Effective Date: 02/25/2022
The chart in this section details the categories of Personal Data that we collect and have collected over the past 12 months:
Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
“You” When you provide such information directly to us. When Personal Data about you is automatically collected in connection with your use of our Services (see the subsection titled“Information Collected Automatically” below).
“Third Parties” Third parties that provide us with Personal Data about you. Third Parties that share your PersonalData with us include: Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
Social networks connected to the services. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into yourAccount with us.
Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
Information Collected Automatically
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences”or “options” section of your browser’s menu. To find out more information aboutCookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
How We Use Your Personal Data
We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services.Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at email@example.com.
How We Share Your Personal Data
Categories of Third Parties with Whom We Share Personal Data
We disclose your Personal Data as indicated in the chart above to the following categories of service providers and other parties:
Your Personal Data may also be transferred to a third party if we undergo a merger, acquisition, bankruptcy orother transaction in which that third party assumes control of our business (in whole or in part).
Categories of Third Parties with Whom We Share Personal Data
We disclose your Personal Data to service providers and other parties for the following business purposes:
Data Security & Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, theServices use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. We retain Personal Data about you for as long as you have an open account with us and for six months after termination of your account for archival and billing purposes, or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We retain a user’s subscription and purchase history indefinitely for archival purposes.
Personal Data of Children
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your PersonalData to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12months, we will identify the categories of Personal Data sold to each category of third party recipient.
You have the right to request thatwe delete the Personal Data that we have collected about you. Under the CCPA,this right is subject to certain exceptions: for example, we may need to retainyour Personal Data to provide you with the Services or complete a transactionor other action you have requested. If your deletion request is subject to oneof these exceptions, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data such as your account login credentials (i.e. username and password), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Personal Data Sales Opt-Out and Opt-In
In this section, we use the term ‘sell’ as it is defined in the CCPA. We sell your Personal Data, subject to your right to opt-out of these sales. As described in the “Information Collected Automatically” section above, we have incorporated Cookies from certain Third Parties into our Services. These Cookies allow those Third Parties to receive information about your activity on our Services that is associated with your browser or device. Those Third Parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under some state laws, sharing your data through Third Party Cookies for online advertising may be considered a “sale” of information. Except for these sales through Third Party Cookies, we don’t sell your Personal Data. You can opt out of these sales by following the instructions in this section.
You have the right to opt-out of the sale of your Personal Data. You can opt-out using the following methods:
Over the past 12 months, we have sold the following categories of your Personal Data to third parties:
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months. We do not sell the Personal Data of minors under 16 years of age without affirmative authorization. If you are between 13 and 16 years of age, you must authorize us to sell your Personal Data. If you are under 13 years of age, your parent or guardian must authorize us to sell your Personal Data.
We Will Not Discriminate Against you For Exercising Your Rights under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at firstname.lastname@example.org. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
European Union Data Subject Rights
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the“GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Sagelink may be the controller of your Personal Data processed in connection with the Services.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “How We Use Your Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Examples of these legitimate interests include:
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
EU Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at [firstname.lastname@example.org].Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Sagelink and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Sagelink in the U.S. and will be hosted on U.S.servers, and you authorize Sagelink to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the EuropeanCommission.