1. The Kinds of Information We Collect.
We collect information to provide better services to all of users of our Service, including determining what types of editorial content and the products and services offered on our Service that are of the most interest and relevance to you.
We collect information about you from the following two sources:
a. The Information you give us (“EMI Profile”). For example, many of our services require that you create an account. When you do, we’ll ask for personal information, like your name, email address, telephone number, and, if you are purchasing products or services on our Service, purchase information such as the products or services purchased, the dates of purchase and the purchase price.
b. The information we collect from your use of our Service. This information relates generally to what editorial and advertising content you view, and the products and services you use that we and our third-party providers offer. This information includes:
(i) Device Information, we collect information about the devices you use to access our Service, such as hardware settings, browser type, browser language, the date and time of your request and referral URL.
(ii) Log Information. When you use our Service, we automatically collect and store certain information in server logs, which automatically record certain information when you use our Service, including the following:
(a) details about how you have used our Service, such as your search queries;
(b) your IP address, which is the number assigned to an Internet connected device such as a tablet or smartphone and used to identify the geographic location of that device; and
(c) cookies that may uniquely identify your browser and collect information about how our visitors interact with our Service, as well as help us identify problems such as error messages from certain pages. A cookie is a small file containing a string of characters that is sent to your computer or other device when you visit our Service. When you visit our Service any time thereafter, the cookie allows our Service to recognize your browser and to store information about your user preferences and other personal information.
(iii) Location information. When you visit our Service, we may collect and process information about your actual location. We use various technologies to determine location, including IP address.
(iv) Local storage. We may collect and store information (including personal information) locally on your device, using mechanisms such as browser web storage (including HTML 5), which allows for data to be stored on a browser even after the browser has been closed and the reopened, and application data caches, which allow for data to be stored on your device, enabling an application to run without an Internet connection and to load content faster.
(v) Collection and Storage technologies. We and our partners use various technologies to collect and store information when you access the EMI Service, and this may include using cookies or other technologies to identify your browser or device. We also use these technologies to collect and store information when you access our Service and interact with the content and products and services we offer, such as advertising services.
2. How We Use Information We Collect.
We use the information we collect from users of our Service in order to provide you with more meaningful editorial and advertising content and to offer you relevant products and services, as well as to maintain, protect and improve your overall experience. In particular, you may choose (i) to subscribe to any of our electronic newsletters, (ii) to receive “special offers” by EMI and its various service providers, (iii) to receive franchise and business opportunity information from selected advertisers, and we will use your information for these purposes provided you have given us your consent. You may also choose (iv) to submit questions or comments in response to editorial content on our Service, or (v) to purchase books and related publications offered on our affiliated website at bookstore.insperonjournal.com (the “Bookstore Website”) in which case, we will process your information to perform our agreement or comply with your request. In each of those instances you will be asked to provide, and we will collect and store, certain personal information such as email address, zip code, telephone number, and in some instances information about your business. In the case of purchases made through the Bookstore Website, we will also collect and store additional information about those purchases, including titles purchased, quantity and dates of purchases, the method of payment, and other information provided such as billing and shipping addresses (if different). By providing that information and provided you have consented thereto, you acknowledge that it can be used by EMI and its various advertisers and other service providers to send you promotions and other communications concerning business opportunities, products or services. You can remove yourself from any such electronic newsletters and otherwise stop receiving any further promotions and other commercial communications by following the “unsubscribe” directions included with each newsletter or, in all of the above instances, by sending an email with the word “unsubscribe” in the subject line to email@example.com.
We may use the name you provide for your EMI Profile across all of the services we offer that require an EMI Account, which is where the information you provide is maintained. In addition, we may replace past names associated with your EMI Account, so that you are represented consistently across all our services.
When you contact EMI, we retain a record of your communications to help solve any issues you might be facing, or to maintain a record to assist with legal claims. We will keep these records for a period of no more than 6 years. Provided you have consented thereto, we may use your email address to inform you about the products and services offered on our Service, such as letting you know about upcoming changes or improvements.
We do not track our users across third party websites and thus do not respond to Do Not Track (“DNT”) signals. However, some third party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, certain website browsers allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.
3. The Advertising on Our Service.
Advertising on our Service makes it possible for us to offer you the information and products/services free of charge. We take seriously and make every effort to make sure that advertising is safe, unobtrusive and as relevant as possible.
Cookies are used to make that advertising as relevant as possible to the needs and interests of users of our Service, and more valuable to our advertisers in being able to show our visitors more relevant ads. Cookies are also used to avoid you seeing the same ad multiple times and to detect and prevent click fraud. We use AdSense, Google Analytics and other DoubleClick services (collectively, “Google® Services”), which help us manage and improve our Service and help our advertisers better understand and track user interaction with their ads. When you visit a location on our Service that includes one or more of these ads, various cookies may be sent to your browser.
We may use other technologies, including Flash and HTML5, which provide the functionality for such displays as interactive advertising. We may also use your IP address to select and provide advertising targeted to that address, in order to improve the relevance of the ads you see and to measure and report to advertisers non-personal statistical information about geographical location of those website visitors who are viewing their ads.
The advertising you see on our Service is determined by a number of factors relating to relevance, including (i) your approximate geographical location base on you IP address and (ii) the subject matter you may be viewing on our Service. For example, if you are viewing an article about physical health, you may see ads concerning exercise equipment.
If you wish to know more about the information collected from website users and used to tailor those advertisements for products and services which might be of the most interest and relevance to those users, or would like to know more about the user’s options in connection with the collection and use of that information, you can visit the Network Advertising Initiative (“NAI”) website at https://www.networkadvertising.org. The NAI is a cooperative of online advertising companies who are committed to responsible practices and consumer protection.
Click here to revoke your Ad Personalization choice.
4. Privacy and Choice.
People have different concerns about privacy. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how that information is used. You may set your browser in its “options” or “preferences” feature in order to warn you before accepting cookies or to disable all cookies entirely. However, it is important to understand that many of the services we provide on our Service and to our Service users may not function properly if your cookies are disabled.
5. Minors and Children under the Age of 16.
EMI does not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register to use our Service. No one under age 16 is allowed to provide any personal information to EMI or on our Service. In the event that we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under age 16, please contact us at firstname.lastname@example.org.
6. Where We Store the Information
The data that we collect from you may be transferred to, and stored at, a destination outside of your country and the European Economic Area (“EEA”) including, in particular, the United States. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your information, you agree to this transfer, storing or processing.
7. The Information You Share.
8. Updating Your Personal Information.
If allowed under applicable law, we may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, requests which would be extremely impractical (for instance, requests concerning information residing on backup systems)).
Where we can provide information access and correction, we will do so at no cost to you, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our Service, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.
9. The Information We Share.
We do not share personal information with companies, organizations and individuals outside of EMI, unless one of the following circumstances applies:
a. We will share personal information with companies, organizations or individuals outside of EMI when we have your opt-in or other consent to do so.
b. We will share personal information with companies, organizations or individuals outside of EMI if we have a good-faith belief that access, use, preservation or disclosure of that information is reasonably necessary to:
(i)comply with applicable law, regulations, legal process or enforceable governmental request;
(ii)enforce any of our applicable Terms of Service, including any potential violations;
(iii)detect, prevent, or otherwise address fraud, security or technical issues; or
(iv)protect against harm to the rights, property or safety of users of our Service or service providers, as well as the general public and EMI as required or permitted by law.
c. We may share personal information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of EMI’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by EMI about our Service users is among the assets transferred.
d. We may share your information publicly and with our partners such as third-party content providers, advertisers or connected sites, but in a manner which does not reveal your personally-identifiable information and which is aggregated with other user information to show usage of EMI and third-party products and services offered on our Service and trends based on such categories as age, gender, geographical origination and other demographic characteristics.
10. The Protection of Your Information.
We work hard to protect the information provided by, or collected about, the users of our Service, from unauthorized access, or alteration, disclosure or destruction. In particular:
a. We encrypt much of that information using SSL.
b. We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to our systems and the information collected and stored therein
c. We restrict access to personal information to those of our employees, contractors and agents, who need to know that information in order to process it for us, who are subject to the obligation of strict confidentiality as relates to that information, and who will be subject to discipline, including termination, if they violate that obligation.
a. services offered by other companies or individuals on non-EMI websites or applications, including any such websites or applications which may be referenced on or linked from our Service; and
12. Your Rights and Choices about What Personal Information We Collect and Maintain and How We Use It
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to You about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose (as defined in Section 13 below) for collecting or selling (as also defined in Section below) that Personal Information.
The categories of third parties, with whom we share that Personal Information.
The specific pieces of Personal Information we collected about YOU (also called a data portability request).
If we sold (as defined in Section 13 below) or disclosed your Personal Information for a business purpose, two separate lists disclosing:
sales, identifying the Personal Information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the Personal Information you request to have deleted is necessary for us or our service providers to:
a. Complete the transaction, for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
b. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
c. Debug products, in order to identify and repair errors that impair existing intended functionality.
d. Exercise free speech, ensure the right of another consumer to exercise his/her free speech rights, or exercise another right provided for by law.
e. If you had previously provided informed consent, engage in public or peer-reviewed scientific, historical, or statistical research in the public interest, that adheres to all other applicable ethics and privacy laws, when deletion of the Personal Information may likely render impossible or seriously impair the purpose(s) of that research.
f. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
g. Comply with applicable law or any legal obligation(s) we may have.
h. Make other internal and lawful use of that Personal Information that is compatible with the context in which you provided that Information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by visiting us, and completing the information requested, at www.insperonjournal.com/privacy-preferences.
Only You may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity as the person making the request or having your authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you in writing of the reason(s) why we will need more time and the additional time needed. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response to you electronically to the email address you provide. Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable consumer request. The response we provide will also explain any reason(s) why we cannot comply with your request (if applicable). For data portability requests, we will select a format for providing your Personal Information, which is readily usable and which should allow you to transmit that Information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
13. Glossary of Terms.
As used in this Privacy Notice, the terms below shall have the following meanings:
“Affiliate” means a person or entity, who/which directly, or indirectly through one or more intermediaries, controls, is controlled by, or is under common control with, us.
“Business purpose” means the use of Personal Information for a business’ or service provider’s operational purpose(s) or other notified purpose(s), provided that the use of such information is reasonably necessary and proportionate to achieve the purpose for which the Personal Information was collected or processed or for another operational purpose that is compatible with the context in which the Personal Information was collected or processed. A business purpose includes: (i) auditing interactions with consumers such as counting ad impressions; (ii) security such as protecting against malicious or fraudulent activity; (iii) debugging such as identification and repair of impairments to functionality; (iv) short-term uses not involving disclosure to a third party, building a profile about a consumer, or altering a consumer’s experience outside of the transaction for which the personal information was collected; (v) performing services such as maintaining or servicing accounts and processing or fulfilling orders, verifying customer information, or providing advertising or marketing services; (vi) internal research for tech development; and (vi) quality and safety maintenance and verification.
“Commercial purpose” under CCPA means to induce a person’s commercial or economic interests, such as by inducing a person to buy, subscribe to, or provide goods, services or information.
“Sale” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information to a third party for valuable consideration or for no consideration, for the third party’s commercial purposes.
“Service Provider” means a for-profit legal entity, to which we disclose a consumer’s Personal Information for processing for a business purpose pursuant to a written contract between us and the Service Provider.
14. Handling Complaints from Our Service Users and Regulatory Authorities.
15. California Residents.
California residents may choose to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes or choose to opt out of such disclosure. Our policy is not to disclose personal information collected online to a third party for directing marketing without your approval. To make a request or to opt out at any time, please contact us at email@example.com or the other contact information provided below.
17. Contacting Us.