Commonwealth of Massachusetts, Rev. 133C579
Version Date: January 01, 2019
SECTION I – IMPROVE YOUR PRIVACY ONLINE
There are many ways that you can take control of your own privacy online. One of the best resources available is the Electronic Frontier Foundation, “the leading nonprofit organization defending civil liberties in the digital world. Founded in 1990, EFF champions user privacy, free expression, and innovation through impact litigation, policy analysis, grassroots activism, and technology development.”
This section contains links to various other resources and tools available to you. Don’t ever fully trust someone else with your privacy.
Not even us.
There are plenty of tools that you can install for free that can help improve your overall privacy online by:
- Blocking or disabling cookies within your browser
- Installing extensions that manage cookies or block web-tracking technologies
- Increasing the generic nature of operating system and web-browser data collected by websites
- Using encrypted email
- Securing files and other data at rest
- Masking your location and IP address
- Or by using a combination of any (or all) of these tools.
You can minimize the damage done by a data breach by using a different, randomized password for every website and account you use and store that information in a password protected, encrypted database so you only need to remember one single password — the one used to unlock the password database. May we recommend that you consider using an effective password manager, such as this one?
SECTION II – GENERAL
SECTION III – GATHERING, USE, AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Generally speaking, every computer potentially provides a pile of data about itself to every other computer it connects to. None of it is directly identifying, and very generic in nature Websites use that information help make things easier on you, on us, and our vendors as well. Even though this information is generic in nature, it can still be used to create a fairly robust profile of a computer on the Internet over time.
SECTION III; A – Users of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, we gather from the users of our Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type, and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally-Identifying Information, it may be possible for us to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. We analyze Non-Personally-Identifying Information gathered from users of the Website to help us better understand how the Website is being used. By identifying patterns and trends in usage, we are able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, we may also release Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.
SECTION III; B – Web Cookies
WEBSITE USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.
SECTION III; C – Web Beacons
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. We may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique we may use to compile aggregated statistical data about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons; however, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.
SECTION III; D – Analytics
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Website, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads).
SECTION III; E – Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information that we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
SECTION III; F – Mobile Device Additional Terms
- Mobile Device. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
- Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for us to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.
- Push Notifications. We may send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
- Mobile Analytics. We may use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally-Identifying Information you submit within the mobile application.
SECTION IV – SOCIAL MEDIA
Social Media is another way that information about you is provided and gathered. For example, you could use your Facebook or Google account to sign in to various sites, including this one, but doing so links all the information you provide on all of those accounts to you, funneling a tsunami of data to back to Facebook and Google all in the name of a single convenient point of failure, should something go wrong.
We may provide you the option to connect your account on the Website to your account on some social networking sites for the purpose of logging in, uploading information or enabling certain features on the Website. When logging in using your social network credentials, we may collect the Personally-Identifying Information you have made publicly available on the social networking site, such as your name, profile picture, cover photo, username, gender, friends network, age range, locale, friend list and any other information you have made public. Once connected, other users may also be able to see information about your social network, such as the size of your network and your friends, including common friends. By connecting your account on the Website to your account on any social networking site, you hereby consent to the continuous release of information about you to us. We will not send any of your account information to the connected social networking site without first disclosing that to you. Each social network may further allow you to set privacy controls around your information on their system, and our collection of information will always follow such controls and permissions. This feature is subject to continuous change and improvement by us and each social networking site involved, and therefore the available features and shared information are subject to change without notice to you.
We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button, or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.
SECTION V – COLLECTION, USE, AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
The personal information we collect directly is provided by you when you create an account on our website, connect from an outside Social Media account, fill out one of our forms, post a comment, buy something, or otherwise provide it through the course of interacting with our website. Will we ever share or use that information? Of course, but only for legitimate business or legal reasons, as needed.
SECTION V; A – Website Registration
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. We may collect a range of Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by us about our users is information provided by users themselves when (1) registering for our service, (2) logging in with social network credentials, (3) participating in polls, contests, surveys or other features of our service, or responding to offers or advertisements, (4) communicating with us, (5) creating a public profile or (6) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic or relevant information as determined by Company from time to time. Users of the Website are under no obligation to provide us with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
SECTION V; B – Online Postings
USERS MUST ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.
SECTION V; C – Company Communications
We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.
SECTION V; D – Company Disclosures
We may disclose Personally-Identifying Information under the following circumstances:
- Marketing Communications. Unless users opt-out from receiving our marketing materials upon registration, we may email our users about products and services that we believe may be of interest to them. If you wish to opt-out of receiving marketing materials from us, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable), or contacting us using the contact information below.
- Third-Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
SECTION VI – Changing Personally-Identifying Information; Account Termination
You can change the information you provide to us, or delete your account with us, at anytime you choose. Some of that information may be retained for legal purposes or, among other things, to prevent the digital equivalent of trespassing on our site.
SECTION VII – General Use
Soooooooooooooo, it all comes down to this: The personal information you provide to us will only be used by us to communicate back and forth with you, our vendors, and legal resources (email, phone, comments, snail-mail, etc) for legitimate and relevant purposes in order to conduct business effectively, provide service(s) to you, or to protect and defend our interests.
This may seem like a “no durr!” moment but, again, lawyers…
We use the Personally-Identifying Information in the file we maintain about you and other information we obtain from your current and past activities on the Website to, among other things:
- deliver the products and services that you have requested;
- manage your account and provide you with customer support;
- communicate with you by email, postal mail, telephone, and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies, or other third parties;
- develop and display content and advertising tailored to your interests on the Website and other sites;
- resolve disputes and troubleshoot problems;
- measure consumer interest in our services;
- inform you of updates;
- to customize your experience;
- detect and protect us against error, fraud and other criminal activity;
- do as otherwise described to you at the time of collection.
At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify persons who are using multiple user IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions. We may use financial information or various payment methods to process payments for any purchases made on the Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
SECTION VIII – COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
Remember those third party vendors we work with? This section is a list of a few of them, and describes what we use them for, and points you to their own privacy policies.
We have no control over what they do, or do not do.
We are not them. They are not us.
EXAMPLES OF SOME, BUT NOT ALL, OF THE THIRD PARTIES WE CURRENTLY USE:
- We use Dreamhost to host the Site and manage our Domain Name. You can read more about how Dreamhost uses your Personal Information here: https://dreamhost.com/legal/privacy-policy. You can also read about some of the security features provided to us at the web-hosting level by Dreamhost here: https://www.dreamhost.com/security.
- We use Cloudflare to improve the performance of our website and to provide an additional security layer to help protect our website from various online threats. https://www.cloudflare.com/privacypolicy links to Cloudflare’s privacy and cookie policies and to their annual transparency report.
- We use Google Analytics to help us understand how you use the Site. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy. You can prevent the collection of data generated by cookies by downloading and installing the browser plug-in that is available here: https://tools.google.com/dlpage/gaoptout.
- We use Facebook pixels in order to track user behavior after they have been redirected to the Site by clicking on a Facebook ad. You can read more about how Facebook uses your Personal Information here: https://www.facebook.com/about/privacy/. You can also object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads, here: https://www.facebook.com/settings?tab=ads
- We use MailChimp to manage our mailing lists and email campaigns. Contact Information you voluntarily provide through our forms (such as “Subscribe”, “Sign Up”, or other opt-in methods) is used for that purpose, and nothing else. You can read more about how MailChimp uses that information (“Contacts”) here: https://mailchimp.com/legal/privacy/#3._Privacy_for_Contacts
SECTION IX – SECURITY
There is only so much that any person, organization, crew, company, agency, or government can to do to secure your personal information. The only one who can really secure your information, realistically, is you.
The number one thing you can do to safeguard your information is to never disclose it to anyone at anytime.
The second thing you can do, concerning any of your account(s), is to use a really effective password that is impossible to guess, or takes wayyyyyyy too long to crack.
Even though we are a small site, we take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse.
- We do not allow “guest” comments.
- Comments are not always posted immediately.
- New user registrations are manually approved.
- Users must be registered and logged in to comment.
- We use Captchas, honeypots, and other means to reduce SPAM and brute force attacks.
- We use Social Media logins specifically to tie an account to an already reasonably vetted person.
- Bots, robots, spiders, problem users, spammers, cyber-bullies, etc will be sent Home (localhost) or to a random law enforcement website of our choosing as a warning.
- We currently do not allow image hot-linking or displaying our webpage via iFrames. It’s one thing to scrape our content. It’s another thing to steal our bandwidth.
- We may prevent you from logging in, based on your IP addresses after a certain number of invalid login attempts. If this happens, come back in an hour and try again.
- (That is another reason why we use Social Media logins instead of creating user accounts, by the way)
- Users leaving any comments deemed to be SPAM will be monitored and, optionally, banned.
- We reserve the right to ban or blacklist any IP address, individually or by range, for any reason and at any time.
- We use Web Application Firewalls, DNSSEC, an isolated and managed hosting environment, randomly generated passwords, and various other security measures to help provide a reasonable balance between layered security and website functionality.
- Our website uses an SSL Certificate between us and Cloudflare. Cloudflare uses an SSL Certificate between you and them. All web traffic between you, Cloudflare, and us is encrypted (look for the lock in the browser bar).
- If you wish to send an encrypted message through any of our comment forms or send us an encrypted email, you may use our public OpenPGP key for that purpose.
Please understand, however, that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures. As much as we are dedicated to protecting all information on the Website as necessary you are responsible for maintaining the security of your own Personally-Identifying Information. If you do not want your information compromised, do not disclose it. If you secure your information with a password, then you must keep your password confidential. If you believe someone has gained unauthorized access to your information or to your account, you must change your password immediately. If you lose control of your account, you must notify us immediately.
This policy is not fixed in stone, and can be updated, corrected, or tossed out completely in favor of a new one at anytime. We will let you know if that happens.
SECTION XI – CHILDREN
If you are 13, please do not sign up for our website. If we find out that you are under 13 years of age or if we are informed by your parent or guardian that you are under 13 years of age, we will delete your account.
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the Website represents to us that they are 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred Personally-Identifying Information to the Website, please contact us using the contact information below to have that child’s account terminated and information deleted.
SECTION XII – GDPR
If you live in Europe, this section may be relevant to you.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information as listed below.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information may be transferred outside of Europe, including to Canada and the United States.
SECTION XIII – CALIFORNIA PRIVACY RIGHTS
If you live in California, this section may be relevant to you.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.
SECTION XIV – “DO NOT TRACK” POLICY
Modern web-browsers use a technology called Do Not Track that can be enabled by you, typically under “Privacy” settings. It has not been standardized as a technology in the tech world, so we don’t bother with it.
Besides, the links in Section I of this policy suggest existing methods which are much, much, much more effective anyway.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.
SECTION XV – CONTACT
Attn: Privacy Officer
304 South Jones Blvd #361
Las Vegas, NV 89107
Email: privacy (at) alphajulietfoxtrot (dot) com