such systems and are required to keep the information confidential, subject to any additional requirements imposed by our contract with them and applicable law. We do not store credit card numbers, social security numbers, or other similar information relating to the processing of transactions on our servers.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password in order to access certain parts of the Services, it is your responsibility to keep this password confidential.
Also, please keep in mind that the transmission of information via the internet is not completely secure. Although we have designed the Services with the protection of your Personal Data in mind, we cannot guarantee the security of your Personal Data transmitted through the Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
In the event that we believe the security of your Personal Data in our control may have been compromised, we may attempt to notify you. In such instances, we may notify you by e-mail, push notification, or otherwise.
9. Your Rights as a Data Subject
We will promptly act on the request of any user of the Services that we:
- Confirm that we have their Personal Data;
- Provide them with access to their Personal Data, including in portable format, that we may possess;
- Correct, update or amend their Personal Data;
- Delete and “forget” their Personal Data; or
- Limit our processing of their Personal Data.
You may always withdraw any consent to process your Personal Data you have provided us and object to our use or disclosure of your Personal Data. Exercise of any of the rights set forth in this section may not apply retroactively from the date a given request is made and doesn’t affect our ability to continue processing Personal Data in accordance with this policy and applicable law. The rights described in this section are subject to certain limitations and exceptions under applicable law.
If you’d like to exercise any of your data subject rights as to your personal data that we may possess, please email us through our Contact Page. When you reach out, please include “Data Subject Access Request” in the request and briefly describe the right or rights you intend to exercise. We may use your Personal Data to confirm your identity before acting on your request.
Finally, you will always have the right to lodge a complaint about our privacy practices with the appropriate supervisory authority. We ask that you contact us first, so we can try to address any concerns that you have about our privacy practices directly.
10. Notice to California Customers
A. Shine the Light
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an e-mail through our Contact Page.
B. Online Erasure
California’s “Online Erasure” law, Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services to allow registered users who are under the age of 18 and residents of California to request removal of their User Contributions. If you fit that description and posted User Contributions on a section of our Services that is directed to minors, you may request removal of the applicable User Contributions by sending us an e-mail at an e-mail through our Contact page. In response to your request, we may elect to make the User Contributions invisible to other users and the public (rather than deleting it entirely), in which case the applicable User Contributions may remain on servers we control and/or may be publicly available elsewhere if a third party copied and reposted the applicable User Contributions.
11. Changes to this Privacy Policy
If we make any changes to this Privacy Policy, we will post the revised Privacy Policy on https://www.atlasguru.com/privacy-policy Where we make significant changes, we may post a notice in certain areas of the Services, including on the https://www.atlasguru.com homepage. You are responsible for periodically visiting this Privacy Policy to check for any changes. The date the Privacy Policy was last revised is listed at the top of the Privacy Policy.
12. Glossary of Terms
The following terms, as used in this Privacy Policy, have the meanings assigned in this Section 12: