Privacy Policy

This Privacy Policy describes policies and procedures of All Risks (“All Risks”, “We”, “Our”, or “Us”) on the collection, use and disclosure of information from visitors or any other individual or entity (“User”, “You”, or “Your”) when You use Our Sites and Services and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide Insurance Services to You and Your Representatives.  By using Our Sites and Services, You agree to the collection and use of information in accordance with this Privacy Policy.

If You have any questions or comments about this Privacy Policy, please submit a request to

Last Updated: 06/26/2020

Interpretation and Definitions


The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.


For the purposes of this Privacy Policy:

  • You means the individual visiting, accessing or using our Sites and Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Sites and Sites and Services, as applicable.Under the (General Data Protection Regulation (GDPR) and the California Consumer Privacy Act of 2018 (CCPA), You can be referred to as the Data Subject or as the User as you are the individual using the Sites and Services.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to All Risks and its Affiliated companies, 10150 York Rd, Hunt Valley, MD 21030.
    For the purpose of the GDPR and the CCPA, the Company is the Data Controller.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Account means a unique account created for You to access Our Sites and Services or parts of Our Sites and Services.
  • Website refers to All Risks, accessible from 
  • Sites and Services refers to the Website and any Portals We utilize.
  • Country refers to: Maryland, United States.
  • Sites and Services Provider means any natural or legal person who processes the data on behalf of the Company.  It refers to third-party companies or individuals employed by the Company to facilitate the Sites and Services, to provide the Sites and Services on behalf of the Company, to perform Services related to the Business or to assist the Company in analyzing how the Sites and Services is used.
    For the purpose of the GDPR and CCPA, Sites and Services Providers are considered Data Processors.
  • Third-party Social Media Sites and Services refers to any website or any social network website through which a User can log in or create an account to use the Sites and Services.
  • Facebook Fan Page is a public profile named allrisks specifically created by the Company on the Facebook social network, accessible from 
  • Personal Data is any information that relates to an identified or identifiable individual.
    For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
    For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Device means any device that can access the Sites and Services such as a computer, a cellphone or a digital tablet.
  • Usage Data refers to data collected automatically, either generated by the use of the Sites and Services or from the Sites and Services infrastructure itself (for example, the duration of a page visit).
  • Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • Business, for the purpose of the CCPA, refers to the Company as the legal entity that collects Consumers’ Personal Data and determines the purposes and means of the processing of Consumers’ Personal Data, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
  • Consumer, for the purpose of the CCPA, means a natural person who is a California resident.  A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
  • Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Data to another business or a third party for monetary or other valuable consideration.

Website Terms

By accessing or using the Sites in any manner, You also agree to be bound by Company’s Terms of Use (the “Agreement”).  Please read the Agreement carefully.  If You do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Sites and Services, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You.  Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Usage Data
Usage Data

Usage Data is collected automatically when using the Sites and Services.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Sites and Services that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Sites and Services by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Sites and Services or when You access the Sites and Services by or through a mobile device.

Information from Third-Party Social Media Sites and Services

The Company allows You to create an account and log in to use the Sites and Services through the following Third-party Social Media Sites and Services:

If You decide to register through or otherwise grant us access to a Third-Party Social Media Sites and Services, We may collect Personal data that is already associated with Your Third-Party Social Media account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Sites account.  If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Sites and Services and store certain information.  Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Sites and Services.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.  However, if You do not accept Cookies, You may not be able to use some parts of our Sites and Services.

Cookies can be “Persistent” or “Session” Cookies.  Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.  Learn more about cookies:

We use both session and persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies
    Type: Session Cookies
    Administered by: Us
    Purpose: These Cookies are essential to provide You with Services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts.  Without these Cookies, the Sites and Services that You have asked for cannot be provided, and We only use these Cookies to provide You with those Services.
  • Cookies Policy / Notice Acceptance Cookies
    Type: Persistent Cookies
    Administered by: Us
    Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies
    Type: Persistent Cookies
    Administered by: Us
    Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference.  The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
  • Tracking and Performance Cookies
    Type: Persistent Cookies
    Administered by: Third-Parties
    Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify You as an individual visitor.  This is because the information collected is typically linked to a pseudonymous identifier associated with the device You use to access the Website.  We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how Our users react to them.

For more information about the cookies We use and Your choices regarding cookies, please visit Our Cookies Policy or the Cookies section of our Privacy Policy.

Information Collected Related to California Residents

During the last twelve (12) months, We have collected the following categories of personal information from consumers.

Category Type of Identifiers We Collect Collected
A. Identifiers First and last name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, physical characteristics or description, address, telephone number, education, employment, employment history and disciplinary action, professional memberships, employee reference checks, trade union membership, credit card number, debit card number, or any other financial information, medical information YES
C. Protected classification characteristics under California or federal law Age, nationality, racial or ethnic origin marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation YES
D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies YES
E. Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application logs, device data and registration, social media account information or advertisement YES
F. Biometric information Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, heart rate, height, weight , gait, or other physical patterns, and sleep, health, or exercise data NO
G. Geolocation Data Physical location or movements NO
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information NO
I. Professional or employment-related information Current or past job history or performance evaluations; disciplinary action, professional memberships, employee reference checks, and trade union membership YES
J. Inferences drawn from other personal information Profile reflecting a person’s preferences, behavior, and attitudes YES

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from Our customers or their agents.
  • Indirectly from Our customers or their agents.  For example, through information We collect from Our clients in the course of providing Services to them.
  • Directly and indirectly from activity on Our website (  For example, from website usage details that are collected automatically.  In addition, like many companies, We use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages You visit.
  • From social media websites, such as Facebook, Twitter, LinkedIn, YouTube, Instagram, and Pinterest.
  • From third parties that assist Us in providing certain transactions and services, even though it appears that You may not have left our Site.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain Our Sites and Services, including to monitor the usage of Our Sites and Services.
  • To manage Your Account: to manage Your registration as a user of the Sites.  The Personal Data You provide can give You access to different functionalities of the Sites and Services that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or Sites and Services You have purchased or of any other contract with Us through the Sites and Services.
  • To contact You: to contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted Sites and Services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, Sites and Services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: to attend and manage Your requests to Us.

Sharing Your Personal Data

All Risks may disclose Your Personal Data to commercial providers for a business purpose, which include verifying Your identity when making a payment.  When We disclose Personal Data for these reasons, We enter into a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except for the purposes set forth in the contract.

In the preceding twelve (12) months, We have disclosed the following categories of Personal Data for one or more business purposes:

  • Identifiers;
  • California Customer Records Personal Information categories;
  • Protected classification characteristics under California or federal law;
  • Commercial information;
  • Internet or other network activity information;

Professional or employment-related information.  We may share Your personal information in the following situations:

  • With Sites and Services Providers: We may share Your personal information with Sites and Service Providers to monitor and analyze the use of Our Sites and Services, to contact You.
  • For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy.  Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With Business partners: We may share Your information with Our business partners to offer You certain products, Sites and Services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.  If You interact with other users or register through a Third-Party Social Media Sites and Services, Your contacts on the Third-Party Social Media Sites and Services may see Your name, profile, pictures and description of Your activity.  Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

We may disclose Your Personal Data for legal reasons.  Specifically, We will share Personal Data with companies, organizations or individuals outside of All Risks if We have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

  • Fulfill any purpose for which You provide it;
  • Meet any applicable law, regulation, legal process or enforceable governmental request;
  • Enforce applicable Terms of Use, including investigation of potential violations;
  • Detect, prevent, or otherwise address fraud, security or technical issues;
  • Protect against harm to the rights, property, assets or safety of All Risks, Our Users or the public, content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law;
  • Facilitate a business transfer, such as to a buyer or other successor in the event of merger, acquisition, consolidation, divestiture, change in control, dissolution or other sale or transfer of some or all of All Risks’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by All Risks about its Users will be among the assets to be transferred, and any such successor may use Your information for the same purposes set forth in the Privacy Policy.
  • For any other purpose disclosed when You provide the information; and,
  • When we obtain Your consent to do so.

We attempt to notify You about legal demands for Your Personal Data when appropriate in Our judgment, unless prohibited by law or court order or when the request is an emergency.  We may dispute such demands when We believe, in Our discretion, that the requests are overbroad, vague or lack proper authority, but We do not promise to challenge every demand.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.  We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes.  Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Sites and Services, or We are legally obligated to retain this data for longer time periods.

After expiry of the applicable retention periods, Your Personal Data will be deleted.  If there is any data that We are unable, for technical reasons, to delete entirely from Our systems, We will put in place appropriate measures to prevent any further use of such data.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located.  It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.  We have put in place commercially reasonable technical and organizational procedures to safeguard the information and Personal Data We collect on the Site.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.  While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Site and Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.


We may use third-party Sites and Service providers to monitor and analyze the use of Our Sites and Services.

  • Google Analytics

Google Analytics is a web analytics Service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Our Sites and Services. This data is shared with other Google Services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made Your activity on the Sites and Services available to Google Analytics by installing the Google Analytics opt-out browser add-on.  The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You.  You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a User to submit or receive information, as the case may be.

We currently provide the following opt-out opportunities:

  1. At any time, You can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from Us to unsubscribe from the service.
  2. At any time, You can contact Us through or the address or telephone number provided below to unsubscribe from the service and opt-out of Our right per Your consent under the terms of this Privacy Policy to share Your Personal Data.

Notwithstanding anything else in this Privacy Policy, please note that We always reserve the right to contact You in the event of a change in this Privacy Policy, or to provide You with any service related notices.

  • Your Ad Choices
    As described above, We or third party partners may place or recognize a unique cookie on Your browser when You visit our Sites for the purpose of serving You targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”).  You may find more information about entities involved in online advertising and additional choices You may make, including opt-out of having Your information used for internet-based advertising, through the Network Advertising Initiative (“NAI”) at the NAI Service, and the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice service.  All Risks is a participant in the online industry’s self-regulatory program administered by the DAA and has agreed to adhere to the DAA’s principles applicable to interest-based ads.
    The tools provided at the DAA opt-out page and the NAI opt-out page are provided by third parties, not All Risks.  All Risks does not control or operate these tools or the choices that advertisers and others provide through these tools.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request to be informed.  You are entitled to be informed of the use of Your Personal Information.  This Privacy Policy provides such information to You.
  • Request access to Your Personal Data.  The right to access, update or delete the information We have on You.  Whenever made possible, You can access, update or request deletion of Your Personal Data directly within Your account settings section.  If You are unable to perform these actions Yourself, please contact Us to assist You.  This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You.  You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data.  This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to Oour processing of Your Personal Data on this ground.  You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data.  You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data.  We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format.  Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent.  You have the right to withdraw Your consent on using Your Personal Data.  If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Sites and Services.
  • Refuse to be subjected to automated decision making, including profiling.  You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on You.
  • Lodge a complaint with a supervisory authority.  You have the right to lodge complaints about Our data processing activities by filing a complaint with Us or with the relevant Supervisory Authority.  A list of Supervisory Authorities is available here:

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us at  Please note that We may ask You to verify Your identity before responding to such requests.  If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data.  For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA Privacy

Your Rights under the CCPA

Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information.  This section describes Californians’ rights and explains how California residents can exercise those rights.

Below We further outline specific rights which California residents may have under the California Consumer Privacy Act.

  • The right to notice.  You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to access Personal Data.  The CCPA permits You to request and obtain from the Company information regarding the use and disclosure of Your Personal Data that has been collected in the past 12 months by the Company.  Any disclosures We provide will only cover the 12-month period preceding the receipt of Your request.  The response We provide will also explain the reasons We cannot comply with a request, if applicable.
  • The right to data portability.  You have the right to a “portable” copy of Your Personal Information that You have submitted to Us.  Generally, this means You have a right to request that We move, copy or transmit Your Personal Information stored on Our servers or information technology environment to another service provider’s servers or information technology environment.
  • The right to say no to the sale of Personal Data.  You also have the right to ask the Company not to sell Your Personal Data to third parties.  You can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.
  • The right to know about Your Personal Data.  You have the right to request and obtain from the Company information regarding the disclosure of the following:
    • The categories of Personal Data collected
    • The sources from which the Personal Data was collected
    • The business or commercial purpose for collecting or selling the Personal Data
    • Categories of third parties with whom We share Personal Data
    • The specific pieces of Personal Data We collected about You
  • The right to delete Personal Data.  You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
  • The right not to be discriminated against.  You have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:
    • Denying goods or Sites and Services to You
    • Charging different prices or rates for goods or Sites and Services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or Sites and Services to You
    • Suggesting that You will receive a different price or rate for goods or Sites and Services or a different level or quality of goods or Sites and Services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can:

  1. Submit a request via email to, or
  2. Call 800-366-5810 to submit your request

You may also designate an agent to exercise Your privacy rights on Your behalf.  In order to designate an authorized agent to make a request on Your behalf, You must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.

Upon receiving Your request, We will confirm receipt of Your request by sending You an email/confirming receipt.  To help protect Your privacy and maintain security, We may take steps to verify Your identity before granting You access to the information.  In some instances, such as a request to delete personal information, We may first separately confirm that You would like for Us to in fact delete Your personal information before acting on Your request.  In some cases Our ability to uphold these rights for You may depend upon Our obligations to process Personal Data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services You have requested.  Where this is the case, We will inform You of specific details in response to Your request.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request.  If We require more time, We will inform You of the reason.  The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.  We will deliver Our written response by mail or electronically, at Your option.

We may deny Your deletion request if retaining the information is necessary for Us or Our service providers to:

  1. Complete the transaction for which We collected the Personal Information, provide a good or service that You requested, take actions reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform Our contract with You;
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  3. Debug products to identify and repair errors that impair existing intended functionality;
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent;
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us;
  8. Comply with a legal obligation; or
  9. Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

Do Not Sell My Personal Information

We have not sold Personal Data in the preceding twelve (12) months.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

  • “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
  • “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Sites and Services.  As operator of the Facebook Fan Page, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things.  These terms are mostly based on the Facebook Terms of Sites and Services:

Visit the Facebook Privacy Policy for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page.  Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook Sites, Sites that are provided by other members of the Facebook Fan Page and Sites by other companies that use Facebook Sites.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here:

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Sites and Services do not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities.  If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked.  You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California’s Shine the Light Law)

Under California Civil Code Section 1798 (California’s Shine the Light Law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If You’d like to request more information under the California Shine the Light Law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 16 who are registered users of online Sites, Services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Sites and Services may contain links to other websites that are not operated by Us.  If You click on a third party link, You will be directed to that third party’s site.  We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time.  We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Sites and Services, prior to the change becoming effective and update the “Last Updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.  Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy Policy, You can contact Us: