Last updated: 8/12/2019
Information We Collect and How We Collect It
Information You Provide
Web beacons (tracking pixels): Web beacons (also known as tracking pixels) are bits of data that count the number of users who access a website or open an email and can also allow us to see if a cookie has been activated. Web beacons used on web pages or in emails allow us to see how successful an article has been, or whether an email message was successfully delivered and read in a marketing campaign. We also use web beacons to learn if you have clicked on any links or offers contained in emails. We may use this information to help us identify which emails are more interesting to you and to inform our partners and sponsors how many customers have clicked on their offers (the information shared with partners is aggregated and does not identify you individually).
We may share Non-Personally Identifiable Information with third parties, but only in an aggregate statistical form that includes no personally identifying information. If we combine Non-Personally Identifiable Information with Personally Identifiable Information, through data mapping or otherwise, the combined information will be treated as Personally Identifiable Information.
Generally: In general, we may use your Registration Data, and/or other information or data we receive or collect from you or other sources, as well as data we derive or infer from combinations of the foregoing, for a variety of purposes, such as:
How We Use Your Information
- to present our Sites and Content to you;
- to provide the Services to you;
- to facilitate the creation of and secure your account on the Services;
- to customize and personalize the Content we deliver to you both on the Services;
- to allow you to participate in interactive features on our Sites or Services;
- to measure and analyze Services usage and enhance the member experience on our Services;
- to improve the content of our Sites or our Services, including our marketing;
- to fulfill your requests for certain products and services, such as distributing electronic newsletters and enabling you to participate in surveys and public forums;
- to provide you with information about our Services that you request from us;
- to register you for email notifications which will keep you up to date on your account status and upcoming renewal dates;
- to register you for email newsletters to receive updates on new courses, products, services, events and other offerings of interest to our members;
- to use third-party service providers to send and distribute e-mail and to perform other marketing and support functions on our behalf or otherwise to assist us in providing our Services to you;
- to alert you to the latest developments and features on our Services, events, and activities and to notify you of administrative information, such as security or support and maintenance advisories;
- to ask you questions about your interests and your experience on the Sites;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
- for identity management, security, and auditing;
- for any other purpose for which you provide it; or
- in any other way we may describe before we collect your information.
Sharing Your Information With Others
We may provide your personal information to service providers or contractors to perform functions on our behalf, including, but not limited to, communicating news; performing Sites or Services development or maintenance; providing functionality or other services for our Sites and our Services; sending postal mail, email or other communications; removing outdated and repetitive information from our lists; measuring and analyzing our Services usage and our data; developing, enhancing, marketing, or providing any of our Services; or assisting us with other marketing and support functions. These companies are authorized to use your personal information only as necessary to provide these services to us. They are not authorized to use your personal information for their own, unrelated purposes.
We may also disclose an individual’s personal information:
- if you elect to take advantage of certain features or services provided jointly by us and third parties, we may share certain information about you with those third parties for account authentication and management, to enable them to communicate with you directly, to enable the Services on their platforms, or for research purposes;
- in situations where sharing or disclosing your information is required in order to provide you with information that you have requested;
- to a person who in our reasonable judgment is seeking the information as an agent of the individual or company;
- if, in our reasonable judgment, it is necessary enforce compliance with our internal policies or the agreement for our Services; or to protect or defend our legal rights or property, or the legal rights of our business partners, employees, agents, and contractors;
- to protect or defend our Sites or Services or protect the safety and security of our users or members of the public, including acting in urgent circumstances;
- to protect against fraud or to conduct risk management;
- to comply with the law, legal process, or legal requests, including, without limitation, a court order or subpoena;
- in response to a law enforcement agency’s request;
- to another entity as part of a merger, bankruptcy, a sale of assets or all or part of a business, or any other corporate change or re-organization; or
- to a third party or parties, where the individual consents to such disclosure or disclosure is required or permitted by law.
Sharing of Anonymized, Non-Personally Identifiable or Aggregated Data: We may share with third parties, advertisers, and/or business partners anonymized aggregated data we receive or collect, such as de-identified demographic information, location information, or information about the computer or device from which you access the Services.
Managing Your Information
Modification of Your Registration Data: We provide you with the ability to modify your Registration Data, which you may do through the settings section of our Site or by contacting customer support.
Retention of Your Registration Data: We will only keep your personally identifiable information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, or reporting requirements.
To determine the appropriate retention period for your personally identifiable information, we will consider the amount, nature, and sensitivity of the personally identifiable information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it (and whether we can achieve those purposes through other means), and the applicable legal requirements.
In some circumstances we may anonymize your personally identifiable information so that it can no longer be associated with you, in which case it is no longer personally identifiable information.
Upon expiration of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
Cancellation or Deactivation of Accounts: If you would like to request the cancellation or deactivation of your account, you should contact our customer support team for assistance. If you elect to have your user account deleted from our database, all of your data will effectively be removed, will no longer be available to us, and we will no longer be able to provide it to you if you decide later to become a member with us again. You can reach us at firstname.lastname@example.org.
Cached Profiles on Search Engines: Please note that although we may deactivate your account at your request, Internet search engines such as Google and Bing cache publicly available webpages for a period of time beyond our control, and may make your deactivated or formerly public profile available to users of their services on their platforms until such time as they refresh their webpage cache.
Rights to “Opt Out”: If you are receiving emails, texts or similar online communications from us, it is because we understood from your registration on our Sites or your information request that you were interested in receiving ongoing information from us. If at any point you no longer wish to receive such communications, you may at any time “unsubscribe” from these communications by following the ‘opt out’ directions to be found at or near the end of the communication. Even if you “opt-out” of these email communications, we will continue to communicate with you about your account and other administrative matters relating to our provision of services to you. If you have any questions about the opt-out process, you can contact us at email@example.com. Please note that if we have already shared your personal contact information with one of our corporate sponsors or partners, unsubscribing from our communications list will not prevent these third parties from continuing to email or text you. You will have to send an opt-out request to those third parties directly. Opportunities to “opt out” from receiving emails and texts are usually found on these companies’ websites or at the end of their emails or texts. If you do not wish to have your personal contact information shared with our corporate sponsors or members, then you can request that we stop such sharing by emailing us at firstname.lastname@example.org.
Security and Content From Other Websites
Protection of Data From Loss: We have implemented security measures designed to protect against the loss, misuse, and alteration of the information we collect or receive from you. However, despite our efforts, no security measures are perfect or impenetrable, and we cannot guarantee the security of our databases nor that information you supply will not be intercepted while being transmitted to us over the Internet.
Data Integrity: We will take steps to ensure that all personally identifiable information collected, processed, and/or stored is protected from destruction, corruption, or use in a manner inconsistent with the purpose for which we received it.
Do Not Track
Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers nor is there a common agreement about how to implement these features or interpret user intent. Our Services are not currently set up to respond to those signals.
Our Policies Concerning Children
Our Sites are not intended for children under the age of 16. We prohibit registration by, and do not knowingly solicit or collect personal information from, anyone under 16 years of age. In the event we obtain actual knowledge that we have collected personally identifiable information from children under the age of 16, we will take reasonable measures to remove such information from our servers and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law). If you believe that we might have any personal information from a child under 16, please contact our customer support team.
Your California Privacy Rights
Pursuant to California Civil Code Section 1798.83, this policy sets forth that we only share personal information (as defined in California Civil Code Section 1798.83) with third parties for direct marketing purposes if you either specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out of such sharing at the time you provide personal information or when you choose to participate in a feature on the Services. If you do not opt-in or if you opt-out at that time, we will not share your personal information with that identified third party for direct marketing purposes.
Additional Notice to Residents of the European Economic Area (EEA) and Switzerland
Legal Bases for Collection and Processing of Information
Our collection and processing of your personally identifiable information is supported by a number of legal bases. Set out below are the most relevant ones. Please note that while we may rely on one legal basis for a particular activity, if that is no longer applicable or available then we may be able to rely on another basis.
To Fulfill a Contract: We collect and process some of your personally identifiable information because we need to do so either to enter into or fulfill a contract we have with you.
For a Legitimate Interest: We may process your personally identifiable information where we or a third party have a legitimate interest in doing so. For example, we have a legitimate interest in understanding how people are using our Services, both to improve them and to market our Services more effectively. Therefore, we may use your personally identifiable information to understand and analyze your use of our Services. When we rely on our legitimate interest, we will carry out a balancing test between our legitimate interests and your privacy rights. Our legitimate interests include: understanding how our audience interacts with our Content, our marketing, and our Services; learning about our audience in order to improve our Services for them; developing, delivering, and maintaining relevant and engaging Content and marketing; supporting dissemination of information on topics of interest to individuals and the community; supporting individuals’ rights to receive information; and conducting our business activities and achieving our business goals.
To Comply with Legal Obligations: We will process your personally identifiable information when necessary to comply with legal and regulatory obligations or defend claims. For example, we may share your personally identifiable information in response to a court order, subpoena, or law enforcement agency’s request.
Access, Correction and Deletion of Information
For personally identifiable information that we hold about you, you may have the right (subject to exceptions allowed by law) to:
- request access to your personally identifiable information;
- request we correct any inaccurate personally identifiable information;
- request we delete any personally identifiable information;
- restrict the processing of personally identifiable information;
- object to the processing of personally identifiable information; and/or
- receive a copy of your personally identifiable information in a structured and commonly used machine-readable format or have such personally identifiable information transmitted to another company.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.
Transfer of Information
Fear Free, LLC
2420 17th Street
Denver, Colorado 80202