Effective Date of Current Policy: 10/01/2018
3. TRANSPARENCY/NOTICE—TYPES of Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with ProProject Bookkeeping and the requirements of applicable law. Some of the ways that ProProject Bookkeeping may collect Personal Information include:
o You may provide Personal Information directly to ProProject Bookkeeping through interacting with the Services, participating in assessments or quizzes via the Services, and requesting Services, or information.
o As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1. Types of Personal Information We Collect
ProProject Bookkeeping collects Personal Information regarding its current, prospective, and former customers, users, visitors and guests (collectively "Individuals").
Information You Provide Directly to Us. When you use the Services or engage in certain activities with ProProject Bookkeeping such as requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
Communications with Us. We may collect Personal Information from you such as email address or phone number when you choose to request information about our Services, register for ProProject Bookkeeping’s newsletter, request to receive customer or technical support, or otherwise communicate with us.
Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
Information Submitted Via Services. ProProject Bookkeeping will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
3.2. How PROPROJECT BOOKKEEPING Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested. ProProject Bookkeeping may use information about you to fulfill requests for Services or information, including information about potential or future Services, including to:
Generally manage Individual information;
Respond to questions, comments, and other requests;
Contact you to answer requests for customer support or technical support.
Administrative Purposes. ProProject Bookkeeping may use Personal Information about you for its administrative purposes, including to:
Measure interest in ProProject Bookkeeping’s Services;
Develop new products and Services;
Ensure internal quality control;
Verify Individual identity;
Communicate about Individual activities on ProProject Bookkeeping’s Services and systems, apps and software, and, in ProProject Bookkeeping’s discretion, changes to any ProProject Bookkeeping policy;
Send email to the email address you provide to us for informational and operational purposes, such as Account management, customer service, or system maintenance;
Process payment for Services purchased;
Prevent potentially prohibited or illegal activities;
Enforce our Terms.
Marketing ProProject Bookkeeping Services. ProProject Bookkeeping may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. ProProject Bookkeeping may provide you with these materials by phone or email, as permitted by applicable law. Such uses include:
To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you;
To provide Services to you;
For other purposes disclosed at the time that Individuals provide Personal Information; or
Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.
Direct Mail and Email Marketing. Individuals who provide us with Personal Information may receive periodic emails, newsletters, or mailings from us with information on our Services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
Anonymous and Aggregated Information Use. ProProject Bookkeeping may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access ProProject Bookkeeping’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and ProProject Bookkeeping may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within ProProject Bookkeeping and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Other Uses. ProProject Bookkeeping may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3. Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Google. We may use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4. THIRD-PARTY WEBSITES AND SOCIAL MEDIA PLATFORMS The Site may contain links to other websites and other websites may reference or link to our Site or Services. These other domains and websites are not controlled by us, and ProProject Bookkeeping does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Site and our Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
3.5. Third-Party Payment Processing When you make a payment to use any portion of the Services, we process it through a Third-Party application. The Third-Party application may collect certain financial information from you to process a payment on behalf of ProProject Bookkeeping, including your name, email address, address and other billing information.
4. Onward Transfer— ProProject Bookkeeping May Disclose Your Information
4.1 Information We Share
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. [ProProject Bookkeeping has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce ProProject Bookkeeping policies or contracts; (v) to collect amounts owed to ProProject Bookkeeping; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
4.2 Data Transfers
All Personal Information collected via or by ProProject Bookkeeping may be stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to ProProject Bookkeeping, you consent to the storage of your Personal Information in these locations.
5. Opt-Out (RIGHT TO RESTRICT PROCESSING)
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to ProProject Bookkeeping’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting email@example.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
5.2 Email Communications
We maintain "do-not-mail" lists as mandated by law. We process requests to be placed on do-not-mail and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
5.3 "Do Not Track"
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.4 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
6. Rights of Access, Rectification, Erasure, and Restriction
Although ProProject Bookkeeping makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which ProProject Bookkeeping is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If ProProject Bookkeeping determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, ProProject Bookkeeping will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. Data Retention
8. Security of Your Information
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
10. Children’s Privacy
The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and ProProject Bookkeeping does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information.
11. Redress/Compliance and Accountability
12. Other Rights and Important Information
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, ProProject Bookkeeping will endeavor to comply with the law or contract.
12.2 California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. ProProject Bookkeeping does not share Personal Information with Third Parties for their own marketing purposes.
The following capitalized terms shall have the meanings herein as set forth below.
"Agent" means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, ProProject Bookkeeping or to which ProProject Bookkeeping discloses Personal Information for use on its behalf.
"Personal Information" is any information relating to an identified or identifiable natural person (“Individual”).
"Process" or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
"Third Party" is any company, natural or legal person, public authority, agency, or body other than the Individual, ProProject Bookkeeping or ProProject Bookkeeping’s Agents.
14. Revision history
Title (Effective Date)