1. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following information about you: Personal information including, for example, your name, e-mail address, telephone, information about your usage of the Products and information collected by tracking technologies as further described below that may identify you as an individual or allow online or offline contact with you as an individual. The Underbelly does not collect or process credit or debit card (?Payment Card?) information. Apple and Google collect Payment Card information with respect to subscriptions and in-app purchases made through the Apps, and our payment processor collects Payment Card information with respect to purchases made through the Websites. Such payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they?ve – stored, and your card?s type, expiration date, billing address, and the last four digits of your card number. Feedback written by you and submitted to us via the Apps or email, which we use to improve the Products and occasionally share with Contractors who provide services to The Underbelly.
2. CONFIDENTIALITY AND SECURITY
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org. Except as described under the ?Disclosure of Your Information? section below, we do not provide your personal information to any third party without your specific consent, as defined by applicable law.
3. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS
We periodically provide communications via the email address used to sign up for the Products. If you inform us that you wish to cancel email promotional materials by selecting ?unsubscribe? at the bottom of such communication or by emailing us at email@example.com, we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level. If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Apps, you will receive such SMS message (the ?SMS Service?). Standard text message rates will apply.
4. TRACKING TECHNOLOGIES
The Underbelly and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device so you don’t have to provide the same information several times during one task, recognize that you may have already given a username and password so you don’t need to do it for every web page requested, and to measure how people are using the Products. We use local storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on the Products also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. We partner with third parties, such as Facebook and Google, to manage our advertising of the Products on other sites or platforms as well as across your other devices based on your past visits to our website. Our third-party partners may use technologies such as cookies to gather information about your activities within the Products to deliver such advertising to you, such as retargeting ads. We will acquire consent from you in order to use such trackers for advertising purposes to the extent required by applicable law. We currently do not respond to do-not-track signals. For more information about interest-based ads, including how to opt-out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third-party platforms. You may also opt-out of receiving ads across devices by adjusting your ad preference in your Google account. We use third-party trackers to let us know when users have visited the Products by ?clicking-through? our sponsored advertising or content hosted on third-party platforms. Products use Google Analytics code to gather statistical information. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Products and the volumes of usage of the Products. This is done to ensure that the Products are available when you want them and are fast. For more information on how Google Analytics processes this information, visit www.google.com/analytics. MOBILE ANALYTICS We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application. LOG FILES As true of most websites, we gather certain information and automatically and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
5. WHERE WE STORE YOUR PERSONAL INFORMATION
All information you provide to us through the Products is stored on our secure servers located in the US. Any payment transactions will be encrypted using SSL technology; all payment information is stored with our payment processor and is never stored on The Underbelly?s servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the Products; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
6. CORPORATE AND OTHER COMMUNITY SHARING
There is interest by large consumer communities (companies, universities, hospitals, insurance group, etc.) (?Communities?) to introduce the Products to their employees and members. If you have registered to use the Products through a code or other registration credential furnished by a Community (a ?Community Subscription?), the Community may have access to your name and the date you registered to use the Products and may have access to your usage information on an aggregated basis with all other members of the Community that are using the Products. Your Community may also have access to your usage information on an individual basis if you have provided appropriate consent under applicable law for such sharing. For example, many employers are offering incentive programs based on employee participation in health & wellness programs and desire to better understand how each of their individual employees is using the Products.
7. ACCESS TO AND DELETION OF PERSONAL INFORMATION
Upon request, The Underbelly will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information, please email firstname.lastname@example.org. You may access your personal information to modify or update at any time by emailing email@example.com. To request the deletion of your personal data that we have on file please email us at firstname.lastname@example.org. Upon request, The Underbelly will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. We will respond to your request in a reasonable timeframe.
8. USES MADE OF THE INFORMATION
We use information held about you in the following ways: To ensure that content provided by the Products is presented in the most effective manner for you and for your computer or other device. To provide you with information, products or services related to The Underbelly that you will facilitate your engagement with the Products. To provide you with promotional communications, such as email, to the extent that you have provided consent to receive such communications under applicable law. To provide you with customer service communications. To carry out our obligations arising from any agreements entered into between you and us. To allow you to participate in interactive features of the Products, when you choose to do so. To notify you about changes to the Products. To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as zip code, state or country). To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the Websites. To inform your Community about your registration and use of the Products as described under Corporate and Other Community Sharing in section 6 above. To serve our advertisements to you through third party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent for such uses under applicable law To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them. Details of transactions you carry out through the Products and of the fulfillment of your Product orders. Details of your visits to and interactions with the Products including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access. If you are an existing customer, we will only contact you by electronic means (e-mail or in-Product communication) with information about products and services similar to those which were the subject of a previous sale to you. We do not disclose information about identifiable individuals to companies that host advertisements on our behalf, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
9. DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also disclose your personal information to third parties as follows: In some circumstances, based on your specific requests, we may need to disclose your personal information to a third party so that they can provide a service you have requested from such party, or fulfill a request for information from such party. An example of this is the SMS Service. In some circumstances, we may disclose the personal information that you have provided to The Underbelly to a third party that offers and/or provides goods or services complementary to our own for the purpose of enhancing our users? experiences by offering you integrated or complementary functionality, complementary services or bundled pricing options. If The Underbelly?s service providers (like hosting, market analytics, and payment service providers) require this information to provide services to The Underbelly. The Underbelly requires each of its service providers to agree to maintain the confidentiality and security of your personal information. In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets. If The Underbelly or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets. If we are under a duty to disclose or share your personal information in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of The Underbelly, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. With your Community, if your subscription is a Community Subscription, as described under Corporate and Other Community Sharing above. With third parties, such as Facebook, in order to serve The Underbelly advertisements on such third party platforms, to the extent that you have consented to such practices under applicable law. If you choose to have your account verified to confirm your status as a U.S. military veteran, we may allow a third party platform to access the specific personal information you provide in order to perform the verification.
10. WITHDRAWAL OF CONSENT FOR PROCESSING ACTIVITIES
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such as use of trackers for the purpose of retargeting activities, such consent can be withdrawn at any time by emailing email@example.com.
11. LINKS TO THIRD PARTY SITES
The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal information to these external websites.
12. SOCIAL MEDIA WIDGETS
Our Products include social media features, such as the Facebook Like button, and widgets, such as the ?Share This? button, or interactive mini-programs. These features may collect your Internet protocol address, which page you are visiting on or Products, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Products. Your interactions with these features are governed by the privacy statement of the company providing it.
13. USE OF PRODUCTS BY MINORS
You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement and consent of a parent or legal guardian, under such person’s account and otherwise subject to these Terms.
14. INFORMATION POSTED ON FORUMS
The Underbelly users may have the ability to post content to one or more The Underbelly forums. All such users may request and obtain removal of such posted content by contacting The Underbelly at firstname.lastname@example.org and specifically identifying the content to be removed. Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the The Underbelly forum(s).
15. CHANGES TO OUR TERMS OF SERVICE
16. CONTACT AND EEA REGISTERED AGENT