Your Privacy is Serious Business to Us!
Maintaining the privacy of our website visitors and mobile application users is very important to us. Because we gather information about you, you need to know:
- The kinds of information we collect and why we collect it;
- How we use that information; and
- How you can update that information or limit or control how it is used.
PICT is the data controller of your personal data for the purposes of the General Data Protection Regulation.
- The Kinds of Information We Collect.
1.1 We collect information to provide better services to all of users of our Service, including determining what types of editorial content and what services offered on our Service are of the most interest and relevance to you.
1.2 We collect information about you (“your personal information”) from the following two sources:
- The information you give us (“PICT Profile Information”). Many of our services require that you create an account. When you do, we’ll ask for personal information, like your name, email address and telephone number. You may also provide us with personal information when you participate in discussion boards or other social media functions on our Website, enter a competition, promotion or survey, sign up to a newsletter and when you report a problem with the Website. Where we indicate that the information is mandatory, it is required to enable us to fulfil a contract with you and, if you do not provide the mandatory information, we will not be able to provide you with the applicable service.
- The information we collect from your use of our Service (“PICT Use Information”). This information relates generally to what editorial and advertising content you view, and the services you use that we and our third-party providers offer. We collect the following PICT Use Information:
- Device Information. We collect information about the devices you use to access our Service, such as hardware settings, browser type and version, browser language, browser plug-in types and versions, operating system and platform, time zone setting and the date and time of Service requests.
- Log Information. When you use our Service, we automatically collect and store certain information in server logs, which automatically record certain information when you use our Service, including the following:
- details about how you use our Service, such as your search queries, the full referral Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the Website;
- your Internet Protocol (IP) address, which is the number assigned to an Internet connected device such as a tablet or smartphone and used to identify the geographic location of that device; and
- cookies that uniquely identify your browser and collect information about how our visitors interact with our Service, as well as help us identify problems such as error messages from certain pages. A cookie is a small file containing a string of characters that is sent to your computer or other device when you visit our Service. When you visit our Service any time thereafter, the cookie allows our Service to recognize your browser and to store information about your user preferences and other personal information.
- Location information. When you visit our Service, we collect and process information about your actual location. We use various technologies to determine location, including IP address.
- Local storage. We collect and store information (including personal information) locally on your device, using mechanisms such as browser web storage (including HTML 5), which allows for data to be stored on a browser even after the browser has been closed and the reopened, and application data caches, which allow for data to be stored on your device, enabling an application to run without an Internet connection and to load content faster.
- Collection and Storage technologies. We and our partners use various technologies to collect and store information when you access our Service, including by using cookies and tracking pixels, to identify your browser or device. We also use these technologies to collect and store information when you access our Service and interact with the content and services we offer, such as advertising services.
- How We Use Information We Collect.
2.1 We use the information we collect from your use of our Service in order to provide you with meaningful editorial and advertising content and to offer you relevant services, as well as to maintain, protect and improve your overall experience. In particular, you may choose
- to subscribe to any of our electronic newsletters,
- to receive “special offers” by PICT and its various service providers, and
- to receive franchise and business opportunity information from selected advertisers, and we will use your information for these purposes provided you have given us your consent. You may also choose to submit questions or comments in response to editorial content on our Service, in which case we will process your information to comply with your request.
In each of those instances we will ask you to provide, and we will collect and store, certain personal information such as email address, telephone number and, where necessary to comply with your request, information about your business. If we ask you for, and you give us, your consent, PICT and its various advertisers and other service providers will use that information to send you promotions and other communications concerning business opportunities, products or services. You can remove yourself from any such electronic newsletters and otherwise stop receiving any further promotions and other commercial communications by following the “unsubscribe” directions included with each newsletter or, in all of the above instances, by sending an email with the word “unsubscribe” in the subject line to email@example.com
2.2 We may use the name you provide for your PICT Profile across all of the services we offer that require an PICT Account, which is where we maintain the information you provide. In addition, we may replace past names associated with your PICT Account, so that you are represented consistently across all our services.
2.3 When you contact PICT, we retain a record of your communications to help solve any issues you are facing, or to maintain a record to assist with legal claims. We will keep these records for a period of no more than 6 years. Provided you have consented thereto, we may use your email address to inform you about the services offered on our Service, such as letting you know about upcoming changes or improvements.
2.5 We share your information with third parties in the circumstances set out in Sections and below.
2.6 We do not track our users across third-party websites and thus do not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, certain website browsers allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.
2.7 We comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union (“EU”) to the United States (“U.S.”).
- Why We Share Your Information with Third-Party Advertisers.
We share your information with third-party advertisers for the reasons explained below. (For each reason your information is shared, we have identified the Controller and/or Processor of that information. The “Controller” is the entity, which stores the information and has control over your ability to unsubscribe from having that information tracked. The “Processor” is the entity that processes your information, in order to fulfill the purpose(s) for which that information is shared.)
- To inform a prospective advertiser or its agency that you are visiting the Website, so that the Website can solicit bids for the opportunity to show an ad to you.
- To identify whether you are the kind of person that the advertiser may want to show ads to.
- To monitor your behaviour on websites, in order to determine if you have viewed or interacted with an ad.
- To record the number of times you have viewed each ad, to prevent a single ad being shown to you too frequently.
- Advertising on Our Service.
The advertising you see on our Service is determined by a number of factors relating to relevance, including (i) your approximate geographical location based on your IP address and (ii) the subject matter you view on our Service. For example, if you are viewing an article about physical health, you may see ads concerning exercise equipment. We detect the use of ad blockers and store that information, in order to help us understand your use of our Services; but we do not restrict you use of our Service if you use ad blockers.
- Privacy and Choice.
People have different concerns about privacy. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how that information is used. You may set your browser in its “options” or “preferences” feature, in order to warn you before accepting cookies or to disable all cookies entirely. However, it is important to understand that many of the services we provide on our Service and to our Service users may not function properly if your cookies are disabled.
- Minors and Children under Age 16.
PICT does not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register to use our Service. No one under age 16 is allowed to provide any personal information to PICT or on our Service. In the event that we learn that we have collected personal information from a child under age 16, we will promptly delete that information. If you believe that we might have any information from or about a child under age 16, please contact us at firstname.lastname@example.org.
- Where We Store the Information.
The personal data that we collect from you will be transferred to, and processed in, the United States and Kenya by PICT. We comply with the U.S. Department of Commerce’s EU-US Privacy Shield. For more information about the EU-US Privacy Shield Framework, please visit the U.S. Department of Commerce’s Privacy Shield website.
- The Information You Share.
Our Service allows visitors to share information with others, such as comments on editorial content and information shared via social media. When you share information, it may as a result become accessible to others through such mechanisms as search engines. We cannot be responsible for how others, with whom you may share information, may use that information.
- Updating Your Personal Information.
Where we can provide information access and correction, we will do so at no cost to you, except where it would require a disproportionate effort. We aim to maintain our Service in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our Service, there may be a delay before we delete residual copies from our active servers and remove information from our backup systems.
- The Information We Share.
10.2 We share your information with selected recipients. These categories of recipients include:
- provided you have consented, advertisers and advertising networks, including Google and Rubicon, located in the United States, that require the data to select and serve relevant ads to you and others;
- analytics and search engine providers including Google® services located in the United States that assist us in the improvement and optimization of the Website;
- provided you have consented, third parties to whom we make available for rental a list of those registrants who have expressly provided us with their permission to receive third party information and offers as part of their user profile; and
- IT services providers, including Salesforce, New Relic and Sailthru, all located within the United States and which provide us with SaaS services, etc.
10.3 We will also share personal information with companies, organizations or individuals outside of PICT when we have your consent to do so.
10.4 Other than the circumstances set out above, we will share personal information with companies, organizations or individuals outside of PICT if we have a good-faith belief that access, use, preservation or disclosure of that information is reasonably necessary to:
- comply with applicable law, regulations, legal process or enforceable governmental request;
- enforce any of our applicable Terms of Service, including any potential violations;
- detect, prevent, or otherwise address fraud, security or technical issues; or
- protect against harm to the rights, property or safety of users of our Service or service providers, as well as the general public and PICT as required or permitted by law.
10.5 We also may share personal information with a buyer or other successor, in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of PICT’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by PICT about our Service users is among the assets transferred.
10.6 We additionally share your information publicly and with our partners such as third-party content providers, advertisers or connected sites, but in a manner which does not reveal your personal data and which is aggregated with other user information to show usage of PICT and third-party products and services offered on our Service and trends based on such categories as age, gender, geographical origination and other demographic characteristics.
10.7 We may transfer and disclose information, including personal information, in response to lawful requests by public and governmental authorities and law enforcement agencies, including to meet national security or law enforcement requirements. In addition, we may disclose personal information to customers, vendors, service providers, public and governmental authorities and law enforcement agencies where required in order to comply with a legal obligation; when the law requires it, at the request of governmental authorities conducting an investigation; when we believe in good faith that disclosure is necessary to protect our rights; to investigate fraud; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of our users or others, in all cases only if and to the extent such transfer and disclosure is permitted by applicable law.
- The Protection of Your Information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to protect the information provided by, or collected about, the users of our Service, from unauthorized access, or alteration, disclosure or destruction. In particular:
- We encrypt much of that information using SSL.
- We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to our systems and the information collected and stored therein.
- We restrict access to personal information to those of our employees, contractors and agents, who need to know that information in order to process it for us, who are subject to the obligation of strict confidentiality as relates to that information, and who will be subject to discipline, including termination, if they violate that obligation.
- Retention Periods.
12.1 We will retain your information for a period of one year after your last use of our Service, after which time your information will be automatically deleted.
12.2 You can also request that your information be deleted by sending an email request to email@example.com, which must include your name and email address with which your Website account is associated.
- services offered by other companies or individuals on non-PICT websites or applications, including any such websites or applications which are referenced on or linked from our Service; and
- Your Rights.
In certain circumstances, you have the right to access and receive a copy of information we hold about you, to rectify any personal data held about you that is inaccurate and to request the deletion of personal data held about you. Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you. You also have the right to data portability for information you provide to us – this means that you can obtain a copy of your data in a commonly used electronic format, so that you can manage and move it. You may have the right to restrict or object to the processing of your personal data by us. You can exercise your rights by contacting us at firstname.lastname@example.org.
- Handling Complaints from Our Service Users and Regulatory Authorities.
- Contacting Us.