Last Updated: January 7, 2020
- What personally identifiable information we collect from you through the Websites.
- How we use the information we collect.
- With whom the information may be shared.
- The kind of procedures we employ in an effort to prevent the unauthorized access, use or disclosure of information you provide to us.
- Information related to third-party websites.
- The laws that apply to those accessing our Websites from outside of the United States.
- How you can learn about changes to our privacy policies, practices and procedures.
- Special provisions related to the European Union’s General Data Protection Regulation
2. The Information We Collect.
A. Personally Identifiable Information.
“Personally Identifiable Information” is information, that either alone or in combination with other information, identifies you. When we combine other information (i.e., information that does not, on its own, identify you), with Personally Identifiable Information, we treat the combined information as Personally Identifiable Information. You may freely visit our Website anonymously and without being required to provide us with any Personally Identifiable Information. However, certain requests and features do require that you provide us with some Personally Identifiable Information, as more particularly described below.
B. When and How We Collect and Use Personally Identifiable Information.
We and our service providers collect the Personally Identifiable Information set forth below in order to provide the requested services, features or resources available via the Website to you, or because we are legally required to do so. If you do not provide the Personally Identifiable Information requested, we may not be able to provide you with the requested services, features or resources. The Personally Identifiable Information we and our service providers collect includes but is not limited to:
- Registration Information.
SBF makes certain features, products or services offered subject to registration requirements. To access those non-public, restricted areas, you may be asked to provide certain information about yourself, such as your name, mailing address, e-mail address; and to create a username and password.
- Email Newsletter; News & Related Information.
SBF offers various subscription lists to which you could voluntarily submit your name, mailing address and/or email address. If you no longer wish to receive these any of these emails and/or subscriptions, you may opt-out by clicking on and completing the opt-out link provided at the bottom of the applicable email.
- Contact Us.
The Website provides links for questions, support and help. If you contact us through any of these contact forms, we will collect your email address, and any other personal information that you provide to us. We will use the information you provide to contact you and to respond to any requests and/or questions.
- Personally Identifiable Information Collected When You Access our Products and Services.
If you opt to access/subscribe to any of our products and services, you will be asked to provide us with a variety of Personally Identifiable Information, and which in many cases will require that you provide us with credit card information for payment. Please note that access to these products and services may contain other terms and conditions, including additional terms related to the use and sharing of your Personally Identifiable Information.
- Personally Identifiable Information You Disclose Relating to Others.
C. Information We Automatically Collect through the Website.
We and our service providers collect the following types of information automatically when you visit the Website:
- Log Information.
When you use visit the Website our servers automatically record information, including your Internet Protocol address. An IP Address is a unique identifier number that certain electronic devices use to identify and to communicate with each other on the Internet; your Internet Service Provider automatically assigns an IP Address to the computer that you are using. We also may collect your browser type, referring URLs (e.g., the site you visited before coming to our Services), number of clicks, and how you interact with links on the Website, domain names associated with your internet service provider, pages viewed, and other such information. We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients. We use all such aforementioned information to track Website visitor movement in the aggregate, and to gather broad demographic information for aggregate use. Our goal in gathering this information is to learn how our customers and the public are using our Website. We may use this information to enhance our Website or for other lawful purposes.
- Cookies and Similar Technology.
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of device identifiers. If you choose to reject cookies or block device identifiers, some features of the Website may not be available or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.
- Do Not Track.
Every time your computer sends or receives information over the Web, the request begins with some short pieces of information called “headers.” These headers include information like what browser you are using, what language your computer is set to, and other details. The Do Not Track technology provides individual users with the ability to include a simple, machine-readable header indicating that they don't want to be tracked, and sends a signal to Websites visited requesting that the website disable either its tracking or cross-site user tracking of an individual user. To learn more about how DNT works, please visit http://allaboutdnt.com/.Currently, various browsers—including Internet Explorer, Google Chrome, Firefox, Opera and Safari—offer a “do not track” option. Presently, there is no consensus on how Do Not Track should be interpreted, and no common or accepted industry standard for implementing. Consequently, please note that our Website does not currently respond to browsers' Do Not Track signals, and as such your activities will be tracked, regardless of whether you have opted to enable the Do Not Track option offered by your browser.
- Other Information.
In addition to the other information outlined in this Section 2.C, we may also collect information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as but not limited to: (i) demographic information and other information provided by you that does not reveal your specific identity; and (ii) information that has been aggregated in a manner that it no longer reveals your specific identity.
3. How We Use Your Personally Identifiable Information.
A. Use of Personally Identifiable Information.
- administering our Website and related services, resources, and business including responding to your inquiries, fulfilling your requests, and providing you with related customer service;
- personalizing our Website for you by presenting products and offers tailored to you;
- sending you goods purchased through our Website;
- supplying professional services purchased through our Website;
- sending statements, invoices, and payment reminders to you, and collecting payments from you;
- sending you non-marketing commercial communications;
- sending you email notifications that you have specifically requested;
- sending you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
- sending you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
- dealing with inquiries and complaints made by or about you relating to our Website;
- verifying compliance with the terms and conditions governing the use of our Website (including monitoring private messages sent through our Website private messaging service); and
- for our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, or improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
B. To Whom We Disclose Personally Identifiable Information and Non Personally Identifiable Information.
We may disclose your Personally and non-Personally Identifiable Information to any of our employees, officers, insurers, professional advisers, agents, suppliers, subcontractors or to any member of our group of companies (including our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.
In addition, we may disclose your Personally and Non-personally Identifiable Information to:
- Our Service Providers.We employ service providers to perform tasks on our behalf and to assist us in providing the Website and related services, such as website hosting, data analysis, payment processing, order fulfillment, customer service, information technology and related infrastructure provision, email delivery, and other services.
- Third-Party Vendors. SBF uses third-party vendors (such as Google Analytics) to analyze how users use the SBF Services. SBF may use anonymous and aggregated data collected by SBF itself or by such third parties on behalf of SBF to track and examine the use of the SBF Services, to create statistics and reports for various business purposes, and to aggregate such anonymous data and share it with SBF’s advertisers, service providers or business partners in order to offer you potentially desirable products and services; however, such data will not include information that enables such third parties to identify you individually without your information. The Personally Identifiable Information compiled in our registration and subscription databases will not be shared with any marketing firms or other third parties (other than those providing services to SBF and that are restricted to using such information on behalf of SBF and solely as and to the extent necessary to provide such services to SBF) without the express consent of the registrant or subscriber.
- Advertising. SBF incorporates remarketing by utilizing third party vendors (such as Google) to display content specific advertisements to visitors who have previously visited the SBF Services and/or expressed interest in the SBF products when such visitors go to other websites that also incorporate similar remarketing tools. SBF and other third-party vendors, including Google, use first-party cookies and third-party cookies together to inform, optimize and serve ads based on user’s past visits to the SBF Services.
Remarketing is a way for SBF to connect to SBF users based upon such users’ past interactions with SBF. Third-party vendors (such as Google) may show SBF ads on other sites on the Web.
If you choose, you can opt out by turning off cookies in your browser. You can opt-out from being tracked by Google Analytics by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser, by visiting: http://www.tools.google.com/dlpage/gaoptout
Finally, you may opt out by turning off cookies in the preferences settings in your browser.
- Companies Involved in Merger and Acquisition Transactions. In some cases, we may choose to buy or sell assets, or merge with another entity. In these types of transactions, user data (including Personally Identifiable Information) is typically one of the business assets transferred. Moreover, if SBF, or substantially all of its assets, were acquired, user data would be one of the assets that is reviewed and transferred or acquired by a third party.
- Law Enforcement, Government Agencies, and Courts. We may disclose Personally Identifiable Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of a customer or any other person. We may also disclose Personally Identifiable Information to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.
- Search Engines and Other Sites. Search engines and other sites not affiliated with the SBF, such as archive.org or google.com, may crawl the Website and make available to the public publicly-available content and postings from the Website.
4. How We Protect Your Information.
The security of your Personally Identifiable Information is important to us and we take reasonable precautions to protect it. However, notwithstanding such precautions, SBF assumes no responsibility for the security of the Services or any data transmitted to SBF, including, but not limited to, information related to potential employment or applications therefore, or any other matter.
5. Children’s Use of the Services.
The Website are not intended for children under 13 years of age. We do not knowingly collect Personally Identifiable Information from children under age 13. If you are under 13 years old, do not use or provide any information on or through the Website. If we learn we have collected or received Personally Identifiable Information from a child under the age of 13 without verification of parental consent, we will delete that information. If you believe we might have any personally identifiable information from or about a child under the age of 13, please email us at Randall (@) SeniorBenefitsFoundation.org
6. Links to Affiliate, Partner, and other Third Party Websites.
7. Use of the Websites from Outside the United States
8. Contact Information.
10. European Union Area, Switzerland and United Kingdom Users
The following provisions applies only to users residing in the European Union Area (“EEA”), Switzerland and the UK.
Please note, in May of 2018 a new data privacy law known as the EU General Data Protection Regulation (“GDPR”) went into effect. Pursuant to GDPR, we are required to provide those residing in the EEA, Switzerland and the United Kingdom (hereinafter, the “EU Users”) additional information and rights related to the “Personal Data” we collect about them. We summarize such information and rights below.
How To Contact Us
Purpose for Information Collection
Legal Grounds for Processing Personal Data
SBF will process personal data that we receive from EU Users on the ground that it is in our legitimate interest for the effective administration of the Website, to fulfill and/or address your requests, or to provide the functionalities and features as further described herein.
Your Information and Your Choices; Withdrawal Of Consent
GDPR provides EU Users with additional rights in respect to the Personal Data we hold about you, including the right i) to be informed about the Personal Data we have collected, and ii) to request a copy of the Personal Data, and iii) to have your Personal Data deleted, and iv) to lodge a complaint about our processing of your Personal Data with your local supervisory authority. Upon appropriate written request we will update or amend your Personal Data, but we reserve the right to use any information previously obtained to verify your identity or take other actions that we believe are appropriate and lawful. You may access, correct, or request deletion of your Personal Data—or request that we stop any processing of your Personal Data—by contacting us. We will respond to your request within a reasonable timeframe.
Please note we may need to retain certain information for record keeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed from such locations. Additionally, there may be circumstances in which we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided in data protection legislation in general, and GDPR in particular. Finally, please note that we are not responsible for removing or deleting information from the databases of third parties (such as service providers) with whom we have shared information about you, but we will make the request on your behalf for such removal/deletion.
Children’s Privacy/Note To Parents Of Children Residing In The EEA, Switzerland And UK
The Website do not intentionally or knowingly collect, use, or disclose personally identifiable information about visitors to our Website that are less than 16 years of age. If a child under the age of 16 submits information to us through any part of the Website and SBF becomes aware that the user submitting the information is under the age of 16, the information provided will be deleted as soon as it is discovered and not used for any purpose. If you are the parent or guardian of a child under 16 years of age and believe that they have disclosed personally identifiable information to us, please contact us at the address below and be sure to include in your message the same user name and password and/or email address that you believe your child submitted, if applicable: Randall (@) SeniorBenefitsFoundation.org.