Privacy Policy

Privacy Policy2018-05-31T13:03:27+00:00

Privacy Notice for Data Subjects

This Privacy Notice (“Privacy Notice”) is intended for anyone who wishes to review, modify, restrict or take ownership of the information that ClickNotices might have on them, as well as understand how ClickNotices uses that information. Additional information for ClickNotices Users can be found in the Privacy Policy.

Overview

ClickNotices’ core purpose is to make delinquency management a more streamlined and efficient process. In today’s fast-paced world, creating a smooth, efficient, repeatable, and compliance process is challenging.

You can think of ClickNotices as the property manager’s delinquency assistant. We do our best to bring together industry knowledge and regulatory information from a variety of public sources (such as is available on the Internet through a simple Google Search) and combine it with tenant, property and delinquency information that our users contribute. We couple that with powerful tools for individuals and companies to manage their delinquency process.

We aim to have the most complete, accurate, and up-to-date record we can for each tenant on our platform (also known as the “ClickNotices Database”). The types of information we may keep track of include contact elements such as name, address, phone number, and email. We often also have rental information (monthly rent amount, lease tenure, secondary occupants).

All of this information is intended to help the companies and tenants you interact with participate in a more meaningful efficient delinquency process. Based on the information someone already has on you, they might look you up in our system and get back some additional information. However, we never share the information that is dearest to your individual privacy: your home addresses, personal email addresses, or your personal phone numbers, unless you have given us your specific and unequivocal permission to share that information or we have secured the information via pseudonymization (e.g., through cryptographic hashing). That means, for example, that a company would not be able to know your personal email unless you have given us your explicit permission or had provided your personal email previously to them.

The information in our system also helps the people and companies you interact with to clean up their own “address books” so that they don’t have information about you scattered across multiple systems and devices and so that they don’t connect with you multiple times, through different channels, with information that its is entirely irrelevant to you . We help our people and companies to gather their existing information into clean contact records for each individual they know.

We also allow people or companies to search in our system for individuals who meet certain criteria. For example, a professional who’s trying to find an expert in their field can use our Services to find the right person. Similarly, an organization could search for the most appropriate audience for their offerings. However, unless you have given us your specific permission, or we have secured the information via pseudonymization (e.g., through cryptographic hashing), we will not provide home addresses, personal email addresses, or personal phone numbers.

Your Rights

Anyone, in any country across the world, may access, rectify, or restrict their Personal Data within ClickNotices Database at any time by requesting a report from getmydata@clicknotices.com. Please note that we may ask you to verify your identity before taking action on your request. If you ask us to erase your data, we may still have to retain certain data about you to ensure that your Personal Data does not re-enter our system and protect your rights. Specifically, we will mark your Personal Data as “hidden” and “restrict processing” such that your data is no longer used or made available to anyone.

California Privacy Rights

California law permits users and customers who are California residents to request and obtain from us, once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Data disclosed to those third parties. See the “Contact Us” section below for where to send such requests.

General Data Protection Regulation (GDPR)

Individuals in the EU may exercise any of the rights described in this section by using the applicable functionality in our Services or by contacting us directly. If you reside outside of the European Union, you may have similar rights under your local laws.

The purpose for processing, categories of Personal Data concerned, and categories of recipients of Personal Data are described in the “Overview” section above. Our lawful basis for processing is our legitimate interest in providing contact management services to our Users, enabling them to better connect and build their relationships with you. Personal Data will be retained as long as necessary to serve that purpose or until you decide it is not in your best interest to keep your information in the ClickNotices Database. You have the right to object to the processing of your Personal Data at any time.

If you have taken ownership of your data by contacting us directly, we may ask for your explicit permission to share certain of your Personal Data. If you choose to give permission to share certain information, then our lawful basis for processing is your Consent. You have the right to withdraw your Consent at any time. You also have the right of portability for any data that you have provided us.

You have the right to request from us access to and rectification or erasure of Personal Data or restriction of processing. You may exercise these rights at (Own Your Personal Data) or by contacting us directly. Requests for erasure can not be met because erasing your Personal Data would not achieve the desired result of your Personal Data not being in our system: we receive data continuously and would likely have your Personal Data in our system again quickly. Instead, we will mark your Personal Data as “hidden” and “restrict processing” such that your data is no longer used in providing our service and is no longer made available to anyone.

You have the right to request the sources of your Personal Data. You may do so by contacting us as indicated in the “Contact Us” section below. Please note that to protect the rights of other data subjects, we may only be able to provide you with the general categories of sources.

We may transfer, store, and process your information within our family of companies or with service providers based in the United States. ClickNotices complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States, respectively.

You have the right to lodge a complaint with your applicable supervising authority.

How to Contact Us
If you have any questions or complaints about this Privacy Notice, please contact us at: privacy@clicknotices.com

Chief Executive Officer (CEO)
Matthew T. Barbieri
privacy@clicknotices.com

Organization:
Click Notices Inc. (a Delaware Company)
77 West Street, Suite 305, Annapolis, MD 21401
+1-443-878-1500

ClickNotices Privacy Policy

Last Updated: 5/22/2018

Thank you for using ClickNotices!

ClickNotices Inc. (“ClickNotices”, “we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, process, and disclose your information, including Personal Data (as defined below), in conjunction with your access to and use of our Services, and it applies to all of the Services offered by ClickNotices and its affiliates including but not limited to all ClickNotices Apps, Sites, APIs (including exports), and ClickNotices Integrations. “Users” as defined in this Privacy Policy includes any user of our Services including individual End Users, organizational Clients, and Developers.

Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use located at ClickNotices Terms, Services Agreement located at ClickNotices Services Agreement, or your executed Master Services Agreement.

Specifically, we’ll cover:

  1. Information We Collect
  2. How We Use Information
  3. How Information Is Shared
  4. Data Retention
  5. Third Party Websites
  6. Minors
  7. Data Protection
  8. Your Rights
  9. Your Rights Under The GDPR
  10. Changes to This Privacy Policy
  11. How to Contact Us

1. INFORMATION WE COLLECT

1.1 Types of Data We Collect

“Personal Data” means any data that allows someone to identify or contact an individual data subject, including, for example, name, address, telephone number, email address, as well as any other non-public information that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

1.2 Information You Provide Us

Account Information.

When you sign up for a ClickNotices Account, we may require certain information such as your full name, organization, phone number, email address(s) and password. You may optionally choose to sign into ClickNotices using a third party (e.g., your Google login). If you choose to do this, you will be asked whether you agree to the third party providing certain information to ClickNotices, such as your name, email address, profile photo, and other information associated with your account.

Profile Information.

To help improve your experience or enable certain features of the Services, you may choose to create a profile including information such as your name, photo, email, phone, URLs, physical address, job title.

Referrals.

When you use ClickNotices to refer our Services to others we will collect and use any contact information you choose to provide and automatically generate an invitation to the contacts you select.

Payment Information.

Some of our Services require payment. We may use third party service providers such as Stripe or Authorize.net to collect all information necessary to complete the transaction. Such information may include name, credit card and billing information, as well as additional fields required for payment. We never share your billing and payment information.

General Communication.

If you contact us (for example via email or phone) we will collect information such as your name, phone number, email address, as well as any other content that you provide. We also may create event logs to diagnose product or app related issues, and capture information relating to any support or service issues. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives and analyze any feedback provided through voluntary customer surveys.

Additional Information.

You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Account, respond to surveys, provide feedback, request support, post to forums, participate in promotions, or use other features of our Services. We may also collect information at other points in our Services when clearly stated that information is being collected.

1.4 Information We Receive from Third Parties.

We may obtain information from other sources, including but not limited to public or licensed APIs (“Public Data”), and combine that with information we collect through the Services. We do not control, supervise, or respond for how the third parties providing your information process your Personal Data.

Analytics.

We may collect and allow third parties to collect information about how you use and interact with our Site and Services. Examples of third-party providers of analytics and similar services we currently use include:

Google Analytics and Facebook Analytics.

Used to track site statistics and user demographics, interests and behavior on websites. Firebase, another Google service, is used on some of our mobile apps to track the effectiveness of our marketing campaigns and advertisements. We also use Google Search Console to help understand how our website visitors find our websites and to improve our search engine optimization.

Third Party Services.

If you link, connect, or login to your ClickNotices Account with a third party service (For Example: Google, Okta, Yardi, Realpage, Rent Manager), the third party service may send us information such as your registration and profile information. This information varies and is controlled by that service or as authorized by you via your privacy settings in that service.

2. HOW WE USE INFORMATION

We use, store, and process information, including Personal Data, to provide, understand, improve, and develop our Services, create and maintain a trusted and safer environment, and comply with our legal obligations.

2.1 Provide, Maintain, and Support the Services

Using the information we collect, we are able to deliver the Services to you and honor our Terms of Use. For example, we may process your requests to provide you with the delinquency management features you select, including but not limited to filing, storage, backup, editing, synchronization, mailing, search, tagging, and grouping.

We also need to use the information you provide (including Personal Data) to facilitate the creation of and secure your Account on our network, identify you as a user in our system, provide improved administration and quality of experience of our Site and Services, send email, call, or send SMS text messages to you to verify ownership of the email address or phone number provided when your Account was created, send you service, support or maintenance messages, updates, security alerts, and Account notifications. Your information may also be used for the detection and prevention of fraud, spam, abuse, and other harmful activity, and for any purpose you authorize at the time of collection.

Additionally, to provide you technical support, we may need to review your Account and the contents of your Account to identify, research, troubleshoot, and resolve any issues that you report to us or that we otherwise become aware of.

2.2 Improve, Personalize, and Develop the Services

We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing

We may process your information (including Personal Data) for marketing purposes including profiling and offering you products or services that may be of interest to you (such as information about ClickNotices Services or partner campaigns and other third party services). We may also administer referral programs, rewards, surveys, sweepstakes, contests, newsletters, or other promotional activities or events sponsored or managed by ClickNotices or its third party partners. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your ClickNotices Account.

2.5 Creation of Anonymous Data

We may create Anonymous Data records from information by excluding certain private data in a manner that makes the data not personally identifiable. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. ClickNotices reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.

3. HOW INFORMATION IS SHARED

3.1 When You Consent, Agree or Direct Us to Share

You may authorize us to disclose your information to others, such as when you connect a third party application or website to access your ClickNotices Account, when you participate in promotional activities conducted by ClickNotices partners or third parties or when you exercise consent as requested in the use of our Services.

3.2 Sharing Between Users

To provide our Services, we may need to share certain information with other Users of our Services , as it is necessary for the adequate performance of the contract between you and us and for performance of certain features of our Services based on our legitimate interest. Examples include, but are not limited to, sharing information through our ClickNotices for Attorneys product as well as information contributed to our Database for the purposes of improving the Services for both you and other End Users and Developers (as described in Section 2.4).

3.3 Compliance with Law, Responding to Legal Requests, Preventing Harm, and Protection of Yours or Our Rights

Regardless of any choices you make regarding your Personal Data (as described below), ClickNotices may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with applicable laws, including laws outside your country of residence; (c) to respond to requests from public and government authorities (including authorities outside your country of residence) or to respond to subpoenas or warrants served on ClickNotices; (d) to protect or defend the rights or property of ClickNotices and/or that of you or other End Users or Developers; and/or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use. In addition, under certain applicable laws, individuals may have the right to require that we disclose to them their information (including Personal Data) that we store in our Database. ClickNotices will make such disclosures required by law, but we will not disclose you as the source of that information unless required by law.

3.4 Service Providers

ClickNotices uses a variety of third party service providers to help us provide our Services. These Service providers may be located anywhere worldwide in countries outside your country of residence. In particular, currently use service providers based in Europe, India, Asia Pacific and North and South America.

In order to facilitate payments for Services we provide, certain information as described above may be shared with the relevant payments service providers. This data sharing is necessary for the performance of the contract between you and us.

These service providers may have limited access to your information as necessary to perform these services on our behalf, and are contractually bound to protect and to use your information only for the purposes for which it was disclosed and consistent with this Privacy Policy.

ClickNotices may need to share your information in order to deliver the Services to you and honor our Terms of Use.

3.5 Corporate Affiliates

To enable or support us in providing the Services, we may share your information including Personal Data, in compliance with local data Privacy laws, within our corporate family of companies that are related by common ownership or control.

3.6 Business Transfers

If ClickNotices undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information, in connection with such transaction, or in preparation for or contemplation of such transaction (e.g., due diligence).

3.7 Aggregated and Anonymized Data

We may also use and share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other Anonymized Data for any lawful purpose, including (but not limited to) regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

4. DATA RETENTION

We generally retain your information for as long as is necessary for the performance of the Services to you and our other Users and to comply with our legal obligations. This includes information that you have made available to the ClickNotices Database for the purposes of improving the Services for both you and other Users of our Services (as described in Section 2.4).

You may request that we delete your information and close your ClickNotices Account or you can delete your End User Contact Data and close your Account on your own. Please note that if you request the deletion of your information or if you delete your information:

We may retain some of your information as necessary for fraud detection and prevention and enhancing safety. For example, if we suspend a ClickNotices Account for fraud or safety reasons, we may retain certain information from that Account to prevent that user from opening a new ClickNotices Account in the future.

We may retain and use your information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting, and auditing obligations.

Information you have shared with other systems (e.g., Google) may continue to exist in those systems, and in some cases be publicly visible.

Some copies of your information (e.g., log records) may remain in our Database but are disassociated from personal identifiers.

Because we maintain backup to protect our Services from accidental or malicious loss and destruction, residual copies of your information will be included in backups and may not be removed from our backup systems.

5. THIRD PARTY WEBSITES

When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites, or the manner in which they collect, use and handle information or content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

6. MINORS

Our Services are not intended for or designed to attract anyone under the age of 18 (“Minors”). We don’t intentionally or knowingly collect personal information regarding Minors and our Terms of Use explicitly prohibit the use of our Services by Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without such parent or guardian’s consent, he or she should contact us. We will then delete such information from our Database.

7. DATA PROTECTION

7.1 Security

We are continuously implementing and updating appropriate technical and organizational measures to help protect your Personal Data against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your Personal Data are firewalls and data encryption, and information access controls. If you know or have reason to believe that your account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the “Contact Us” section below.

7.2. Our International Operations and Data Transfers

To bring you our Services, we operate globally. We may transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia and North America. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the European Economic Area (the “EEA”) may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy.

7.3 EU-US and Swiss-US Privacy Shield

ClickNotices Inc. complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States, respectively. ClickNotices has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, ClickNotices is subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at: ClickNotices, Inc., Legal Department, 77 West Street, Suite 305, Annapolis, MD 21401 or via email privacy@clicknotices.com. If we are not able to resolve your concern, you may also contact our designated Privacy Shield independent dispute resolution provider, JAMS. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.

8. YOUR RIGHTS

8.1 Email Choices

We offer you choices regarding the collection, use, and sharing of your Personal Data. If you are a User of our Services, we may periodically send you free newsletters and emails that promote our Site or Services as well as products or services we think you may be interested in. When you receive such promotional newsletters or communications from us, you may indicate a preference to stop receiving them from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly. Despite your indicated email preferences, we may send you service related communication, including notices of any updates to our Terms of Use or Privacy Policy.

8.2 Access, Correction, and Deletion

ClickNotices allows any data subject, including the End Users of our Services, to access, modify, and set permissions with respect to Personal Data that it holds about them.

Further information for data subjects can be found at Privacy Policy.

8.3 California Privacy Rights

California law permits users and customers who are California residents to request and obtain from us, once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Data disclosed to those third parties. See the “Contact Us” section below for where to send such requests.

9. YOUR RIGHTS UNDER THE GDPR

In the Use of our Services we mainly act as data processor and, in some cases, we may act as data controller when we determine the purposes and means of the processing of Personal Data.

EEA residents may exercise any of the rights described in this section by using the applicable functionality in our Services or by contacting us directly. If you reside outside of the European Union, you may have similar rights under your local laws. Please note that we may ask you to verify your identity before taking action on your request.

9.1 Purposes and Legal Basis for Processing.

The purposes for processing are described in detail in Section 2 (“HOW WE USE INFORMATION”). In the Use of our Services when we act as data controller the legal basis for processing is as follows:

  • Provide and Maintain the Services (Section 2.1): This enables us to deliver the Services to you and honor our Terms of Use in the performance of a contract.
  • Improve, Personalize, and Develop the Services (Section 2.2): This use is based on our Legitimate Interest in improving our services for you and other users.
  • Provide, Personalize, Measure, and Improve our Advertising and Marketing (Section 2.3): This use is based on our Legitimate Interest in marketing our Services.
  • Combine Contacts and Relationship Information Across Users (Section 2.4): This use is necessary to deliver certain Services to you and is based on our your explicit Consent.
  • Creation of Anonymous Data (Section 2.5): This use is based on our Legitimate Interests to improve and market our Services.

9.2 Categories of Recipients of Data.

Recipients of data are detailed in Section 3 (“HOW INFORMATION IS SHARED”).

9.3 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete Personal Data concerning you (and which you cannot update yourself within your ClickNotices Account).

9.4 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request copies of your Personal Data held by us. You may also be entitled to request copies of Personal Data that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

9.5 Withdrawing Consent and Restriction of Processing.

Where you have provided your consent to the processing of your Personal Data by ClickNotices you may easily withdraw your consent at any time specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Data, in particular where (i) you contest the accuracy of your Personal Data; (ii) the processing is unlawful and you oppose the erasure of your Personal Data; (iii) we no longer need your Personal Data for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 9.2.6 below (“Objection to Processing”) and pending the verification whether the legitimate grounds of ClickNotices override your own.

9.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require ClickNotices not to process your Personal Data for certain specific purposes, where such processing is based on legitimate interest. If you object to such processing we will no longer process your Personal Data for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise, or defense of legal claims.

Where your Personal Data is processed for direct marketing purposes, you may, at any time, ask us to cease processing your Personal Data for these direct marketing purposes by sending an email to: opt-out@clicknotices.com.

9.7 Lodging Complaints.

You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities. If you are a EEA resident, you have the right to file a complaint with your applicable data protection authority.

10. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an email to the last email address associated with your Account, and/or by prominently posting notice of the changes on our Site. If any changes materially affect the manner in which we use or disclose Personal Data, we will provide advance notice of the change by email to the last email address associated with your Account, and/or by prominently posting notice of the changes on our Site. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

11. HOW TO CONTACT US

If you have any questions or complaints about this Privacy Policy, please contact us at: privacy@clicknotices.com

Chief Executive Officer (CEO)
Matthew T Barbieri
privacy@clicknotices.com

Organization:
Click Notices Inc. (a Delaware Company)
77 West Street, Suite 305, Annapolis, MD 21401
+1-443-878-1500

Types of information covered by ClickNotices Privacy Policy:

Note differences in this policy regarding the term “human resources data”. Human Resources Data refers to personal data about employees, past or present, collected in the context of the employment relationship. Information other than Human Resources data includes the following: customer, client, visitor, tenant, and rental data.

ClickNotices’ Privacy Policy covers: Personal data other than human resources data
Purposes for which ClickNotices collects and processes personal data in reliance on the Privacy Shield:

General Use.

In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

  • Facilitate the creation of and secure your account on our network;
  • identify you as a user in our system;
  • provide improved administration and quality of experience of our Site and Services;
  • provide the Services you request;
  • send you a welcome email to verify ownership of the e-mail address provided when your account was created;
  • send you administrative e-mail notifications, such as security or support and maintenance advisories;
  • respond to your inquiries related to employment opportunities or other requests; and
  • send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of ClickNotices.

Creation of Anonymous Data.

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. ClickNotices reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.

Disclosure of Your Personal Data.

We disclose your Personal Data, End User Contact Data and Completed Contact Data as described below and as described elsewhere in this Privacy Policy. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, ClickNotices is potentially liable.

Third Party Service Providers.

We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to ClickNotices. These third party service providers are required not to use your Personal Data other than to provide the services requested by ClickNotices. ClickNotices requires its service providers to whom it discloses Personal Data and who are not subject to the laws based on the EU Data Protection Directive 95/46 or Swiss Federal Data Protection law to either (i) subscribe to the Privacy Shield principles or (ii) contractually agree to provide at least the same level of protection for Personal Data as is required by the relevant Privacy Shield principles.

Affiliates and Acquisitions.

We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

Other Disclosures.

Regardless of any choices you make regarding your Personal Data (as described below), ClickNotices may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on ClickNotices; (c) to protect or defend the rights or property of ClickNotices or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use. ClickNotices may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Developers.

Developers may want access to Personal Data (including End User Contact Data) that we collect from their customers. As a result, we may provide your Personal Data to Developers; however (and in accordance with California’s “Shine the Light” Act codified at Civil Code section 1798.83), we will cease any further disclosure of your Personal Data to Developers for their own direct marketing purposes if you “opt-out” by contacting us as described in Section 13 below. If you wish to discontinue receipt of these e-mails, please contact the applicable Developer directly to update your preferences. The privacy policies of the Developers may apply to the use and disclosure of your Personal Data that we collect and disclose to such Developers. We contractually require Developers to not, and to require their customers to not, use such data for the purposes of cookie tracking, ad exchanges, ad networks, data brokerages, and sending electronic communications (including email) in violation of applicable law. ClickNotices requires Developers to whom it discloses Personal Data and who are not subject to the laws based on the EU Data Protection Directive 95/46 or Swiss Federal Data Protection law to either (i) subscribe to the Privacy Shield principles or (ii) contractually agree to provide at least the same level of protection for Personal Data as is required by the relevant Privacy Shield principles.