Effective Date: August 1, 2019
You must be 18 or older to use our Services. Minors under 18 and at least 13 years of age are only permitted to use our Services through an account owned by a parent or legal guardian with their appropriate permission and under their direct supervision. We do not knowingly collect or solicit Information from anyone under the age of 13 or knowingly allow such persons to register for the Service. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at DataPrivacy@prioritydesigns.com.
What Information We Collect and How We Collect It
We collect information about you in a variety of ways including, without limitation: via phone call, our Website, information submitted via email, physical mail, online or physical questionnaires or forms, business cards collected by us and/or our affiliates or service providers while at events, conferences, or otherwise, orally, or otherwise collected by us during our provision of services in the ordinary course of business. We may also collect information about you from third-party sources, with the understanding that, if expressed consent is required based on where you reside and/or where the information about you was collected, we take steps to obtain assurances from such sources that you gave your consent to the sharing of such information when you provided such information to such third party. For the purpose of performing our Services, we collect the types of information about you about you falls into the following categories:
- “Personal Data” means details about you, including without limitation your legal name; place of residence; phone numbers; email address; birthdate; age; employment-related information, (such as name of employer, position/job title, time of service, etc.); education-related information, such as high school and college transcripts, majors, etc.
- “Sensitive Data” means information about you that we normally would not require you to provide such as you race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health information, sexual orientation or criminal record. Please do not post or add Sensitive Data to any information sheet, inquiry, survey, online form, or other content that you provide to us that you would not want to be publicly available. If you are asked for this information, and if you are an EEA data subject, as that term is defined by the GDPR, your expressed consent is needed before you provide that information and the information will be held separately from your other information and be encrypted and/or pseudonymised.
- Information collected automatically which means that whenever you interact with our Services, third-party vendors that we engage with automatically receive and record information. The information or third party vendors collect is about the device and applications you use to access emails sent through our Services, such as your IP address, your operating system, your browser ID, browser types, time and date, subject of advertisements clicked or scrolled over, click stream information, and other information about your system and connection (“Device Information”). This includes information collected when you use a mobile platform such as your unique device ID (persistent / non-persistent), hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), your device name, your location (based on your IP address), etc. Our third-party vendors may also collect usage data about you whenever you interact with emails sent through the Services, which may include dates and times you access emails and your browsing activities (such as what pages are viewed), and information regarding the performance of the Services, including metrics related to the deliverability of emails and other electronic communications our Members send through the Services. This information allows us to improve the content and operation of the Services, and facilitate research and analysis of the Services (“Product Usage Information”). We may also collect information regarding your activity when you are using the Services (both individually and on an aggregate basis) and your interactions with other users of the Services, as applicable to the particular function of the Services that you are using. Some of our Services allow advertisers and their networks to collect and use certain Device Information and/or Product Usage to provide advertisements of interest to you. These third party vendors typically use a cookie or third party web beacon to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit networkadvertising.org.
Our Legitimate Basis and Why We Collect and How We Use Your Information and our Legitimate Basis for Doing So
We process Personal Information (and potentially Sensitive Information) about you as a data controller as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; and ensuring the security of the Services and our Website as set forth more specifically below. We may need your Personal Information to perform a contract with you and, in some cases, we may have a legal obligation to collect Personal Information from you. Where required by law, we collect Personal Information and/or Sensitive Information only from where we have your express consent to do so.
How we use your information will depend on which Services you use, how you use those Services and the choices you make in your settings. The primary reason we collect Information is to provide and improve our Services, for their products and services, and to provide you with a more customized experience on our Services.
The following is a summary of more specific ways we may use your information:
- To deliver the Services to you, including processing applications and registrations to participate in our Services
- To correspond and communicate to you with respect to delivering the Services
- To notify you about any changes to our Services to you
- To provide payment processing and account management, operate, measure and improve our Services, keep our Service safes, secure and operational, and customize Website content
- As part of our efforts to keep you safe and secure
- To contact you regarding your account or Services you have purchased
- To respond to your requests or questions
- To troubleshoot problems with your account, to resolve a dispute
- For our administrative, accounting, and business needs such as billing, invoicing, internal accounting and record-keeping requirements as well as other related administrative and business purposes
- To send you transactional communications. For example, we might send you emails about your registration for an event. We might also contact you about this policy or our website terms and/or to send an email on behalf of our marketing partners
- To provide other services requested by you as described when we collect the Information
- To share with our marketing partners for marketing purposes or to use for our own marketing purposes, e.g., to send you information about events or special promotions, to tell you about new features or products, etc.
- To determine your level of engagement with email or promotional marketing materials that are send to you, including whether you opened an email or promotional marketing materials and/or otherwise engaged with it
- To improve our Services, for example by reviewing information associated with stalled or crashed pages experienced by users allowing us to identify and fix problems and give you a better experience
- For security purposes. To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities and/or attempts to harm our users
- To monitor and improve the information security of our Websites and mobile applications
- To comply with governmental regulations or to respond to a subpoena or other governmental, court, administrative order/requirement
- To hire, train, and manage our staff
- To support the functions of our human resource management, including the coordination of third-party vendors that provide insurance and personal financial services such as retirement planning and savings and investment accounts
- To carry on our business and serve our customers as described above
- For other purposes with your consent
- We may combine information received from other sources with information you give to us and information we collect about you.
We may use this information and the combined information for the purposes set out above. The collection of personal information shall be limited to that which is necessary for the purposes identified above.
How Your Information Is Shared
We may share non-personally identifiable information, such as Device Information, Product Usage Information and/or aggregated user statistics with third parties.
We may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and in the following circumstances:
Internally With our Employees/Agents
We will share your information with our employees/agents who are responsible for providing you the Services in line with the scope of their employment/agency with us.
We use Facebook to help us market to you. You can review Facebook’s Data Policy here.
Information collected by the Google Analytics cookie is transmitted to, and stored by, Google in accordance with its privacy practices. To see an overview of privacy at Google and how this applies to Google Analytics, please visit: https://support.google.com/analytics/answer/6004245. To opt out of Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout.
Business Transfers (Including Target/Purchasers’ Agents and Advisors)
We may choose to buy or sell assets. In these types of transactions, customer / user information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired or merged, or if we go out of business, enter bankruptcy, or go through some other change of control, Information would be one of the assets transferred to or acquired by a third party.
Protection of Company and Others
We reserve the right to access, read, preserve, and disclose any Information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, interests, or safety of our Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Where we believe that an emergency, illegal activity or some other reasonable basis exists for notifying the relevant authority or if necessary to protect the vital interests of any person.
Aggregated and Anonymized Information
We also may share (with our current or potential clients) aggregated or anonymized information that does not explicitly identify you or any individual user of our Services.
Cookies and Other Tracking Technologies
What are Cookies?
“Cookies” are text files transferred to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are widely used to make websites work more efficiently, recognize your browser or device, improve your user experience, customize features and advertising, and provide reporting information about the Services. Cookies, for example, enable us to keep track of your movement from page to page so you do not get asked for the same information you have already provided us. Cookies also allow you to proceed through many pages of a website quickly and easily without having to authenticate or reprocess each new area you visit.
You can configure your desktop or mobile browser’s settings to reflect your preference to accept or reject cookies, including how to handle third-party cookies (see How Can I Manage Cookies? below).
You can find out more information about cookies at http://www.allaboutcookies.org and http://www.youronlinechoices.eu.
In addition to cookies, there are other similar technologies used by us and elsewhere on the web or in mobile sites or applications. Web beacons, browser storage and plugins and other technologies often work in conjunction with cookies, and may store small amounts of data on your device.
While specific types of cookies and technologies may change from time to time as we improve and update the Services, cookies used by the Services generally fall into the categories below:
- Security and Authentication (Strictly Necessary Cookies): These cookies are essential to provide you with the Services and to use some of its features, such as access to secure areas. Without these cookies, we can’t provide parts of the Services that you request, like secure login accounts and transactional pages.
- Performance & Functionality Cookies: We use performance cookies to analyze how the Services are being accessed and used, or how the Services are performing to maintain, operate and continually improve the Services and provide a better overall user experience. Functionality cookies record information about choices you’ve made and allow us to customize the Services to you. When you continue to use or return to the Services, we can remember choices you make (such as login credentials, language preference, country location or other online settings) and provide the personalized or enhanced features that you select. We also employ Google Analytics to help understand how the Service is used. (See below for more information about Google Analytics.)
- Advertising or Targeting Cookies: These cookies allow us and third parties to gather information about the content you’re browsing, your visit, or your interaction with ads and our communications, and to display ads that are relevant to you and measure their effectiveness. Certain third party cookies may also track your activity across various sites to display ads relevant to you and your interests on third party sites and applications. Most advertising or targeting cookies set by the Services belong to our service providers.
What Third-Party Cookies do we use?
We use Google Analytics’ which Google uses the information shared by sites and apps to deliver our services, maintain and improve them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalize content and ads you see on Google and on our partners’ sites and apps. To learn more about the Company’s use of Google Analytics and what Google Analytics does, please see How Google uses information from sites or apps that use or services.
To opt-out of Analytics for the web, visit the Google Analytics opt-out page and install the add-on for your browser. For more details on installing and uninstalling the add-on, please see the relevant help resources for your specific browser.
Updates to your browner or operating system may affect functionality of the opt-out add-on. Learn about managing add-ons for Chrome here. If you are not using Chrome, check directly with the manufacturer of your browser to determine whether add-ons will function properly on the browser version that you are using.
The latest versions of Internet Explorer sometimes load the Google Analytics opt-out add-on after sending data to Google Analytics. Therefore, if you are using Internet Explorer, the add-on will set cookies on your computer. These cookies ensure that any collected data is immediately deleted from the collection server. Please make sure that third party cookies aren’t disabled for your Internet Explorer browser. If you delete your cookies, the add-on will, within a short timeframe, reset these cookies to ensure that your Google Analytics browser add-on remains fully functional.
The Google Analytics opt-out browser add-on does not prevent data from being sent to the website itself or in other ways to web analytics services.
How You Can Manage Cookies?
You can choose whether or not to accept cookies and other technologies, as explained below. However, you should be aware that disabling cookies may prevent you from enjoying the full functionality of the Services.
Most browsers allow you to change your cookie settings. The “Options” or “Preferences” menu of most browsers detail how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Your browser’s settings may also allow you to disable or delete similar technologies and data used by browser add-ons (such as Flash cookies), for instance by changing the add-on’s settings or clearing browser storage. Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information:
- Google Chrome
- Internet Explorer
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
- Opera Mobile
For other browsers, please consult the documentation that your browser manufacturer provides.
If you only want to limit third party advertising cookies, you can turn off most of these cookies by visiting the following links (but be aware that not all of the companies listed on these sites drop cookies via our Services):
Your Online Choices
Network Advertising Initiative
Digital Advertising Alliance
You can also exercise your Website cookie preferences by visiting the TRUSTe preference center by clicking this link: http://preferences-mgr.truste.com/
Disabling Most Interest Based Advertising:
Most advertising networks offer you a way to opt out of Interest Based Advertising. If you would like to find out more information, please visit http://optout.aboutads.info/?c=2&lang=EN or http://www.youronlinechoices.com.
You can opt out of having your mobile advertising identifiers used for certain types of Interest Based Advertising, including those performed by us, by accessing the settings in your Apple or Android mobile device and following the most recent published instructions through the Digital Advertising Alliance’s YourAdChoices. In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads. If you opt out, we will remove all data about you and no further data collection or tracking will occur. The random ID we (or our third party partners) had previously assigned to you will also be removed. This means that if at a later stage, you decide to opt-in, we will not be able to continue and track you using the same ID as before, and you will for all practical purposes be a new user to our system.
For Google Analytics, you can opt-out through Google Ads Settings, Ad Settings for mobile apps, or any other available means (e.g. the NAI’s consumer opt-out listed above). Google also provides a Google Analytics opt-out plug-in for the web.
Please note that even if you opt-out and limit cookies or these third party tracking technologies, they may still collect data and you may still see ads, but they will not be targeted based on information collected through these technologies.
What is Do Not Track?
Do Not Track is a privacy preference that users can set in their web browsers. Some Internet browsers – like Internet Explorer, Firefox, and Safari – include the ability to transmit “Do Not Track” or “DNT” signals. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Since uniform standards for “DNT” signals have not been adopted, we do not currently process or respond to “DNT” signals. We deploy cookies and other technologies on our Service to collect information about you and your browsing activity, even if you have turned on the Do Not Track signal.
EEA Data Protection Rights
If you are based in the European Economic Area (“EEA”) you have rights under the General Data Protection Regulation (“GDPR”): (i) access your Personal Data/Sensitive Data by asking us in writing for a copy of your Personal Data/ Sensitive Data; (ii) to review and correct inaccuracies in your Personal Data/Sensitive Data; (iii) delete Personal Data/Sensitive Data that is no longer necessary or relevant; (iv) restrict processing of your Personal Data; and (v) to receive a copy of your Personal Data/ Sensitive Data in a structured machine-readable format. Additionally, you can object to the continued processing of your Personal Data/ Sensitive Data hereunder in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement). Likewise, where we rely solely on your consent as our grounds for processing your Personal Data/ Sensitive Data above, you may withdraw your consent at any time; subject to the limitations and disclosures set forth above regard the effect such demands or withdrawals may have on our ability to continue providing the products and/or services in the manner originally requested. You may also object to processing that is described above as being based on our legitimate interests alone. In such instances, our business interests must be found to be compelling and to not jeopardize your individual rights before further processing may continue.
You have the right to complain to a data protection authority about our collection and use of your Personal Information and/or Sensitive Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
We respond to all requests received from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
Your rights above are subject to certain limitations under the GDPR. For more information about exercising your rights, see the Request to Exercise Individual Rights below.
Opting Out / CAN-SPAM / Electronic Communications
To keep your Information accurate, current, and complete, please contact us at DataPrivacy@prioritydesigns.com. We will take reasonable steps to update or correct your Information in our possession that you have previously submitted via the Services.
From time to time, we may send you emails regarding updates to our websites, mobile applications or products/services, notices about our organization, information about products/services we offer, business opportunities, or promotional offers we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain Services-related email communications, e.g., account verification, confirmations of transactions, technical or legal notices as those are considered transactional and necessary for account management. The only way to effectively opt out of transaction emails is to close your account(s) with us and cease engaging/interacting with us via Services.
The CAN-SPAM sets the rules for commercial email, establishes requirements for commercial messages, and gives recipients the right to have emails stopped from being sent to them. If, at any time, you would like to unsubscribe from receiving future emails, you can email us at DataPrivacy@prioritydesigns.com and we will promptly remove you from email communications.
We take appropriate and reasonable technical and organizational measures to protect your Personal Information/Sensitive Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information/Sensitive Information. For further information about our security practices, please see our Security page here. If you have any questions about the security of your Personal Information, you may contact us at DataPrivacy@prioritydesigns.com.
If you have an account with us that requires a username and password to log in, you must keep their username and password secure, and never disclose it to a third party.
We retain Personal Data/Sensitive Date where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our Services.
- Whether you have the ability to access and delete the data within your account.
- Whether you would reasonably expect that we would retain the data until you remove it or until your account is closed or terminated.
When we have no ongoing legitimate business need to process your Personal Data/Sensitive Data we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data/Sensitive Data has been stored in backup archives), then we will securely store your Personal Data/Sensitive Data and isolate it from any further processing until deletion is possible.
California Privacy Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal Information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Priority Designs, 100 South Hamilton Road, Columbus, Ohio 43213. We will respond to one request per California customer each year, and we do not respond to requests made by means other than as set forth above.
California Do Not Track Disclosure: Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Web browser “do not track” settings or signals. We deploy cookies and other technologies on our Service to collect information about you and your browsing activity, even if you have turned on the Do Not Track signal.
As pf January 1, 2010, if you a California Resident, you may have additional rights under the California Consumer Protection Act (“CCPA”). You may also request that we delete or amend all or part of your Information. To submit a verified request, please contact us DataPrivacy@prioritydesigns.com and title the subject of your email “California Privacy Rights Request”. In response, we will request information from you to verify your identity.
In some cases, we will not be able to delete your Information, including, if we need it to:
- Complete a transaction or provide service to you or perform or perform our obligations under your Subscriber agreement;
- Detect security incidents or protect against deceptive, fraudulent or illegal activity;
- Identify and fix errors in any functionality;
- Exercise free speech or aid another in the same;
- Comply with a legal obligation;
- Engage in scientific research; or
- For our internal uses that are reasonably aligned with you expectations of us and our Services.
For more information about exercising your rights, see the Request to Exercise Individual Rights below.
Nevada Residents: Rights under Nevada Law
As of October 1, 2019, if you are a Nevada resident, you may opt-out of the sale of your Personal Information. To do so, please contact us at DataPrivacy@prioritydesigns.com and title the subject of your email “Nevada Privacy Rights Opt-Out Request”. In response, we will request information from you to verify your identity. We will respond to your request, once verified, within 60 calendar days (with a possible 30 day extension upon notice to you).
For more information about exercising your rights, see the Request to Exercise Individual Rights below.
Request to Exercise Individual Rights
To exercise any of your rights as described in the “EEA Data Protection Rights”, “California Data Rights” and “Nevada Residents: Rights under Nevada Law” sections above please contact us in writing, via email or postal mail as indicated above, so that we may consider your request under applicable law. Please be aware that your request will not be accepted for review unless you provide the following:
- The name, user ID, pseudonym, email address, or other identifier that you have used to use our Platform, or if you are not a registered user of the service, or have not otherwise previously interacted with us, your first and last name and an address where we can correspond with you.
- State or Country in which you are located.
- Clear description of the information or content you wish to receive or to be deleted or corrected, or the action you wish to be taken; and
- Sufficient information to allow us to locate the content or information to be deleted, removed or corrected
For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request.
In addition, please note that, depending on the nature of your inquiry, request or complaint, we may need to verify your identity before implementing your request and may require proof of identity, such as in the form of a government issued ID and proof of geographical address.
We will try to comply with your request as soon as reasonably practicable. However, we reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive) and/or, in some cases, to charge a fee that takes into account the administrative costs for providing the information or the communication or taking the action requested.
Questions or Concerns
For EEA Residents
For purposes of the GDPR, when Priority Designs is the controller of your Personal Data/Sensitive Data. Our Data Protection Office can be contacted as follows:
For Non-EEA Residents
ATTN: Privacy Officer
100 South Hamilton Road
Columbus, Ohio 43213