Effective August 5, 2019
SCOPE OF POLICY
- Customers – individuals who register, on their own or on behalf of an entity, to use iThemes Services with the creation or administration of a iThemes account.
- Event/Marketing Participants – individuals who provide their information to iThemes when they register for iThemes webinars, subscribe to marketing material, participate in surveys or contests, or attend other iThemes events.
INFORMATION WE COLLECT
iThemes asks for your account information which includes your name, business name, email address, physical address, phone number, credit card and bank account information (stored directly with a third party processor), and website domain. By voluntarily providing iThemes with your account information, you represent that you own and consent to our use of such personal data.
iThemes may ask for your name, email address, physical address, and phone number. Participation in events, surveys, contents, or subscribing to marketing material is voluntary and you may choose whether or not to participate and therefore disclose this personal data.
At your option, iThemes asks and may collect your name, email address, physical address, and phone number. In addition, we also collect information such as web server logs, internet protocol (IP) addresses, browser type, or other information as part of aggregated data.
HOW WE USE YOUR INFORMATION
iThemes uses the information it collects about you in the following ways:
- To respond to any requests from you regarding sales and support.
- To contact you regarding any agreements or accepted terms that you may have with iThemes for the Services.
- To provide you with marketing emails, special offers, advertising campaigns, or newsletters.
- To provide you with information logs associated with the use of iThemes’ Services.
- To contact you regarding functionality changes to our Services or Website.
- To develop new features and functionality to our Services and Website.
- To collect payment and bill for our Services.
- To help personalize searches.
- To diagnose problems.
- To find and prevent fraud.
- To register your domain and IP address through ARIN (American Registry for Internet Numbers).
- To carry out other purposes as disclosed to you through the Website, or found in terms or an agreement between you and iThemes.
- Process for other purposes for which we obtain your consent.
HOW WE SHARE INFORMATION
iThemes shares the information it collects about you in the following ways:
- Advertising – Based on the cookies and other tracking devices, we may work with advertising companies to display ads that may be of interest to you
- Business Transactions – To provide information to a third party in the event of any disposition of all or any portion of our business (e.g. reorganization, sale, assignment, bankruptcy).
- Aggregated or De-identified Data – We may disclose or use aggregated or de-identified information with third party providers for research purposes relating to our Services.
- As Required by Law or Similar Investigations – To comply with legal obligations (e.g. subpoena) or investigate potential legal violations. Liquid Web may be required to share personal data in response to lawful requests from public authorities including to meet national security and/or law enforcement requirements.
- Safety – We may disclose your information to protect and defend the safety of iThemes in connection with investigating and preventing fraud or security issues.
- Consent – iThemes may share your information with your consent.
You may unsubscribe from receiving promotional or marketing emails from iThemes at any time by using the “unsubscribe” link in the email received, or by emailing us at email@example.com. As outlined in the Section, Information We Collect, you can also control your cookie settings.
With respect to your account information, you may update, correct or delete information that you provided to us by logging into your iThemes account or contacting us at firstname.lastname@example.org.
DATA RETENTION AND SECURITY
When iThemes no longer has a legitimate business need (e.g. termination of a Customer agreement) to process your personal information, we will either delete or anonymize it.
iThemes takes all reasonable steps to protect information received from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We maintain technical, physical, and administrative safeguards to secure your information, and we use industry standard Secure Socket Layer (SSL) encryption for your data that is transferred over the internet. Despite its use of encryption, iThemes cannot guarantee any method of transmission of information over the internet is 100% secure. If you have any questions about the security of your personal information, please contact us at email@example.com.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
For individuals in the EEA, iThemes’ legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. iThemes will process personal information from you where, a) we have your consent to do so, b) where processing is necessary for iThemes to perform Services pursuant to an agreement, or c) where processing is in our legitimate interests. and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information, or may otherwise need the personal information to protect your vital interests or those of another person. At any time, you have the right to withdraw or decline consent. If you do not provide the requested information, iThemes will not be able to perform Services for you. Also, you have the right to object where we rely on our legitimate interests to process your personal information.
iThemes stores your information in the United States. iThemes may transfer your personal information to countries other than the country in which you live. Whenever iThemes transfers personal information originating from the EEA or Switzerland to other countries not deemed adequate under applicable data protection law, it will do so on the basis of the Privacy Shield Frameworks or EU Standard Contractual Clauses.
iThemes remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless iThemes proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, iThemes commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact iThemes at the contact information in the “Contact Us” section below.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
DATA SUBJECT RIGHTS
Individuals located in the EEA may have additional statutory rights available to them with respect to their personal information, including the right to access your personal information, have it erased, have it corrected, or object to or restrict processing. If you would like to make such a request, please email firstname.lastname@example.org and we will respond within thirty (30) days. iThemes will need to verify that the individual is inquiring about his/her own information before we can assist with the request.
We will comply with such requests to the extent legally required by applicable law. For EU individuals, you also have the right to lodge a complaint with the supervisory authority.
Our Website and/or Services is not directed at children and our services are designed for consumers and businesses. We do not knowingly collect information from or about children under 13 years of age, and use of our services by children under 13 years of age is forbidden.
iThemes Privacy Matters
c/o Liquid Web, LLC
Attn: Director of Security
2703 Ena Drive
Lansing, MI 48917
Email – email@example.com
August 5, 2019 Version