Privacy & Cookies Policy

Please read the following carefully to understand our practices regarding your personal information and how it will be treated.

HOW AND WHEN WE COLLECT PERSONAL INFORMATION ABOUT YOU 

It is not our intention to collect any personal information about you, however, the we may incidentally collect personal information from you when you:

• contact us or request information from us in any other way;
• visit our website; or
• communicate with us via social networking websites, third party apps or similar technologies.

We will indicate where any personal information we have requested is mandatory or optional. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances this may mean we are unable to provide you with a certain service.

We may also collect information about you from third party sources, such as from your use of other websites which we operate, and from related third parties such as sub-contractors with whom we work.

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU 

We may collect and process personal information about you which you provide to us, such as your contact details (e.g., your name, address, or email address).

If you contact us with a complaint or query, we may keep a record of the correspondence.

PURPOSES FOR PROCESSING YOUR PERSONAL INFORMATION

We may process your personal information for the following purposes:

• to provide you with the information and services you have requested;
• for system administration purposes and for internal operations to ensure that content is presented in the most effective manner for you and for your device;
• to provide customer support and ensure we provide a good level of customer service;
• to notify you of any changes to our services;
• for security and fraud prevention and to ensure that our website and digital properties are safe and secure; and
• to comply with applicable laws and regulations.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

• Our legitimate business interests: Where it is necessary for us to process your personal information as part of the normal operation of our business, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example, where you contact us about the site and it is necessary for us to handle your personal information as part of our customer service.

• Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

WHERE WE STORE YOUR PERSONAL INFORMATION

The personal information that we collect may be transferred to, and stored at, a destination outside the United States, including countries, which have less strict, or no data protection laws, when compared to those in the US.

Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Privacy and Cookies Policy. In these cases, we rely on approved data transfer mechanisms to ensure your information is subject to adequate safeguards in the recipient country. 

HOW WE KEEP YOUR PERSONAL INFORMATION

We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymized. For example, we may keep a record of any correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.

SECURITY

We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. 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 as it is transmitted to us.

DISCLOSING YOUR INFORMATION

We may disclose your personal information to the following categories of third parties:

• with our suppliers, business partners, and service providers, where they are helping us to promote the site and its content as well as providing our services to you;

• with business reorganization parties, in the event that we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;

• if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers and visitors to our websites will be one of the transferred assets;

• with authorities or similar third parties (e.g., auditors) requesting mandatory disclosure in compliance with applicable law, if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request; or

• with other companies and organizations for the purposes of fraud protection to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions (this includes exchanging information).

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies, web beacons and/or similar technologies to understand and enhance your online experience on the site. Our affiliates, as well as our and their third-party service providers, also use such technologies for this purpose.

Cookies are small text files placed in your browser.  Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as the IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server.

Various types of cookies are used via the site:

• “Session cookies” are used (which will usually be deleted when you log out) to keep track of your internet session, which, for instance, allows us to remember the site language. Without these cookies the online services that you have asked for cannot be provided. Session cookies are necessary and/or useful for the functioning of the site

• “Persistent cookies” are used (which are longer-term) to help you move around and enjoy the features on the site more easily and to remember preferences, actions and settings to improve your visit (at your request)

You can object to such cookies through your browser settings, however, please note that without essential cookies, some features or activities may be limited or not available to you.  For more information on how to control cookies on your browser, or about cookies generally, please see  https://www.aboutcookies.org/.

The purposes for which we use cookies and other technologies.

We use cookies and similar technologies on the site for the following purposes:

• Strictly Necessary: enabling core site functionality

Strictly necessary cookies and similar technologies are essential in order to enable you to move around the site and use its features. Without them, services like enabling appropriate content based on your type of device cannot be provided.

• Analytics: allowing us to analyse site usage.

Analytics cookies and similar technologies collect information about how you use the site, so that we can analyse traffic and understand users’ interactions to perform analytics, including to analyse, measure and report on usage and performance of the site.

For this purpose, we may use third-party service providers such as Google Analytics, who may use their own cookies and similar technologies. The information is used to improve our sites or products. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. To opt out of Google Analytics relating to your use of our sites, you can download and install the Google Analytics Opt-out Browser Add-on available via this link: https://tools.google.com/dlpage/gaoptout?hl=en.

• Functional: allowing us to personalize your experience of our sites.

Functional cookies and similar technologies allow the site to remember choices you make (such as the region you are in) and to provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of webpages that you can customize.

Managing cookies and similar technologies.

You can manage your consents for cookies on the site through your browser settings. You can adjust your browser to reject cookies from us or from any other site operator. Controlling cookies via browser controls may not limit our use of other technologies. Please consult your browser’s settings for more information. You can also check your browser settings to learn how to delete cookies.

Blocking cookies and similar technologies might, however, prevent you from accessing some of our content or site features.

Adobe’s Flash player and similar applications use Local Shared Object (“LSO”) technology to remember settings, preferences and usage similar to browser cookies. Flash cookies are not managed through your web browser, but you can access your Flash management tools from Adobe’s website. Your browser may also offer other tools to delete or reject other LSOs; please check your browser’s settings or help menu for more information.

YOUR RIGHTS

You have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information.

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights, please conduct us using the contact details below.

You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns, we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.

Our website and other digital properties may, from time to time, contain links to and from third party websites and services (including third party social media platforms). If you follow a link to any of these websites and/or services, please note that they have their own privacy policies and we do not accept any responsibility or liability for them. Please check any such third party privacy policies before you submit any personal information to these websites or services.

CALIFORNIA RESIDENTS

California law requires that we describe the personal information that we have collected about California consumers in the past 12 months, by identifying specific categories of personal information. We have collected the following:

• Identifiers;
• Internet or other electronic network activity information; and
• Characteristics of protected classifications under California or Federal law, such as age or national origin;

For more details on what is collected, or for information regarding the sources of such personal information, please see sections “How and When We Collect Personal Information About You” and “What Personal Information Do We Collect About You” above. For information regarding how we may use or disclose such personal information, please see sections “Purposes for Processing Your Personal Information” And “Disclosing Your Information” above.

California law also mandates that we specify certain disclosures, as some disclosures constitute a “sale” of data under California law, even if no money is exchanged. We do not sell personal information. However, we may have disclosed the following personal information to the following categories of third parties for our operational “business purposes” as defined by California law, in the last 12 months:

In addition to the right to access the personal information that we collect, use, disclose, and sell, and the right to deletion, as described above, California residents also have the right to access specific pieces of information we hold about them, and the right to opt-out of the sale of their personal information. However, we do not sell personal information, nor do we have any actual knowledge of any sale of personal information of minors under 16 years of age.

You have the right to not be denied goods or services for exercising your rights.

If you wish to exercise any of these rights or have any questions or concerns regarding the processing of your personal information, please contact us at  dwhogan@comcast.net. We will respond to your request consistent with applicable law.

Please note, however, before we will be able to process your request for access or deletion of personal information, we will need to properly verify your identity for security purposes. Where we possess appropriate information about you on file (e.g., name, email address), we will attempt to verify your identity using that information. We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

To use an authorized agent to make a request on your behalf, you will need to directly confirm with us that you provided the authorized agent permission to submit the request, provide the company with signed permission for the authorized agent to act on your behalf, and you will need to verify your identity, directly with the company.

CHANGES TO THIS PRIVACY AND COOKIES POLICY 

We may change this Privacy and Cookies Policy at any time. The new Privacy and Cookies Policy will be displayed on our website. The date this Privacy and Cookies Policy was last updated appears at the bottom. If any changes occur, that materially impact previously collected information about you, we will make reasonable efforts to notify you.

CONTACT US

Questions and comments regarding this Privacy and Cookies Policy should be sent to  dwhogan@comcast.net.

This Privacy and Cookies Policy was last updated on August 21, 2020.