This privacy statement was last updated on 08 February, 2010. REFOG, Inc. and its affiliates (collectively, “REFOG”) has created this privacy statement in order to disclose its information gathering and dissemination practices for this internet Website, www.refog.com (the “Website”).
Upon reading this privacy statement, you will be informed regarding the following:
(1) what personally identifiable information of yours or third party personally identifiable information is collected from you through the Website;
(2) the organization collecting the information;
(3) how the information is used;
(4) with whom the information may be shared;
(5) what choices are available to you regarding collection, use and distribution of the information;
(6) the kind of security procedures that are in place to protect the loss, misuse or alteration of information under REFOG’s control; and
(7) how you can access and correct any inaccuracies in the information collected about you.
Questions regarding this statement should be directed to email@example.com
If you have any concerns or feel that there are certain problems or issues relating to compliance with the policies outlined in this privacy statement, please submit a report to: http://support.refog.com/hc/en-us
Word from REFOG
Third Party Websites
REFOG does not control the information collection and distribution policies on Internet domains other than those Internet domains that are under the control of REFOG itself. When you are on the REFOG Website, you may be directed to other sites that are beyond our control. These other sites may independently collect data, solicit personal information, or send their own “cookies” to you. REFOG is not responsible for any use of the information including click-stream data created when using such third party sites.
The REFOG Website may also contain advertising and other links to other web sites. Please be aware that we are not responsible for the privacy practices or content of those other sites. Also we do not send random marketing emails to personal email addresses (spam). The REFOG Website may contain hyper links to external web sites owned and operated by third parties. REFOG has no control over or association with such third party sites and REFOG is not responsible for the accuracy, completeness and quality of the information contained within them. Any and all contents on these external web sites do not reflect products, services or information provided by REFOG. You should direct any concerns regarding any external link to the site administrator or webmaster of such site. REFOG will inform you before you will be redirected to such third party sites and that REFOG will notify when you leave its Website and/or provide indication that you are directed to such other third party websites.
This Website may be subject to the laws of various jurisdictions, including the laws of the United States of America, European and other jurisdiction because the access to our Website may use internet traffic of different jurisdictions, including without limitation the United States of America and EU. REFOG will disclose personally identifiable information without your permission when required by law, or in good faith belief that such action is necessary to investigate or protect against harmful activities to REFOG guests, visitors, associates, or property (including this Website), or to others. As mentioned above, laws related to personal identifiable information vary by country. For example, personally identifiable information collected in the European Union and its Member States is subject to the EU Directives concerning personal data, privacy and electronic communications, including but not limited to Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector and Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the subsequent legislation adopted in the EU Member States.
REFOG may be required by law enforcement or judicial authorities to provide personally identifiable information to appropriate governmental authorities. If requested by law enforcement or judicial authorities, we will provide this information upon receipt of the appropriate documentation. REFOG may also provide information to law enforcement to protect its property and the health and safety of individuals as permitted by statute.
B. COLLECTED INFORMATION
Information We Collect
As a visitor to this Website, you can engage in many activities without providing any personal information as described above in Section Browsing above. In connection with other activities, such as utilizing online software applications or purchasing or downloading any of the products and services available on the Website, REFOG may ask you to voluntarily supply us with certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities and/or make any purchases. If you elect to engage in these activities or make purchases, however, REFOG may ask that you provide us personal information, defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains, including but not limited to your first and last name, mailing address (including ZIP code), e-mail address, employer, and other personal information. This information may be requested in conjunction with the purchase and registration of our Products or services. In addition, if you choose and upon your modifications of the Product’s settings your personal information may be transmitted via email to the address provided by you. As noted below, minimum information is requested if you choose to subscribe to product updates.
REFOG may collect personal information as described above of registered users, service subscribers, and all posted advertisements information. All advertisements will be archived and stored on our servers. You may deactivate your personal information by contacting at: firstname.lastname@example.org. When and if you deactivate your personal information, all information stored and maintained as part of your personal information will be deleted from our servers, provided that the information may be retained by REFOG for archival, backup and record purposes. The security of this information is addressed in the section Security below.
You never have to answer any questions, and you can decline this exchange of information at any time. However, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity or purchase, you will not be able to engage in that activity or make such a purchase. REFOG will inform on the mandatory and/or optional character of the requested and/or required information.
REFOG will only share your information with outside parties in ways that are described in this privacy statement or if we are required to do so by law or in the good-faith belief that such action is necessary in order to conform to the edicts of the law, cooperate with law enforcement agencies, or comply with a legal process served on our Website and the subsequent legislation adopted in the United States or EU Member States.
When you use the Website, REFOG or third parties authorized by REFOG may also collect certain technical and routing information about your computer to facilitate your use of the Website and its services. When you surf the Internet, your Internet browser (such as Mozilla Firefox or Microsoft Internet Explorer) automatically transmits some information to REFOG every time you access content on one of our internet domains within the Website. Examples of such information include the URL of the Web page you were just on (known as the “Refer”), the IP (or Internet Protocol) address of the computer you are using, or the browser version you are using to access our site. All of this information may be collected by REFOG and used to help improve our offerings to you.
We use such data to facilitate and track your use of the Website and its services. REFOG also uses such environmental variables to measure traffic patterns on the Website. Without expressly informing you in each particular circumstance, we do not match such information with any of your personal information.
When you submit personal information to REFOG through this Website, you understand and agree that this information may be transferred across national boundaries and may be stored and processed in any of the countries in which REFOG and its affiliates and subsidiaries maintain offices. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage, and processing of your information may be undertaken by trusted vendors of REFOG. Such vendors are bound by contract not to use your personal information for their own purposes or provide it to any third parties.
Updating Your Personal Preferences
You may have access and correct your personal information and privacy preferences by writing REFOG at email@example.com.
As a registered user you have the right to access and change your personal information and privacy preferences at any time by logging into your personal account, where you can view and make changes to your personal information. You may also access and change your personal information and privacy preferences by contacting us at: firstname.lastname@example.org.
Information Relating to Children
The Children’s Online Privacy Protection Act (COPPA) was passed by the U.S. Congress in November 1998. COPPA provides parents with specific rights regarding their children's privacy. For additional information and resources on COPPA, please visit the Federal Trade Commission Web site at http://www.ftc.gov/. The REFOG Website and any products or services available on that site are not directed at children under 13 years of age and, therefore, COPPA does not apply. However, we recognize that children under the age of 13 may access this Website and subscribe to the newsletter, purchase products and services, or download software programs. The collection of information is covered above. Parents and Legal Guardians may request from us to review, delete or stop the collection of the personally identifiable information of their child. You may do so by contacting us by letter (using the address information provided at the bottom of this page).
Securing the Transmission and Storage of Information
C. USE AND DISCLOSURE OF INFORMATION
How your personal information is used
REFOG collects your information in order to record and support your participation in the activities you select. We will use your e-mail address to send a confirmation and, if necessary, might use the other information to contact you for help to process the purchase or service you have selected. If you subscribe to a service or register a product, for example, the information is used to register your rights, if any, to technical support or other benefits that may be made available to registered users. Your personal information is also used to keep you informed about new products, product upgrades, patches, special offers, and other products and services of REFOG and selected third parties if you have so opted to receive such communications.
REFOG may collect information about the use of the Website, such as the types of services used and how many users we receive daily. This information is collected in aggregate form, without identifying any user individually. REFOG may use this aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes.
However, you should be aware that some of your contact information in advertisements and postings may be visible for all other visitors, and we cannot guarantee that someone will not use it for commercial or other purposes or activities.
Disclosure of Information to Third Parties
REFOG may use the services of third parties, such as e-mail service providers, purchase, shipping and order processing merchants and marketing companies that act as independent contractors on behalf of REFOG. These parties are contractually prohibited from using personally identifiable information for any purpose other than for the purpose REFOG specifies. We do provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We prohibit the sale or transfer of personal information to entities outside of the REFOG’s affiliates for their use without your approval.
In the event that all or substantially all of REFOG’s stock and/or all or substantially all assets are transferred or sold to another entity, REFOG may transfer personally identifiable information to the acquiring entity. If, as a result of such a business transition, your personally identifiable information will be used in a materially different manner, you will be given choice consistent with our policy regarding notification of changes.
Choices available to you
You can always choose whether or not to disclose personally identifiable information and that choice will not prevent you from using the REFOG Website. Please note, however, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information and you will be given an opportunity to “opt-in” and make your preference choices for any items that are optional and which are not prerequisite for our rendering such services.
You can choose at anytime to opt out of receiving emails from REFOG or from having your personally identifiable information shared with selected companies. If you want to opt out, you can do so by editing your preferences with respect to email or the sharing of information. If you elect to “opt out” we will not, as applicable, share your personal information with third parties or send you emails. However, we may continue to use your personal information for internal purposes, to enhance your user experience or as necessary to administer the site or comply with applicable law.
We reserve the right to send a one-time registration confirmation email, and infrequent Service Alert messages to users to inform them of specific changes that may impact their ability to use a service they have previously signed up for, regardless of email contact opt-in status. We also reserve the right to contact you if compelled to do so as part of a legal proceeding or if there has been a violation of any applicable licensing, warranty and purchase agreements.
REFOG is retaining these rights because in limited cases we feel that we may need the right to contact you as a matter of law or regarding matters that will be important to you. These rights do not allow us to contact you to market a new or existing service if you have asked us not to do so, and issuance of these types of communications is rare.
When you create a personal account with REFOG and/or provide your e-mail address and other personal identification information, based on your personal preferences, we may periodically contact you via e-mail and provide information about special offers and promotions that may be of interest to you. These communications will relate to REFOG offers and/or the promotions of select, reputable third parties with whom REFOG has a strategic marketing relationship because they offer products or services that we believe would be of interest to you. We may use a third party e-mail service provider to send e-mails. This service provider is prohibited from using your e-mail address for any purpose other than to send REFOG related e-mail. If you do not wish to receive e-mails with updates and information please unsubscribe by sending email to: email@example.com. In addition, every time you receive an e-mail you will be provided the choice to opt-out of future e-mails by following the instructions provided in the e-mail. You may also opt-out online by updating your personal account as described in Updating Your Personal References Section above.
To ensure that your request is honored, you must provide REFOG with information sufficient for us to accurately identify and access your records. The information we require is your full name, address and the email address you provided to REFOG when you requested services or products. REFOG reserves the right to contact you to verify that we have accurately identified your record.
Our Website uses “cookie” technology. “Cookies” are short pieces of data generated by a web server that a website stores on a user’s computer. Certain pages on our Website may require the use of a cookie for purposes of keeping information you enter on multiple pages together. Cookies also enable us to customize our Website and offerings to your needs and provide you with a better online experience with us. In addition, cookies are used to:
measure usage of various pages on our Website to help us make our information; more pertinent to your needs and easy for you to access; identify and categorized the internet webpages from which the visitor came to the Website and observe the browsing patterns; and provide functionality such as online orders, REFOG’s services and other functionality that we believe would be of interest and value to you.
In addition, the service providers we use to serve and host our advertisements, and/or deliver our e-mails, use session and persistent cookies, to track the number of times the Website is accessed and whether the site was accessed from an advertisement. There are no cookies in the advertisement or e-mail. A cookie is placed on your computer only if and when you click on an advertisement or open the e-mail. The cookie generated from the advertisement or e-mail does not contain any personally identifiable information and will remain on your hard drive until you delete it.
You may set your browser to block cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use certain functionality and access certain content on our Website.
D. PRIVACY-RELATED INQUIRIES AND COMPLAINTS
Please note that if you provide REFOG with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), REFOG cannot guarantee that your most recent privacy preference will be honored.
Please note that REFOG does not collect any credit card information unless and until you provide such information in connection with your payment for REFOG’s paid services. REFOG will never contact you to ask you for your credit card data or other personal information via e-mail, phone etc.
Copyright © 2010 REFOG, Inc. All rights reserved.