Last Updated June 2020
Acceptance of Terms
The Information We Collect
In the course of operating the Websites and/or interacting with you, we will collect (and/or receive) the following types of information.
1. Personal Information.
When you sign up to receive any of our newsletters, download a freebie, respond to a survey, register for a class, or purchase any product or service, you may be required to provide us with personal information about yourself, such as your name, address, email address, or phone number. We do not collect any personal information from Visitors when they use the Websites unless they provide such information voluntarily, such as by registering or sending us an email or signing up for a newsletter. All information we collect and/or receive under this section is collectively called “Personal Information.”
2. Order Information.
When you place an Order, you must provide us with certain information about the products and services you are seeking to purchase. Such information is collectively called the “Order Information.”
3. Billing Information.
4. Other Information.
In addition to the information noted above, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:
a. From You. Additional information about yourself that you voluntarily provide to us (e.g., via a survey), such as household income range, gender, product and service preferences, and other information that does not identify you personally.
b. From Your Activity. Information that we automatically collect when you use the Websites, including, without limitation:
- IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Websites you visit; and similar data; and
- Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data.
c. From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Websites. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Websites may not function properly.
The Website may engage in affiliate marketing, which is done by embedding tracking links into the Website. If you click on a link for an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commissions.
Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies.
For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Websites.
e. From Other Sources. We also may collect or receive information from third parties, such as Facebook and/or other third-party social media sites.
Information Collected by or Through Third-Party Advertising Companies
Accessing and Modifying Personal Information and Communication Preferences
If you have registered for the Websites, you may access, review, and make changes to your Personal Information, Billing Information, and certain Other Information by following the instructions found on the Websites. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any PEN Group Online, Inc. marketing email. Customers cannot opt out of receiving transactional emails related to their account or their Orders. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.
How We Use and Share the Information
We use the Personal Information, the Order Information, the Billing Information, and the Other Information (collectively, the “Information”) to provide our services; to process Orders; to administer our rewards and promotional programs; to maintain and improve our Websites and services to you; to solicit your feedback; and to inform you about our products and services and those of our third-party marketing partners.
We may also use and/or share Information as described below.
- PEN Group Online, Inc. will access, use, and share the Information as required to process your Orders and provide support to you.
- With your permission, third-party applications or services may access your Personal Information. We use standard OAuth (open authorization) to enable you to give permission to share your Personal Information with other websites and services, such as Facebook and Twitter (e.g., when you agree to a pop-up requesting you to allow another application to access your account information). We also use OAuth to allow us to share information about you that is stored by us without sharing your security credentials.
- In an ongoing effort to better understand our Visitors, customers, and our products and services, we may analyze the Order Information and Other Information in aggregate form in order to operate, maintain, manage, and improve the Websites and/or our products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
- As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
- To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of PEN Group Online, Inc. or others.
Information You Share
Please keep in mind that whenever you voluntarily make your Personal Information available to third parties — for example on message boards or web logs; through email; during webinars, classes, telephone conferences, or coaching calls; or in comment or chat areas — that information can be seen, collected, heard, and/or used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.
How We Protect the Information
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Websites may not be secure, and you should therefore take special care in deciding what information you send to us via email.
Important Notice to Non-U.S. Residents
PEN Group Online, Inc. does not monitor, recognize, or honor any behavioral advertising opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
Mediavine Programmatic Advertising
The Website uses Mediavine to manage all third-party advertising on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website. The cookie may collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from a third-party site, the URL of the linking page.
First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at www.allaboutcookies.org/manage-cookies/.
Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site.
The Website may collect IP addresses and location information to serve personalized ads and pass it to Mediavine. If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit http://www.networkadvertising.org/managing/opt_out.asp. You may also visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/# to learn more information about interest-based advertising. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
Mediavine partners with the following data processors:
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