2. A NOTE ABOUT CHILDREN. We do not intentionally gather Personal Data about visitors who are under the age of 13.
4. TYPES OF DATA WE COLLECT. Company collects Personal Data and Anonymous Data from you when you visit our site, when you send us or our Coaches information or communications, and/or when you download and use our Products. ‘Personal Data’ means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. ‘Anonymous Data’ means data that is not associated with or linked to your Personal Data. Anonymous Data does not permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
Personal Data You Provide to Us. We collect Personal Data from you, such as your email address when you provide it voluntarily on the Site. If you provide us feedback or contact us via e-mail (e.g., in response to an employment opportunity posted on our website), we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply, and any information that you submit to us, such as a resume. When you participate in one of our surveys, we may collect additional profile information. When you post messages on the message boards of our website, the information contained in your posting will be stored on our servers and other users will be able to see it. We also collect other types of Personal Data that you provide to us voluntarily, such as your Twitter name or Facebook profile. We may also collect Personal Data, such as demographic information from you via the Products or at other points in our website that state that Personal Data is being collected.
Recordings. By using our Services you consent to the audio or video recording of conversations between your Coach and yourself and the use of such recordings and any data relating thereto by Willow in order to improve the services and products offered by Willow. Any data from such recordings shall only be used in to improve our Services as described in the section titled “Creation of Anonymized Data” below.
Willow is a member of the Digital Advertising Alliance (DAA) self-regulatory program and adheres to the DAA self-regulatory Principles for Online Behavioral Advertising. We work with a variety of advertisers, ad networks and analytics companies (“Ad Partners”) that collect information about your use of our services. You can opt out of the use of interest-based advertising at any time by visiting the Digital Advertising Alliance consumer choice page.
Our Relationship with Social Networking Sites. We have created, and may offer You, interfaces that allow You to connect with social networking websites such as Facebook and Twitter (‘SN Sites’) through our Site. We will work with the SN Site’s application protocol interface (better known as their developer API) in a way that allows You to authorize us to access Your account on that SN Site on Your behalf. In order to provide this authorization, You will not provide us with Your user name or password to the SN Site, but You will need to log-in to that SN Site directly through our Site. Once authorized by You, the SN Site will provide us a token that allows the SN Site to recognize us when we ask, on Your behalf, for access to Your account information or to post information. You will be able to revoke our access to any SN Site at any time by amending the appropriate settings from within Your account settings on the applicable SN Site, though such revocation may limit the Services we are able to provide You.
5. USE OF YOUR DATA.
General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. Company uses your Personal Data in the following ways:
Provide you with the Services and customer support;
Respond to your requests, resolve disputes and/or troubleshoot problems;
Improve the quality of the Site and the Services;
Communicate with you about the Site and the Services;
Market our products and services (and those of third parties) to You that we believe may be of interest to You. If you prefer that we do not send you these messages, please see the section below on YOUR CHOICES REGARDING YOUR PERSONAL DATA to learn how to opt-out.
Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our products and services and improve site navigation. Company reserves the right to use and disclose Anonymous Data to Third Party Companies in its discretion. [a]
6. DISCLOSURE OF YOUR PERSONAL DATA.
Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas or warrants served on Company; or (b) protect or defend the rights or property of Company or users of the Products or related services.
7. THIRD PARTIES.
Personal and/or Anonymous Data Collected by Third Parties. We may receive Personal and/or Anonymous Data about you from other sources like telephone or fax, or from companies that provide our products or services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website (‘Third Party Companies’). Our Third Party Companies may supply us with Personal Data, such as your email address, in order to help us establish the account. We may add this information to the information we have already collected from you via our website in order to improve the products and services we provide.
Our provision of a link to any other website or location, such as the payment processing websites, is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our site and go to another site. During this process, another entity may collect Personal Data or Anonymous Data from you.
Disclosure to Third Party Service Providers. Except as otherwise stated in this policy, we do not generally sell, trade, share, or rent the Personal Data collected from our services to other entities. However, we may share your Personal Data with third party service providers to facilitate creation of accounts or to provide services to us that enable us to make the Site or Services available to you or to our Coaches to provide a service to you. You expressly consent to the sharing of your Personal Data with our contractors and other service providers for the sole purpose of providing services to you.
Disclosure to Third Party Companies. We may enter into agreements with Third Party Companies. A Third Party Company may want access to Personal Data that we collect from its customers. As a result, we may disclose your Personal Data to a Third Party Company. The privacy policies of our Third Party Companies may apply to the use and disclosure of your Personal Data that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of our Third Party Companies, you should read and understand their privacy policies.
NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83).
A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A ‘CALIFORNIA CUSTOMER’), MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING LACY@TRUSTWILLOW.COM. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR, AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.
8. YOUR CHOICES REGARDING YOUR PERSONAL DATA.
Changes to Personal Data. You may request deletion of your Personal Data by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.
9. SECURITY OF YOUR PERSONAL DATA. Company is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. Despite these measures, you should know that Company cannot fully eliminate security risks associated with Personal Data and mistakes may happen.
Willow Network, Inc
Attn: Lacy Garcia
226 Causeway Street, 6th Floor, Boston, MA 02114, USA
11. DISPUTE RESOLUTION. If you believe that Company has not adhered to this Statement, please contact Company by email at email@example.com. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.
[a] This is addressed more fully in the TOS.