UNS WEBSITE AND GATEKEEPER PRIVACY NOTICE
Effective Date: [10/26/2020]
This Privacy Notice explains how UNS Project, Inc. (“Company”, “UNS”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes Personal Information (as defined below) in connection with our website (the “Site”) and where we collect Personal Information from UNSproject.com and GATEKEEPER.UNIVERSALNAMESERVICE.COM. (collectively, the “Services”). This Privacy Notice does not address the collection and use of Personal Information from users of GUARDIAN.UNVERSALNAMESERVICE.COM, for which see [insert link]. We are the data controller. We are responsible for, and control, the processing of your Personal Information. If you wish to contact us, you can find our contact details in the “Contact Us” section of this Privacy Notice below.
What is Personal Information?
When we use the term “Personal Information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Our Collection of Personal Information
Sometimes we collect Personal Information automatically when an individual interacts with our Services and sometimes, we collect the Personal Information directly from an individual. At times, we may collect Personal Information about an individual from other sources and third parties, even before our first direct interaction.
Personal Information Collected from Site Visitors
We may collect the following Personal Information submitted to us by visitors to our Site or when a user uses our Services:
- Contact Information, including first and last name, email address, phone number and communication preferences.
- Inquiry Information, including information provided in custom messages sent through the forms or contact information provided on our Site.
- Device Information, including device ID and IP address.
- SERVICE DOMAIN
- SERVICE PUBLIC KEYS AND X.509 CERTIFICATE and related information required for Public Key Infrastructure
- API usage – Number of authentication requests
Personal Information Automatically Collected
As is true of most digital platforms, we and our third-party providers may also collect Personal Information from an individual’s device, browsing actions and site usage patterns automatically when visiting or interacting with our Site, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Site and any errors that may occur during the visit to our Site), analytics data (such as the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site) and location data (such as general geographic location based on the log data we or our third-party providers collect).
We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this Personal Information. For example, our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to collect and view reports about the traffic on our Site. More information about the use of Google Analytics for these analytical and non‑advertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here.
The following types of cookies are used on our Site:
- Strictly Necessary Cookies: These cookies enable core functionality such as security, network management and accessibility. You may disable these by changing your browser settings, but this may affect how the websites and online services function.
- Analytical/Performance Cookies: These cookies allow us to recognize and count the number of visitors to our websites and online services, and to see how visitors move around our websites and online services when they are using them. This helps us to improve the way our websites and online services work, for example, by ensuring that users are finding what they are looking for easily. If you are accessing our websites with a European IP address, you have been asked to consent to the use of these cookies. You are free to deny your consent. Please see the “Annex” below for more information.
- Functionality Cookies: These enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Site, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
Personal Information from Third Parties
We also obtain Personal Information from third parties; which we often combine with Personal Information we collect either automatically or directly from an individual.
We may receive the same categories of Personal Information as described above from the following third parties:
- Business Partners: When an individual interacts with our Services through or in conjunction with our business partners, we may receive some information about individuals that they permit our business partners to share with third parties.
- Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers, collect Personal Information and often share some or all of this information with us.
- Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual.
Our Use of Personal Information
We may use Personal Information we collect to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations;.
- Manage our organization and its day-to-day operations;
- Communicate with individuals, including via email, text message, social media and/or telephone calls;
- Request individuals to complete surveys about our organization, organizations we partner with, and Services;
- Market to individuals, including through email, direct mail, phone or text message;
- Provide you with news, special offers and general information about goods, services and events you may be interested in;
- Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site;
- Facilitate client benefits and services, including customer support through our command center services;
- Conduct research and analytics on our client base and our Services;
- Improve and customize our Services to address the needs and interests of clients and individuals we interact with;
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- Defend, protect or enforce our rights or applicable contracts and agreements;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity; and
- Comply with legal obligations.
Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information provided at that time.
Our Disclosure of Personal Information
We may disclose Personal Information in the following ways:
- Affiliates. We may share Personal Information with other companies owned or controlled by Company, and other companies owned by or under common ownership as Company, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
- Business Partners: We may share Personal Information with our business partners.
- Service Providers: We engage third-party service providers that perform business or operational services for us or on our behalf, such as marketing services, customer service operations, communications services, website hosting, infrastructure provisioning, IT services, analytics services, and administrative services.
- Other Business As Needed To Provide Services: We may also share Personal Information with third parties that an individual engages with through our Services or as needed to fulfill a request or transaction.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Information may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose Personal Information to third parties, such as legal advisors and law enforcement: (i) in connection with the establishment, exercise, or defense of legal claims; (ii) to comply with laws or to respond to lawful requests and legal process; (iii) to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; (iv) to detect, suppress, or prevent fraud; (v) to protect the health and safety of us and others; or (vi) as otherwise required by applicable law.
- Otherwise With Consent or Direction: We may disclose Personal Information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Site or service-related publications.
Links to Third-Party Websites or Services
Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy notices.
Updates to This Privacy Notice
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify individuals by email to their registered email address, by prominent posting on this Site or our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
Region-Specific Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:
- If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please contact us at privacy@unsproject.com to submit such a request.
- If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
- If you are based in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”), please click here for additional Europe-specific privacy disclosures.
Contact Us
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@unsproject.com Alternatively, inquiries may be addressed to:
Universal Name System
615 W. Johnson Ave, Suite 202
Cheshire, CT 06410-4532
ADDITIONAL EUROPE-SPECIFIC PRIVACY DISCLOSURES
Last Updated: 10-26-2020
These additional European Economic Area (“EEA”), Switzerland and United Kingdom (“UK”) privacy disclosures (“European Privacy Disclosures”) supplement the information contained in our above Privacy Notice. However, these European Privacy Disclosures apply only to our processing of your Personal Data where you are based in the EEA, Switzerland or the UK
Unless otherwise expressly stated, capitalized terms in these European Disclosures have the same meaning as defined above.
Company is the controller of the Personal Data (as defined below) we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your Personal Data is used.
Personal Data Disclosures
When we use the term “Personal Data ” in these European Privacy Disclosures, we mean any information relating to an identified or identifiable natural person.
Legal Bases for Processing
We use the Personal Data we collect about you in the following ways and rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:
Category of Personal Data | How We Use the Personal Data | Legal Basis for Processing |
Contact information, such as name, phone number and email address. | We use this information to communicate with you, including sending service-related communications. | The processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract. |
We use this information to send you unsolicited marketing communications in accordance with your preferences. | We will only use your Personal Data in this way to the extent you have given us consent to do so. | |
We use this information to address inquiries and complaints made by you relating to your use of our Services. | The processing is necessary for our legitimate interests, namely administering our Services and for communicating with you effectively to respond to your queries or complaints. | |
Data collected through the use of our Services, including information about how you use our Services, your actions on our Services, including feedback through the Services. | We may use information about how you use and connect to our Services to present our Services to you on your device. | The processing is necessary for our legitimate interests, namely, to tailor our Services to the user. |
We may use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely, to inform our direct marketing. | |
We may use this information to monitor and improve our Services and business, resolve issues and to inform the development of new products and services. | The processing is necessary for our legitimate interests, namely, to monitor and resolve issues with our Services and to improve our Services generally. | |
Your preferences, such as preferences set for notifications and marketing communications. | We use this information to provide our Services to you in accordance with your choices. | The processing is necessary for our legitimate interests, namely ensuring our Services are displayed in accordance with the user’s preferences. |
We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented. | The processing is necessary for compliance with a legal obligation to which we are subject. | |
Location information, we do not collect information about your precise location (other than information you choose to provide us); however, your WiFi, wireless network triangulation, or your IP address may help us determine an approximate location . | Providing you with content that is more relevant to you based on your location. | We only process your Personal Data in this way to the extent that you have given us your consent. |
Information provided by social networks you connect to our Services, including when you “Like”, follow or share UNS content on Facebook, Twitter, Instagram or other sites. We also receive profile information, picture, user ID, and any other information associated with your social media account that you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network. | We use this information to promote and market our Services and increase user engagement with our products and Services. | The processing is necessary for our legitimate interests, namely promoting our products and services and increasing user engagement with our products and services. |
Information contained in communications between you and UNS, including any information you provide when you contact us or interact with us directly, such as by participating in a contest or promotion, or submitting feedback or other information to us. | We use this information to respond to comments, questions or requests for customer service. | The processing is necessary for our legitimate interests, namely administering our Services and addressing your queries and concerns. |
We use this information to address any violations of our Terms of Service , or any other rules, regulations or policies relating to our Services. | The processing is necessary for the performance of a contract between you and us. | |
Information about how you access and use our Services, including usage history, and your clicking and browsing patterns. | We use this information to operate, maintain and provide to you the features and functionality of our Services, to improve our products and services, for research and product development. | The processing is necessary for our legitimate interests, namely, to tailor our Services to you, to improve our Services and to develop new features and functionalities on our Services. |
Internet and network information, including device information, logs and analytics data. | We use this information to provide and monitor the effectiveness of our Services; monitor usage of and activities on our Services; diagnose errors and problems with our Services; otherwise plan for and enhance our Services; understand your activities when you use our Services to deliver ads and information about products and services that may be of interest to you. | The processing is necessary for our legitimate interests, namely, to tailor our Services to you, to improve our Services and to develop new features and functionalities on our Services. |
All Personal Data as set out above. | We may use this information to comply with any professional or legal obligation to which we may be subject, such as disclosure of information to comply with a court order or at the request of a regulator. | The processing is necessary for the compliance with a legal obligation to which we are subject. |
We may use this information to facilitate our internal business operations that are put in place for compliance with our legal obligations. | The processing is necessary for our legitimate interests, namely the detection and prevention of fraud and the fulfilment of professional obligations. | |
We may use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely, to inform our direct marketing. |
We use the Personal Data we automatically collect about you in the following ways and rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:
Category of Personal Data | How We Use the Personal Data | Legal Basis for Processing |
Information about how you access our Services.For example, the site from which you came and the site to which you are going when you leave our websites, how frequently you access the Services, whether you open emails or click the links contained in emails, and whether you access the Services from multiple devices. | We or the third-party partners we use, may use the data collected through tracking technologies to:
a) remember information so that you will not have to re-enter it during your visit or the next time you visit our Services; b) provide custom, personalized content and information, including targeted content and advertising; c) identify and contact you across multiple devices; d) provide and monitor the effectiveness of our Services; e) perform analytics and detect usage patterns on our Services; f) diagnose or fix technology problems; g) detect or prevent fraud or other harmful activities, and h) otherwise plan for and enhance our Services.
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The processing is necessary for our legitimate interests, namely: to tailor our Services to the user and to improve our Services generally; to monitor and resolve issues; for marketing purposes; to communicate with users; to contact users; and for the detection and prevention of fraud.
For more information on the legal basis for cookies, please see the “Personal Information Automatically Collected” section above. |
Information about how you use our Services. For example, the pages you visit, the links you click, the ads you view and click on, your purchase and subscription information, your location when you access or interact with our Services and other similar actions. | ||
Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. | ||
Analytics information. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our Services and to understand more about the demographics and behaviors of our users. |
You are not required to provide Personal Data to us, but we do rely on your Personal Data to provide certain of our services and products. If you choose not to provide us with your Personal Data, we may not be able to provide you with a service or product you request.
Data Retention
We retain Personal Data about you for as long as is necessary for the purposes set out in these European Privacy Disclosures, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights. In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the Personal Data, as well as the potential risk of harm from unauthorized use or disclosure of your Personal Data.
Personal Data Disclosures
We may transfer Personal Data about you among us and to our subsidiaries or affiliates, as well as to the categories of third parties identified in the “Our Disclosure of Personal Information ” section of our Privacy Notice above. Personal Data may be transferred to, stored and processed in a country other than the one in which it was collected, including, but not limited to, the United States. The country to which Personal Data is transferred may not provide the same level of protection for Personal Data as the country from which it was transferred.
Adequacy Decisions
We may transfer Personal Data about you to countries that the European Commission has deemed to adequately safeguard Personal Data.
Standard Contractual Clauses
The European Commission has adopted Standard Contractual Clauses, which provide safeguards for Personal Data transferred outside of the EEA, Switzerland and the UK. We may use these Standard Contractual Clauses when transferring Personal Data from a country in the EEA, Switzerland or the UK to a country outside the EEA, Switzerland or the UK that has not been deemed to adequately safeguard Personal Data. You can request a copy of our Standard Contractual Clauses by contacting us as set forth in the “Contact Us” section of our Privacy Notice above.
Your Privacy Rights
You have the following rights in relation to your Personal Data (subject to certain limitations at law):
Access | The right to obtain:
(i) confirmation of whether, and where, we are processing your Personal Data; |
Rectification | The right to correct or update any Personal Data about you that is inaccurate or incomplete. |
Restriction of Processing | The right to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the Personal Data is contested by you. |
Erasure | The right to request the deletion or erasure of Personal Data about you without undue delay if the continued processing of that Personal Data is not justified. |
Portability | The right to obtain a copy of Personal Data about you in an easily accessible format and the right to transmit that Personal Data to another controller. |
Objection to Processing | You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason. |
Please note that if the exercise of these rights limits our ability to process Personal Data, we may not be able to provide our products or services to you, or otherwise engage with you going forward.
Right to Withdraw Consent
Where we rely on your consent for processing of your Personal Data, as identified in the “Legal Bases for Processing ” section above, you also have the right to withdraw your consent to such processing. You may withdraw your consent at any time by contacting us using the contact details in the “Contact Us” section of our Privacy Notice above.
Submitting Requests
To submit a request, please contact us as set forth in the “Contact Us” section of our Privacy Notice above. We may need to verify your identity before processing your request, which may require us to obtain additional Personal Data from you. In certain circumstances, we may decline a request to exercise the rights described above.
Right to Lodge a Complaint
If you have any complaints regarding our privacy practices, you have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority). If you are based in the EEA, Switzerland or UK, information about how to contact your local data protection authority is available here . However, we encourage you to first reach out to us by using the contact details set out in the “Contact Us” section above so that you have an opportunity to address your concerns directly and so that we may find a solution together before you do lodge a complaint.
ADDITIONAL CALIFORNIA SPECIFIC PRIVACY DISCLOSURES
Last Updated 10-26-2020
These additional California-specific privacy disclosures (“CA Disclosures”) supplement the information contained in our above Privacy Notice by providing additional information about how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). Unless otherwise expressly stated, all terms defined in our Privacy Notice above retain the same meaning in these CA Disclosures and all other terms defined in the CCPA and not otherwise defined in these CA Disclosures have the same meaning when used in these CA Disclosures.
Collection, Disclosure, and Sale of Personal Information
In the last 12 months, we have not sold personal information about you, but we have collected and disclosed for a business purpose the following categories and examples of specific pieces of personal information, which reference the personal information described in the “Our Collection of Personal Information” and the “Our Use of Personal Information” sections above:
Category of Personal Information | Collected | Disclosedfor BusinessPurpose | Sold |
Identifiers, such as including first and last name, email address, and phone number. | No
Personal Information Sold |
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California Customer Records (Cal. Civ. Code § 1798.80(e)): including your contact information. | |||
Internet/Network Information, such as log data, analytics data, and application data. | |||
Geolocation Data, including your general geographic location or more precise location when permitted by law. | |||
Sensory Information, including recordings of phone calls between you and us, where permitted by law. | |||
Other Personal Information, including communication preferences, customer service and communication history, personal information you permit us to see when interacting with us through social media, and personal information you provide us in relation to a question, request, inquiry, survey, contest or promotion. | |||
Inferences, including our predictions about your interests and preferences and related service profile information. |
Sources of Personal Information
As described in the “Our Collection of Personal Information” section of this Privacy Notice above, we collect personal information directly from you when you provide it to us, automatically when you visit our websites and other online services, and from service providers and other third parties.
Purposes for Collecting Personal Information
We collect personal information about you for the purposes described in the “Our Use of Personal Information” section above.
Recipients of Personal Information
As described in the “Our Disclosure of Personal Information” section above, we share personal information within the Company and with a variety of third parties.
Your Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
Right to Know | The right to request any or all of the following personal information we have collected and disclosed about you in the last 12 months:
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Right to Deletion | The right to request the deletion of personal information we have collected from you, subject to certain exceptions. |
Right to Opt Out | The right to direct us not to sell personal information we have collected about you to third parties. |
Right to Non-Discrimination | The right to be free from discrimination for exercising any of the rights described above.
The right to non-discrimination does not prohibit us from offering you certain financial incentives that may result in different prices, rates or quality levels of products or services. In addition, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may not be able to provide our products and services to individuals who exercise these rights, or to otherwise engage with such individuals going forward. |
Submitting Requests
To Exercise Your Right to Know or Right to Deletion:
To submit a request to exercise your right to know or right to deletion, please submit a request by emailing us at [insert email] or by [insert alternative submission method (e.g., webform or toll-free phone number)].
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, or date of last interaction with customer service.
In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.
Authorized Agents:
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit a right to know and/or right to deletion request on your behalf through the designated methods set forth in these CA Disclosures where we can verify the authorized agent’s authority to act on your behalf by:
- receiving a power of attorney valid under the laws of California from you or your authorized agent; or
- receiving sufficient evidence to show that you have:
- provided the authorized agent signed permission to act on your behalf;
- verified your own identity directly with us pursuant to the instructions set forth in these CA Disclosures; and
- directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
ANNEX – COOKIES
Company | Name | Type of cookie | Used On | Purposes / Additional description | How to change preferences |
[Google Analytics] | [__utma] | [Analytics cookie] | [https://unsproject.com] | [This is one of the four main Cookies set by the Google Analytics services which enables website owners to understand visitor behavior and measure the website performance. This Cookie distinguishes between users and sessions. It is used to calculate new and returning visitor statistics. The Cookie is updated every time data is sent to Cookie Analytics. The lifespan of the Cookie can be customized by website owners. Currently configured for [six months].
Please also see Google’s Policy: https://policies.google.com/technologies/cookies?hl=en] |
[You may review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/] |
This Privacy Notice explains how UNS Project, Inc. (“Company”, “UNS”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes Personal Information (as defined below) in connection with our website (the “Site”) and where we collect Personal Information from UNSproject.com and GATEKEEPER.UNIVERSALNAMESERVICE.COM. (collectively, the “Services”). This Privacy Notice does not address the collection and use of Personal Information from users of GUARDIAN.UNVERSALNAMESERVICE.COM, for which see [insert link]. We are the data controller. We are responsible for, and control, the processing of your Personal Information. If you wish to contact us, you can find our contact details in the “Contact Us” section of this Privacy Notice below.
Region-Specific Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:
- If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please contact us at privacy@unsproject.com to submit such a request.
- If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
- If you are based in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”), please click here for additional Europe-specific privacy disclosures.
What is Personal Information?
When we use the term “Personal Information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Our Collection of Personal Information
Sometimes we collect Personal Information automatically when an individual interacts with our Services and sometimes, we collect the Personal Information directly from an individual. At times, we may collect Personal Information about an individual from other sources and third parties, even before our first direct interaction.
Personal Information Collected from Site Visitors
We may collect the following Personal Information submitted to us by visitors to our Site or when a user uses our Services:
- Contact Information, including first and last name, email address, phone number and communication preferences.
- Inquiry Information, including information provided in custom messages sent through the forms or contact information provided on our Site.
- Device Information, including device ID and IP address.
- SERVICE DOMAIN
- SERVICE PUBLIC KEYS AND X.509 CERTIFICATE AND RELATED INFORMATION REQUIRED FOR PUBLIC KEY INFRASTRUCTURE (PKI)
API usage – Number of authentication requests
- [Any other data collection?]
Personal Information Automatically Collected
As is true of most digital platforms, we and our third-party providers may also collect Personal Information from an individual’s device, browsing actions and site usage patterns automatically when visiting or interacting with our Site, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Site and any errors that may occur during the visit to our Site), analytics data (such as the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site) and location data (such as general geographic location based on the log data we or our third-party providers collect).
We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this Personal Information. For example, our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to collect and view reports about the traffic on our Site. More information about the use of Google Analytics for these analytical and non‑advertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here.
The following types of cookies are used on our Site:
- Strictly Necessary Cookies: These cookies enable core functionality such as security, network management and accessibility. You may disable these by changing your browser settings, but this may affect how the websites and online services function.
- Analytical/Performance Cookies: These cookies allow us to recognize and count the number of visitors to our websites and online services, and to see how visitors move around our websites and online services when they are using them. This helps us to improve the way our websites and online services work, for example, by ensuring that users are finding what they are looking for easily. If you are accessing our websites with a European IP address, you have been asked to consent to the use of these cookies. You are free to deny your consent. Please see the “Annex” below for more information.
- Functionality Cookies: These enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Site, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
Personal Information from Third Parties
We also obtain Personal Information from third parties; which we often combine with Personal Information we collect either automatically or directly from an individual.
We may receive the same categories of Personal Information as described above from the following third parties:
- Business Partners: When an individual interacts with our Services through or in conjunction with our business partners, we may receive some information about individuals that they permit our business partners to share with third parties.
- Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers, collect Personal Information and often share some or all of this information with us.
- Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual.
Our Use of Personal Information
We may use Personal Information we collect to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations;.
- Manage our organization and its day-to-day operations;
- Communicate with individuals, including via email, text message, social media and/or telephone calls;
- Request individuals to complete surveys about our organization, organizations we partner with, and Services;
- Market to individuals, including through email, direct mail, phone or text message;
- Provide you with news, special offers and general information about goods, services and events you may be interested in;
- Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site;
- Facilitate client benefits and services, including customer support through our command center services;
- Conduct research and analytics on our client base and our Services;
- Improve and customize our Services to address the needs and interests of clients and individuals we interact with;
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- Defend, protect or enforce our rights or applicable contracts and agreements;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity; and
- Comply with legal obligations.
Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information provided at that time.
Our Disclosure of Personal Information
We may disclose Personal Information in the following ways:
- Affiliates. We may share Personal Information with other companies owned or controlled by Company, and other companies owned by or under common ownership as Company, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
- Business Partners: We may share Personal Information with our business partners.
- Service Providers: We engage third-party service providers that perform business or operational services for us or on our behalf, such as marketing services, customer service operations, communications services, website hosting, infrastructure provisioning, IT services, analytics services, and administrative services.
- Other Business As Needed To Provide Services: We may also share Personal Information with third parties that an individual engages with through our Services or as needed to fulfill a request or transaction.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Information may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose Personal Information to third parties, such as legal advisors and law enforcement: (i) in connection with the establishment, exercise, or defense of legal claims; (ii) to comply with laws or to respond to lawful requests and legal process; (iii) to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; (iv) to detect, suppress, or prevent fraud; (v) to protect the health and safety of us and others; or (vi) as otherwise required by applicable law.
- Otherwise With Consent or Direction: We may disclose Personal Information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Site or service-related publications.
Links to Third-Party Websites or Services
Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy notices.
Updates to This Privacy Notice
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify individuals by email to their registered email address, by prominent posting on this Site or our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@unsproject.com Alternatively, inquiries may be addressed to:
615 W. Johnson Ave, Suite 202
Cheshire, CT 06410-4532
ADDITIONAL EUROPE-SPECIFIC PRIVACY DISCLOSURES
Last Updated: 10-26-2020
These additional European Economic Area (“EEA”), Switzerland and United Kingdom (“UK”) privacy disclosures (“European Privacy Disclosures”) supplement the information contained in our above Privacy Notice. However, these European Privacy Disclosures apply only to our processing of your Personal Data where you are based in the EEA, Switzerland or the UK
Unless otherwise expressly stated, capitalized terms in these European Disclosures have the same meaning as defined above.
Company is the controller of the Personal Data (as defined below) we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your Personal Data is used.
Personal Data Disclosures
When we use the term “Personal Data ” in these European Privacy Disclosures, we mean any information relating to an identified or identifiable natural person.
Legal Bases for Processing
We use the Personal Data we collect about you in the following ways and rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:
Category of Personal Data | How We Use the Personal Data | Legal Basis for Processing |
Contact information, such as name, phone number and email address. | We use this information to communicate with you, including sending service-related communications. | The processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract. |
We use this information to send you unsolicited marketing communications in accordance with your preferences. | We will only use your Personal Data in this way to the extent you have given us consent to do so. | |
We use this information to address inquiries and complaints made by you relating to your use of our Services. | The processing is necessary for our legitimate interests, namely administering our Services and for communicating with you effectively to respond to your queries or complaints. | |
Data collected through the use of our Services, including information about how you use our Services, your actions on our Services, including feedback through the Services. | We may use information about how you use and connect to our Services to present our Services to you on your device. | The processing is necessary for our legitimate interests, namely, to tailor our Services to the user. |
We may use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely, to inform our direct marketing. | |
We may use this information to monitor and improve our Services and business, resolve issues and to inform the development of new products and services. | The processing is necessary for our legitimate interests, namely, to monitor and resolve issues with our Services and to improve our Services generally. | |
Your preferences, such as preferences set for notifications and marketing communications. | We use this information to provide our Services to you in accordance with your choices. | The processing is necessary for our legitimate interests, namely ensuring our Services are displayed in accordance with the user’s preferences. |
We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented. | The processing is necessary for compliance with a legal obligation to which we are subject. | |
Location information, we do not collect information about your precise location (other than information you choose to provide us); however, your WiFi, wireless network triangulation, or your IP address may help us determine an approximate location . | Providing you with content that is more relevant to you based on your location. | We only process your Personal Data in this way to the extent that you have given us your consent. |
Information provided by social networks you connect to our Services, including when you “Like”, follow or share UNS content on Facebook, Twitter, Instagram or other sites. We also receive profile information, picture, user ID, and any other information associated with your social media account that you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network. | We use this information to promote and market our Services and increase user engagement with our products and Services. | The processing is necessary for our legitimate interests, namely promoting our products and services and increasing user engagement with our products and services. |
Information contained in communications between you and UNS, including any information you provide when you contact us or interact with us directly, such as by participating in a contest or promotion, or submitting feedback or other information to us. | We use this information to respond to comments, questions or requests for customer service. | The processing is necessary for our legitimate interests, namely administering our Services and addressing your queries and concerns. |
We use this information to address any violations of our Terms of Service , or any other rules, regulations or policies relating to our Services. | The processing is necessary for the performance of a contract between you and us. | |
Information about how you access and use our Services, including usage history, and your clicking and browsing patterns. | We use this information to operate, maintain and provide to you the features and functionality of our Services, to improve our products and services, for research and product development. | The processing is necessary for our legitimate interests, namely, to tailor our Services to you, to improve our Services and to develop new features and functionalities on our Services. |
Internet and network information, including device information, logs and analytics data. | We use this information to provide and monitor the effectiveness of our Services; monitor usage of and activities on our Services; diagnose errors and problems with our Services; otherwise plan for and enhance our Services; understand your activities when you use our Services to deliver ads and information about products and services that may be of interest to you. | The processing is necessary for our legitimate interests, namely, to tailor our Services to you, to improve our Services and to develop new features and functionalities on our Services. |
All Personal Data as set out above. | We may use this information to comply with any professional or legal obligation to which we may be subject, such as disclosure of information to comply with a court order or at the request of a regulator. | The processing is necessary for the compliance with a legal obligation to which we are subject. |
We may use this information to facilitate our internal business operations that are put in place for compliance with our legal obligations. | The processing is necessary for our legitimate interests, namely the detection and prevention of fraud and the fulfilment of professional obligations. | |
We may use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely, to inform our direct marketing. |
We use the Personal Data we automatically collect about you in the following ways and rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:
Category of Personal Data | How We Use the Personal Data | Legal Basis for Processing |
Information about how you access our Services. For example, the site from which you came and the site to which you are going when you leave our websites, how frequently you access the Services, whether you open emails or click the links contained in emails, and whether you access the Services from multiple devices. | We or the third-party partners we use, may use the data collected through tracking technologies to:
a) remember information so that you will not have to re-enter it during your visit or the next time you visit our Services; b) provide custom, personalized content and information, including targeted content and advertising; c) identify and contact you across multiple devices; d) provide and monitor the effectiveness of our Services; e) perform analytics and detect usage patterns on our Services; f) diagnose or fix technology problems; g) detect or prevent fraud or other harmful activities, and h) otherwise plan for and enhance our Services.
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The processing is necessary for our legitimate interests, namely: to tailor our Services to the user and to improve our Services generally; to monitor and resolve issues; for marketing purposes; to communicate with users; to contact users; and for the detection and prevention of fraud.
For more information on the legal basis for cookies, please see the “Personal Information Automatically Collected” section above. |
Information about how you use our Services. For example, the pages you visit, the links you click, the ads you view and click on, your purchase and subscription information, your location when you access or interact with our Services and other similar actions. | ||
Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. | ||
Analytics information. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our Services and to understand more about the demographics and behaviors of our users. |
You are not required to provide Personal Data to us, but we do rely on your Personal Data to provide certain of our services and products. If you choose not to provide us with your Personal Data, we may not be able to provide you with a service or product you request.
Data Retention
We retain Personal Data about you for as long as is necessary for the purposes set out in these European Privacy Disclosures, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights. In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the Personal Data, as well as the potential risk of harm from unauthorized use or disclosure of your Personal Data.
Personal Data Disclosures
We may transfer Personal Data about you among us and to our subsidiaries or affiliates, as well as to the categories of third parties identified in the “Our Disclosure of Personal Information ” section of our Privacy Notice above. Personal Data may be transferred to, stored and processed in a country other than the one in which it was collected, including, but not limited to, the United States. The country to which Personal Data is transferred may not provide the same level of protection for Personal Data as the country from which it was transferred.
Adequacy Decisions
We may transfer Personal Data about you to countries that the European Commission has deemed to adequately safeguard Personal Data.
The European Commission has adopted Standard Contractual Clauses, which provide safeguards for Personal Data transferred outside of the EEA, Switzerland and the UK. We may use these Standard Contractual Clauses when transferring Personal Data from a country in the EEA, Switzerland or the UK to a country outside the EEA, Switzerland or the UK that has not been deemed to adequately safeguard Personal Data. You can request a copy of our Standard Contractual Clauses by contacting us as set forth in the “Contact Us” section of our Privacy Notice above.
Your Privacy Rights
You have the following rights in relation to your Personal Data (subject to certain limitations at law):
Access | The right to obtain:
(i) confirmation of whether, and where, we are processing your Personal Data; (ii) information about the categories of Personal Data we are processing, the purposes for which we process your Personal Data and information as to how we determine applicable retention periods; (iii) information about the categories of recipients with whom we may share your Personal Data; and (iv) a copy of the Personal Data we hold about you. |
Rectification | The right to correct or update any Personal Data about you that is inaccurate or incomplete. |
Restriction of Processing | The right to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the Personal Data is contested by you. |
Erasure | The right to request the deletion or erasure of Personal Data about you without undue delay if the continued processing of that Personal Data is not justified. |
Portability | The right to obtain a copy of Personal Data about you in an easily accessible format and the right to transmit that Personal Data to another controller. |
Objection to Processing | You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason. |
Please note that if the exercise of these rights limits our ability to process Personal Data, we may not be able to provide our products or services to you, or otherwise engage with you going forward.
Right to Withdraw Consent
Where we rely on your consent for processing of your Personal Data, as identified in the “Legal Bases for Processing ” section above, you also have the right to withdraw your consent to such processing. You may withdraw your consent at any time by contacting us using the contact details in the “Contact Us” section of our Privacy Notice above.
Submitting Requests
To submit a request, please contact us as set forth in the “Contact Us” section of our Privacy Notice above. We may need to verify your identity before processing your request, which may require us to obtain additional Personal Data from you. In certain circumstances, we may decline a request to exercise the rights described above.
Right to Lodge a Complaint
If you have any complaints regarding our privacy practices, you have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority). If you are based in the EEA, Switzerland or UK, information about how to contact your local data protection authority is available here . However, we encourage you to first reach out to us by using the contact details set out in the “Contact Us” section above so that you have an opportunity to address your concerns directly and so that we may find a solution together before you do lodge a complaint.
ADDITIONAL CALIFORNIA-SPECIFIC PRIVACY DISCLOSURES
Last Updated 10-26-2020
These additional California-specific privacy disclosures (“CA Disclosures”) supplement the information contained in our above Privacy Notice by providing additional information about how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). Unless otherwise expressly stated, all terms defined in our Privacy Notice above retain the same meaning in these CA Disclosures and all other terms defined in the CCPA and not otherwise defined in these CA Disclosures have the same meaning when used in these CA Disclosures.
Collection, Disclosure, and Sale of Personal Information
In the last 12 months, we have not sold personal information about you, but we have collected and disclosed for a business purpose the following categories and examples of specific pieces of personal information, which reference the personal information described in the “Our Collection of Personal Information” and the “Our Use of Personal Information” sections above:
Category of Personal Information | Collected | Disclosedfor BusinessPurpose | Sold |
Identifiers, such as including first and last name, email address, and phone number. | No
Personal Information Sold |
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California Customer Records (Cal. Civ. Code § 1798.80(e)): including your contact information. | |||
Internet/Network Information, such as log data, analytics data, and application data. | |||
Geolocation Data, including your general geographic location or more precise location when permitted by law. | |||
Sensory Information, including recordings of phone calls between you and us, where permitted by law. | |||
Other Personal Information, including communication preferences, customer service and communication history, personal information you permit us to see when interacting with us through social media, and personal information you provide us in relation to a question, request, inquiry, survey, contest or promotion. | |||
Inferences, including our predictions about your interests and preferences and related service profile information. |
Sources of Personal Information
As described in the “Our Collection of Personal Information” section of this Privacy Notice above, we collect personal information directly from you when you provide it to us, automatically when you visit our websites and other online services, and from service providers and other third parties.
Purposes for Collecting Personal Information
We collect personal information about you for the purposes described in the “Our Use of Personal Information” section above.
Recipients of Personal Information
As described in the “Our Disclosure of Personal Information” section above, we share personal information within the Company and with a variety of third parties.
Your Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
Right to Know | The right to request any or all of the following personal information we have collected and disclosed about you in the last 12 months:
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Right to Deletion | The right to request the deletion of personal information we have collected from you, subject to certain exceptions. |
Right to Opt Out | The right to direct us not to sell personal information we have collected about you to third parties. |
Right to Non-Discrimination | The right to be free from discrimination for exercising any of the rights described above.
The right to non-discrimination does not prohibit us from offering you certain financial incentives that may result in different prices, rates or quality levels of products or services. In addition, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may not be able to provide our products and services to individuals who exercise these rights, or to otherwise engage with such individuals going forward. |
Submitting Requests
To Exercise Your Right to Know or Right to Deletion:
To submit a request to exercise your right to know or right to deletion, please submit a request by emailing us at [insert email] or by [insert alternative submission method (e.g., webform or toll-free phone number)].
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, or date of last interaction with customer service.
In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.
Authorized Agents:
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit a right to know and/or right to deletion request on your behalf through the designated methods set forth in these CA Disclosures where we can verify the authorized agent’s authority to act on your behalf by:
- receiving a power of attorney valid under the laws of California from you or your authorized agent; or
- receiving sufficient evidence to show that you have:
- provided the authorized agent signed permission to act on your behalf;
- verified your own identity directly with us pursuant to the instructions set forth in these CA Disclosures; and
- directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
ANNEX – COOKIES
Company | Name | Type of cookie | Used On | Purposes / Additional description | How to change preferences |
Google Analytics | utma | Analytics cookie | [https://unsproject.com] | [This is one of the four main Cookies set by the Google Analytics services which enables website owners to understand visitor behavior and measure the website performance. This Cookie distinguishes between users and sessions. It is used to calculate new and returning visitor statistics. The Cookie is updated every time data is sent to Cookie Analytics. The lifespan of the Cookie can be customized by website owners. Currently configured for [six months].
Please also see Google’s Policy: https://policies.google.com/technologies/cookies?hl=en] |
You may review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/ |