Last Updated: March 13, 2020
DATA CONTROLLER DISCLAIMER
PERSONAL Information Collection & USAGE
Information Provided by You
We utilize analytic services, including, without limitation Google Analytics to capture and analyze visits and traffic in using the Services. These analytic services collect information about your use of the Services, including, without limitation, information about your visit to the Site and/or Application, any referral website, the type of web browser and operating system you are currently using, and your network location and IP address. The information collected by these analytic services is anonymous and aggregated. We reserve the right to use this information for any lawful business purpose, including selling or sharing the aggregated and anonymized data collected, whether by us or a third party service provider. We may also use this aggregated and anonymized data to analyze trends or seek third party advertisers.
The personal information we collect depends on the context of your interactions with us and our Services, the choices you make related thereto, and the features you use. The personal information we collect can include the following:
- User Account. We collect information about you when you register for a customer account, create or modify your profile, and/or set preferences through our Services. For example, you provide your contact information when you created an account to use our Portal.
- Content you provide through our Services. We collect and store information about content that you post, send, receive and share. This content includes any information about you that you may choose to include.
Information Collected Automatically & Through Our Services
We may automatically collect certain information when you visit, use or navigate the Services. This information is non-personal and does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, browsing history on the Services, the length of time spent on certain pages, Internet service provider, date/time of visit information, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain security and operation of our Services, and for our analytics and reporting purposes.
We may also collect Personal Information about you for other purposes from time-to-time, or as permitted or required by law. We will always identify any additional purpose prior to or at the time of collection.
Perrill’s Information Usage
- provide you with the Services;
- evaluate and improve the Services, products, services, marketing, and your experience;
- monitor and analyze trends, usage, and activities;
- personalize the Services and provide content or features that match user profiles;
- respond to your inquiries or requests;
- communicate with you; and
- provide you with offers and promotions that we feel may be of interest.
- conduct statistical analysis of Users’ interactions with the Services;
- troubleshoot service issues or interruptions;
- conduct research and for commercial purposes, such as to update and improve the Services;
- understand the demographics of our users and their browsing habits; and
- provide you with promotional messages and advertisements, both while you are using the Services and after.
We may process or share data, including Personal Information, for the following reasons:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Performance of a Contract: Where we have entered into a contract with you and/or a third-party provider on behalf of you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, government requests, judicial proceeding, court order, or legal process, such as in response to a court order of a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Consultants or Other Third-Party Service Providers: We may share your data with third party service providers, contractors or agents who perform services for us or on our behalf or for whom we provide services and require access to such information to do that work. Examples include: payment processing, data analysis, e-mail delivery, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. Unless described in this Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.
- Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.
We may also share non-personal information with select third-parties, such as our advertisers, for purposes of serving you with customized promotions. If you would like to learn more about the sharing of non-personal information for purposes of providing customized advertisements or promotions, please visit http://www.aboutads.info/consumers/.
PERSONAL INFORMATION STORAGE & SAFETY
COOKIES AND OTHER TRACKING TECHNOLOGIES
Cookies are small files that are sent to and stored in your computer by the websites you visit. Cookies are stored in your browser’s file directory. Cookies may be stored only for the time you are in a given site or they may remain stored in your browser for a defined period of time beyond your current session. Cookies work in combination with content within the website itself, to capture and remember information. To learn more about these technologies and how they work, please see www.allaboutcookies.org.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can review the options available to manage cookies in your browser. One option is to disable, or turn-off, all cookies. If you turn cookies off, you may not be able to browse the Site. If you disable certain kinds of cookies, some aspects of our Site may not function properly or as well.
SAFETY OF YOUR INFORMATION
No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone. If you believe your password has been compromised, please contact us immediately.
If we receive instructions using your Perrill membership login information, we will consider that you have authorized the instructions. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate memberships, and to remove or edit content.
You may have choices when it comes to the collection, use, and sharing of your personal information. You may choose to “unsubscribe” from email marketing communications, or you can contact us at firstname.lastname@example.org to be removed from our email marketing lists or to terminate your membership. Please be aware that you are not able to opt out of receiving communications about your Perrill or related transactions with us unless you terminate your use of our Services.
Accessing Your Information
You must notify us of any change in your Personal Information by updating your Perrill membership profile through our Services. Any changes will affect only future uses of your Personal Information.
You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.
Links to Third Party Sites
Do Not Track
Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not use technology that recognizes DNT signals from your web browser.
The Services is not intended for children under the age of 18 years old. We do not knowingly collect information from children under the age of 18. If we discover that we have information from a child under the age of 18, we will delete it immediately. If you believe that a child under the age of 18 may have provided his or her information to us, please contact us using the contact information below.
VISITING THE SERVICES FROM OUTSIDE THE UNITED STATES
California Residents’ Privacy Rights.
If you are a California resident, California law may require us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
Your California Privacy Rights
If you are a California resident, the CCPA may allow you to make certain requests about your personal information. Specifically, the CCPA may allow you to request us to:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
- Provide access to and/or a copy of certain personal information we hold about you.
- Delete certain personal information we have about you.
- Provide you with information about the financial incentives that we offer to you, if any.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, and other account information. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please use the online web form or contact us at email@example.com.
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our Services, charge you different prices or rates (if any), or provide you a lower quality of Services if you exercise your rights under the CCPA. However, we may have different tiers of Services as allowed by applicable data protection laws (including the CCPA) with varying prices, rates, attributes or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you.
Notice of Right to Opt Out of Sale of Personal Information
California residents may opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that may include when we share your information with third parties to provide you with offers and promotions that we believe may be of interest to you. It also may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.
Depending on what Services you use, we may provide the following categories of personal information to third parties for these purposes:
- For online targeted advertising purposes: demographic and statistical information, user-generated content, device information and identifiers, connection and usage data, geolocation, and social media information.
- For sharing with third parties to send you relevant offers and promotions: contact and membership registration information; demographic and statistical information, user-generated content, and geolocation.
If you would like to opt out of Perrill’s use of your information for such purposes that are considered a “sale” under California law, you may submit a sale opt-out request by emailing us at firstname.lastname@example.org Please note that we do not knowingly sell the personal information of minors under 18 years of age without legally –required affirmative authorization.
California Shine Light
If you live in California and have an established business relationship with us, you can request a list of the Personal Information we have shared with third-parties for their marketing purposes. We will also give you a list of the third-parties that have received your information. You can make a request one time each year.
To exercise your rights, you can e-mail us at email@example.com or write to:
1st Scribe, Inc.
Attn: Alex Pagliano
110 Cheshire Lane, Suite 105
Minnetonka, Minnesota 55305
Mention in your letter that you are making a “California Shine the Light” inquiry. We will respond within 30 days.
1st Scribe, Inc.
Attn: Alex Pagliano
110 Cheshire Lane, Suite 105
Minnetonka, Minnesota 55305