2. How personal information is controlled
4. How we collect information and what types of information we collect
5. How we use the information we collect and for what purposes
6. When and to whom information we collect may be disclosed
7. How we safeguard and protect Personal Information (defined at 3(i) below) that you provide
8. The choices that are available to you regarding our collection and use of Personal Information
9. How you contact us in relation to any issues that may arise.
1. Policy Scope
2. Controllers of Personal Information
Third Party Websites
For persons within the European Union the following provisions apply:
(a) In Europe, data is protected under the EU Data Protection Directive 95/46/EU, which has been transposed into the national law of the member states of the European Union. For more information see http://www.ico.gov.uk/for_organisations/data_protection.aspx
(c) In Europe, WorthPoint Ireland Ltd. Trinity Technology and Enterprise Campus, Unit 17, Pearse Street, Dublin 2, Ireland is the data processor for the purposes of the Data Protection Acts 1988 to 2003 and in compliance with EU Data Protection Directive 95/46/EU. For further information on data privacy go to www.dataprivacy.ie
(e) WorthPoint complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. WorthPoint has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit www.export.gov/safeharbor.
(f) In compliance with the Safe Harbor Principles, WorthPoint commits to resolve complaints about your privacy and our collection or use of your personal information. If you live within the EU and have any issues or concerns in relation to your personal information held by WorthPoint, you should first contact us at WorthPoint Ireland Ltd., Trinity Technology and Enterprise Campus, Unit 17, Pearse Street, Dublin 2, Ireland, or by telephone at +353 01 687 7430, or by email at email@example.com.
(g) WorthPoint has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by WorthPoint, you may contact the BBB EU SAFE HARBOR program at Council of Better Business Bureaus, Inc., BBB EU SAFE HARBOR, 4200 Wilson Boulevard, Suite 800, Arlington, VA 22203, or by telephone at 703-276-0100, or online at www.bbb.org/us/safe-harbor-complaints.
3. Updates and Changes
4. Collection of Information
(i) Personal Information Provided Voluntarily by the User. You may be asked to provide or otherwise voluntarily provide personal information when you participate in various services and offerings available through the WorthPoint Websites, when you contact us via phone, mail, or otherwise, and when you participate in our sweepstakes, contests, surveys and related promotions. The personal information we collect may include, but is not limited to, the following categories of information: name, mailing address, email address, telephone number, year of birth, hobbies, interests, and occupation, and financial information (for billing purposes) (“Personal Information”).
Though you may access and use portions of our Websites without providing any Personal Information, in order to take advantage of the full capabilities of our Websites and to obtain access to, and use of, many of the features of our Websites, you must provide certain Personal Information. For example, in order to register for a membership account through our Websites (each a “Membership Account”), to buy and to sell items on our Websites, to access prices in our Worthopedia price guide and to request information about products and services offered on our Websites you must provide certain Personal Information.
Certain functionalities available through our Websites may require you to provide information about third parties. This information may include a third party’s name, address, phone number, fax number, email address, and other similar information. If you provide Personal Information to us, including Personal Information regarding individuals other than yourself, you represent and warrant that
(b) you and the third party concerned have provided such Personal Information voluntarily, and
(ii) Information Collected from Other Sources. We may obtain information about you from other sources, such as companies that update and verify email and physical addresses, for the purpose of updating and enhancing our files.
We will use the information we automatically collected through your access and use of our Websites to determine how our Websites are accessed and used. For example, this information will allow us to:
(a) determine which pages are the most popular with users,
(b) determine if our Websites are working properly, and
(c) improve the user-experience on our Websites.
We do not use automatically collected information to identify a particular user.
We may aggregate and use certain non-personally identifiable information for research or marketing purposes and may share, sell and rent or trade that information and statistical data derived from such information with our marketing partners, advertisers, or other third parties for research or marketing purposes.
We use Membership Account registration information and other information users provide as they interact within the communities to: authenticate users; provide communications from us to users regarding the community; and administer the community (including, but not limited to, managing the technical requirements of the site and monitoring submissions and posts for offensive content after posting and removing such content in our sole discretion).
Please note that information (including your name, email address, address, or phone number) you provide in a posting on community or any bulletin board is available (even after you stop participating in the community) to any other individual who has access to that same community and may be used by another individual in a manner unintended by you, including as a target for unsolicited communications. You should therefore treat any information provided by you in the content of a submission or post to a community as public information. For this reason, we urge you to act cautiously in providing any such information in your submissions or posts, as we are not liable for any use or misuse by an individual user of the information you provide in a submission or post.
You can configure your browser to accept all Cookies, reject all Cookies, or notify you when a Cookie is received. (Each browser is different, so check the Help menu of your browser to learn how to change your Cookie preferences). You may reject, delete or otherwise disable Cookies at any time. However, by deleting, rejecting or otherwise disabling Cookies, you may inhibit your user experience on our Websites and you may not be able to take full advantage of all offerings on our Websites. For example, if you disable or reject cookies you will not be able to purchase products or services. In addition, if you disable or disallow Cookies, some multimedia images and graphics may not display properly, you may not be able to view customizable features, and/or you may have more difficulty navigating through our Websites.
Some of our email communications to you may include a “click-through URL” linked to a particular page on one of our Websites. By clicking on one of these URLs, you will automatically enter one of our Websites. Our systems track this information to gauge the effectiveness of our email communications and your level of interest in particular areas. You may avoid having this information collected by avoiding clicking on URL links in our email communications.
Please note, that we will NEVER send you an email with an imbedded link that asks for your password or any financial or account information; passwords are for your protection. If you EVER receive such an email, please contact us immediately using the information in the Section 9 below entitled “Contact Us”.
We use pixel tags to identify what pages of our Websites are visited most frequently and to evaluate the effectiveness of the search functions on our Websites.
(vi) Notice for Parents Our Websites are general audience sites that are not targeted for use by children. WorthPoint does not intend to collect Personal Information from individuals under the age of eighteen (18) on our through our Websites. If you are the parent or guardian of a child under the age of 18 who has provided Personal Information to us, please inform us as provided below in Section 9 (“Contact WorthPoint”) below, and we will delete that Personal Information.
5. Use of Personal Information
We use Personal Information that you provide to us for our business purposes, such as (i) to allow you to access your Membership Account, (ii) to confirm your identity, (iii) for marketing our products and services to you and to customize this advertising and marketing information (iv) to contact you regarding your Membership Account and to keep records regarding your Membership Account, (v) to carry-out promotions, including but not limited to sweepstakes, contests surveys and related promotions that you have entered; (vi) to provide the services and products you request and to respond to your other requests and inquiries, (vii) to enhance our service offerings; and (viii) to adjust our Websites to your personal preferences.
6. Disclosure of Personal Information
WorthPoint does not sell or rent your Personal Information to third parties for commercial or marketing purposes.
We may share Personal Information you provide to us with certain third parties that perform services on our behalf. Those third parties may host our Websites; provide certain features or functionality; print or send mailings or emails (including marketing materials); provide the services you requested; authorize and process your payments; provide customer service; analyze data; or otherwise assist us with the operation of our business. Those third parties are not authorized to use or disclose Personal Information for any purpose other than to perform the services designated by WorthPoint.
We may also provide the Personal Information you provide to us to governmental authorities or if we are required by law or litigation so to disclose such Personal Information. For example, we may be required to disclose Personal Information to respond to a subpoena, court order or other legal process.
Finally, the Personal Information you provide to us may be transferred as an asset in connection with a merger or sale involving all or part of WorthPoint or as part of a corporate reorganization, stock sale or other change of control. Except as specifically provided in this section, we will not sell or rent or otherwise share the Personal Information you provide to us with third parties.
7. Safeguarding Personal Information
We employ reasonable measures, including administrative, technical, and physical measures, to protect Personal Information from unauthorized access, loss, alteration, use or disclosure.
Our Websites are capable of using Secure Sockets layer 128-bit encryption and we will use at least such level of encryption in the transmission of Personal Information from our Websites to our servers. End-to-end (i.e., from your browser to our servers) Secure Socket layer 128-bit encryption may be available in some instances only if you provide technology capable of such encryption (e.g., you use a browser to interact with our Websites that are capable of Secure Sockets layer 128-bit encryption).
You can help us to protect the Personal Information you provide to us by:
(i) not sharing your password or other account information with others,
(ii) using a secure web browser, and
(iii) frequently changing your password.
8. Managing Information
You may update the information you provide by accessing your account and following the instructions set forth therein.
You may opt-out of receiving certain types of communications from us (“Optional Communications”). However, you will not be able to opt-out of receiving other types of communications, such as service announcements and administrative messages, as these types of communications are necessary if you have an account with us.
You may opt-out of receiving Optional Communications by following the instructions set forth in those communications or by accessing your account and following the instructions set forth therein.
If you have any questions regarding your ability to opt-out of receiving certain types of communications please contact us using our contact information set forth below in Section 8 (“Contact Information”).
Please note that removal of Personal Information from our database or “opting-out” will not stop marketing or advertising content that is ready to be mailed or is queued for transmission to you prior to the time when we can implement your request.
You may terminate your account with us by giving notice to us as set out in Section 8 below. A notice period of 28 days is required to allow us time to terminate any processes, payments, or other scheduled transactions on your account.
9. Contact Information
In Europe you can contact us at firstname.lastname@example.org , by mail at WorthPoint Ireland Ltd. Trinity Technology and Enterprise Campus, Unit 17, Pearse Street, Dublin 2, Ireland, or you may call us at: +353 1 687 7430.