SMI adheres to the following policies with regard to Your privacy.
- “NPI” is information that is not personally identifiable and that is obtained through Your use of the Service.
- “PII” is non-public information that is personally identifiable and obtained in connection with providing a product or service to You. It may include information such as name, email, phone number, and address that You provide to SMI. PII does not include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to contact or identify you.
3. INFORMATION COLLECTED
When You use the Service, SMI collects NPI, including Your device’s browser type. Likewise, in order to offer You meaningful products and services and for other reasons, SMI may collect PII about You from the following sources:
- Information available to Us through weblogs about Your traffic on other websites; or
- Information You give SMI on applications or other forms while using the Service, including without limitation Your responses to questions through the Service; or
- Information You send SMI via the Service; or
- If You use a mobile device platform to access the Service or communicate with SMI, information transmitted from Your mobile device; or
- Information purchased from or provided by third parties.
SMI may also use web beacons, pixels, anonymous ad network tags, and cookies to collect NPI about Your use of the Service, to collect anonymized, aggregated auditing, research and reporting for advertising purposes, and to collect data related to Your use of special promotions or newsletters. The information collected by web beacons also allows SMI to statistically monitor how many people open SMI emails and for what purposes these actions are being taken. SMI web beacons are not used to track Your activity outside of the Service or the websites of SMI sponsors. SMI does not link NPI from web beacons to PII without Your permission.
Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including SMI, do not respond to DNT signals.
Collection of Location Information
When You use the Service, We may collect location data from the browser or other software that You use to access the Service. We may also collect location data from Your device’s internet protocol (“IP”) address. SMI may also receive location data passed to it from third-party services or GPS-enabled devices that You have enabled.
Log Files, IP Addresses and Information About Your Device
When You use the Service, SMI automatically receives the URL of the site from which You came and the site to which You are going when You leave the Service. SMI also receives the IP address of Your computer (or the proxy server You use to access the internet), Your computer operating system and type of web browser You are using, email patterns, Your mobile device, including Your Unique Device Identifier (“UDID”) and mobile operating system, as well as the name of Your ISP or Your mobile carrier. The link between Your IP address and Your PII is not shared with third parties without Your permission, except as described in Section 8 (“When SMI May Disclose Your Information”), below.
5. USE OF PII
From time to time, We may disclose the information collected from You, including PII, in accordance with Section 8 (“When SMI May Disclose Your Information”), below.
SMI uses and/or intends to use PII to:
- Operate and improve the Service;
- Track use of the Service;
- Provide You with the Service and other products and services that You may request or that You have expressed interest in, including services provided to You under a written agreement entered into between You and SMI;
- Evaluate Your interest and needs in order to improve the Service and make available other offers, products or services;
- Provide You with personalized offers based on Your PII;
- Evaluate the types of offers, products or services SMI makes available to You and potential customers;
- Provide customer support;
- Communicate and provide additional information that may be of interest to You through email or other means, such as special offers, announcements, and marketing materials;
- Send You reminders, technical notices, updates, security alerts and support and administrative messages, service bulletins, or marketing;
6. LIMITATIONS ON ACCESS TO PII
Our policies limit access to un-aggregated user PII that is collected from the Service, including Our App, to Our employees and agents and the employees and/or agents of Our affiliates and business partners who need the information to fulfill their business responsibilities, and who are under obligations of confidentiality. In some cases, this may require Your PII to be sent to other countries. By supplying Your PII to SMI, including information supplied through the Service, You consent to Your information being transferred to SMI, its affiliates, vendors or agents. Vendors and other outside contractors We engage are subject to Our contractual requirements for safeguarding PII.
In addition, SMI employs commercially reasonable security measures, including advanced technology, to protect PII collected against unauthorized access, disclosure, alteration or destruction. SMI reviews and enhances its security systems in a commercially reasonable manner and as it deems necessary. Even with such technology, no web site or database is 100% secure. SMI cannot and does not guarantee that such security measures will prevent loss, misuse and/or alteration of information under its control.
7. OTHER WEBSITES
SMI is not responsible for the actions, practices, or content, including but not limited to the privacy practices, of such third-party websites from which You may access the Service. SMI does not guarantee, approve, or endorse any information, material, services, or products contained on these third-party websites. SMI is not responsible for any content on sites linked from or to the Service or for obtaining the necessary consent for such third party sites to collect, transmit, or otherwise use your information.
You understand that such websites may have their own legal documents to which You must agree prior to using and that SMI has no control over these legal documents. As always, You understand that it is Your responsibility to verify Your legal use of a website as well as use of information from the website with the corresponding website owner. If You visit the sites of third parties, please be sure to review the privacy policies applicable to those sites.
8. WHEN SMI MAY DISCLOSE YOUR INFORMATION
- B. SMI may share PII SMI collects, as permitted by law, to companies such as credit reporting agencies, or servicing and processing companies, or when required or advised to do so in response to a valid legal requirement to release this information such as a state or federal law, regulation, search warrant, subpoena, or court order; or in special cases, such as in response to a physical threat to You or others, to protect property, or if We determine such disclosure is legally advisable or necessary to defend or assert legal rights or prevent harm, to defend ourselves in litigation. In the event that SMI is legally compelled to disclose Your PII to a third party, SMI will attempt to notify You unless doing so would violate the law or court order.
- C. SMI may share PII in accordance with Section 11 (“Transfer of Ownership”), below.
- D. If You prefer that SMI does not share certain information with its contractors and service providers, as described above, You can direct SMI not to share that information by contacting Us at:
700 River Avenue
Pittsburgh, PA 15212
Please note that an opt-out with respect to information sharing will not apply to information sharing arrangements described in Sections 8. B or C.
9. SECURITY POLICY & USER ID/PASSWORD
The Service utilize various information security measures such as internet firewalls, an intrusion detection system, encrypted data transmission, and operating procedures to protect Your PII, accounts, passwords, etc. This information is kept completely separate and confidential, unless You have given someone else access to Your PII. If SMI provides the capability for You to create a user ID and password, You should protect Your user ID and password and NOT share it with anyone. If You believe Your user ID and password have been compromised and You have trouble changing Your user ID/password on the Service, please contact SMI’s technical support department (firstname.lastname@example.org).
10. CAN-SPAM COMPLIANCE NOTICE
SMI and its affiliates fully comply with the federal CAN-SPAM Act. You can always opt out of receipt of further email correspondence from SMI.
11. TRANSFER OF OWNERSHIP
12. NOTICE TO RESIDENTS OF COUNTRIES OUTSIDE OF THE UNITED STATES OF AMERICA
13. CALIFORNIA PRIVACY RIGHTS
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of PII that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of PII that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by SMI pursuant to Section 1798.83 of the California Civil Code, please contact SMI via email to email@example.com.
15. PROTECTING CHILDREN’S PRIVACY
Use of the Service is limited to users who are eighteen (18) years of age or older.
SMI strongly believes in protecting the privacy of children. In line with this belief, We do not knowingly collect or maintain PII from the Service from persons under eighteen (18) years of age, and no part of the Service is directed to persons under eighteen (18) years of age. If You are under eighteen (18) years of age, then please do not use or access the Service at any time in any manner. We will take appropriate steps to delete any PII of persons less than eighteen (18) years of age that has been collected on the Service without verified parental consent upon learning of the existence of such PII.
16. GENERAL DATA PROTECTION REGULATION (GDPR)
SMI’s policy is to protect and safeguard any PII obtained by SMI in accordance with applicable United States state and federal laws governing the protection of PII and data. Those who choose to access Our Service from locations outside the United States do so on their own initiative, and are responsible for compliance with local laws if and to the extent local laws are applicable.
Although SMI does not target or knowingly collect data from users in the EU, SMI has undertaken efforts to ensure Our services are compliant with the European Union’s General Data Protection Regulation (GDPR), including limiting Our Service’s availability to only users located outside the EU and United Kingdom. If You are an EU or United Kingdom resident and believe We may have collected PII from You, subject, as the case may be, to additional elements that may be required to establish Your identity, You may send Us an e-mail at firstname.lastname@example.org to request, at no charge, to delete any information We may have collected from You.
700 River Avenue
Pittsburgh, PA 15212
Our response to such inquiries may be limited to information under Our direct control.