1. Changes to this Policy. We reserve the right to change this Policy at any time, in our sole discretion, upon notice to you. We may give notice by posting the updated Policy on the Site, sending you an email, or by any other reasonable means. You should periodically review this Policy for changes and you can review the most current Policy at any time at: %%URL%%. The updated Policy will govern your use of the Site as of the Effective Date indicated at the top of this Policy. If you do not agree to the updated Policy, you should stop using the Site. Your use of the Site after the Effective Date of the updated version of this Policy will constitute your acceptance of the updated Policy.
2. Information Collection.
A. General. When you visit the Site, you can browse without submitting any personal information about yourself. We will, however, receive and store some non-personally identifiable information about you, as described below. In order to participate in certain functionalities, you may be asked to provide personally identifiable information. Personally identifiable information is information that can identify you, including, for example your name or email address. It will always be your choice, or the choice of anyone acting for you, to provide personally identifiable information.
B. Account and Login Information. We will collect personally identifiable information from you when you create an Account to become a Gates Notes Insider. If you create an Account, you will be asked to provide information about yourself, including, but not limited to, a user name, email address, and password selected by you. If you register for your Account using Social Networking Service credentials, we will collect your credentials in order to identify and log into the third party application or website and will retain your credentials to collect information from the Social Networking Service. For example, if you sign in with your Facebook or Twitter account, we may collect information from your public profile.
C. User Content and User Discussions. The Site may allow you to submit comments, photos, videos, or other information (“User Content”) to interactive portions of the Site, including, but not limited to, the user discussion areas of the Site or your Account Profile page (if applicable). You may sign in and participate in the user discussion areas of the Site using Disqus, a free service that requires your email address, a user name, and password. We may save User Content submitted by you indefinitely and in a profile specific to you.
D. Email Address Collection. In order to receive certain communications from us, including, but not limited to, our Annual Letter, you may be required to submit your name and email address to us. Any email you receive from us will include an unsubscribe link that will allow you to opt-out of receiving future emails.
E. Requests or Communications Submitted by You. The Site provides users the option to submit questions, feedback, or comments by filling out a form available under the “Contact” link at the bottom of the page. This form asks for your name and email address and we will use this information to respond to your inquiries. Any communications and contact information that you voluntarily submit to us may be saved indefinitely and in a profile specific to you.
F. Automatically Collected Information. Similar to other websites, we may collect some information automatically and store it in log files. This information does not identify you. This collection may include, but is not limited to: your domain name and host for Internet access, the Internet address of the site from which you came, the date and time of your access, your computer’s IP address and information about its operating system, browser, and host, the date and time you access the Site and the pages you visit. We collect this non-identifying information in order to help diagnose problems with our server and to administer the Site. We also use it to help identify you and to gather broad demographic information. We may automatically collect information using the following mechanisms:
Pixels (aka web beacons/web bugs/java script). Pixels are tiny graphics with a unique identifier that are used to track the online movements of web users. Unlike cookies, which are stored on a computer’s hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on web pages or in HTML-based emails. Our third-party analytics providers may place pixels on the Site that track what other websites you visit (both before and after visiting the Site). Our third-party analytics providers use information obtained from pixels to help us improve our business and the Site. We do not control the use of pixels by third parties. See the section on “Third Party Analytics Providers” below.
G. Third Party Analytics Providers. We use third parties to help us operate and improve the Site. We may provide these third parties with information we collect and they may collect information from you about your use of the Site. If we provide information to third parties, it will, unless specifically noted otherwise in this Policy, be governed by this Policy and may only be used by those third parties to help us operate or improve our business or the Site and to provide services to us. We do not control information collected by third parties and are not responsible for their use of that information.
3. Information Use
B. Use of Non-Personally Identifiable Information. We may use non-personally identifiable information for any lawful purpose, including, but not limited to analyzing trends, administering the Site, tracking users’ movements on the Site, and for management and improvement of the Site. We may also use this information to store information about your device so that you will not have to re-enter it the next time you visit the Site; to monitor aggregate metrics such as total number of visitors or pages viewed; or to track submissions in any interactive portion of the Site. We may also combine non-personally identifiable information with non-personally identifiable information collected from other sources.
C. Information Retention. We will retain your information indefinitely, or as long as legally required or allowed. We may dispose of any information in our discretion without notice, subject to applicable law. We do not undertake any retention obligations through this statement.
4. Information Disclosure.
A. Affiliated Entities or Service Providers. We will not sell or rent any of your personal information to third parties for marketing purposes. However, we may disclose your information to any affiliated entity or organization and to agents and service providers. These third parties may include various business service providers or providers that supply support for the Site or otherwise are working directly with us. Use of information by affiliated entities and organizations will be subject to this Policy or an agreement that is at least as restrictive as this Policy. For information on the use of information by agents and service providers, also see the “Third Party Analytics Providers” Section above.
D. Legal Requirements. In some cases, we may disclose your information (1) as required by any applicable law or legal regulation; (2) if we believe disclosure is needed to protect our rights, property, or safety; (3) to government regulators or law enforcement authorities in connection with any judicial proceeding, court order, subpoena, or legal process served on us or the Site; and (4) to respond to a physical threat to you or another person.
E. Insolvency and Business Transitions. If we should ever file for bankruptcy or engage in a business transition such as a merger with another company, or if we purchase, sell, or reorganize all or part of our business or assets, we may disclose your information, including personal information, to prospective or actual purchasers in connection with one of these transactions.
F. Disclaimer. We cannot ensure that all of your information will never be disclosed in ways not otherwise described in this Policy. For example, a third party may unlawfully intercept or access transmissions or private communications, or other users of the Site may abuse or misuse your personal information. No transmission of data over the internet can be 100% secure.
5. Information Security Measures. Keeping your information secure is of great concern to us. We exercise care in facilitating the transmission of information between your device or computer and our servers (or the third-party servers that operate and store information for the Site). Personally identifiable information collected by the Site is stored in operating environments that are not available to the public. While we have mechanisms in place to safeguard your personal information after we receive it, no transmission of data over the internet can be guaranteed to be 100% secure.
7. Children’s Privacy.
A. This Site is not for or Directed Towards Children. Our primary audience is adults and young adults. We do not intend to and will not knowingly collect any personal information from children under the age of 13; children under the age of 13 are prohibited from using the Site without parent/guardian supervision. If we learn that we have collected information from a child under the age of 13, we will remove that information immediately and delete it from our servers (subject to applicable law and this Policy). If you believe User Content from a child under the age of 13 has been posted to the Site, please notify us by going to the “Contact” link at the bottom of our home page and using the inquiry form located there. We also recommend that children over the age of 13 ask their parents for permission before sending any information about themselves to anyone over the internet.
B. California Minors. If you are a California resident who is under age 18 and you are unable to remove publicly-available User Content that you have submitted to us, you may request removal by contacting us at: email@example.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information is located, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information. REMOVAL OF YOUR CONTENT OR INFORMATION FROM THE SITE DOES NOT ENSURE COMPLETE OR COMPREHENSIVE REMOVAL OF THAT CONTENT OR INFORMATION FROM OUR SYSTEMS OR THE SYSTEMS OF OUR SERVICE PROVIDERS. We are not required to delete the Content or information posted by you; our obligations under California law are satisfied so long as we anonymize the Content or information or render it invisible to other users and the public.
8. California Shine the Light Law. California Civil Code Section 1798.83 permits 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 personal information (as defined under that statute) of that California resident, for direct marketing purposes in the preceding calendar year and the categories of that kind of personal information that was disclosed to them. If you are a California resident and you wish to make such a request, you may do so by contacting us as specified in Section 11 below.
10. Accessing, Updating, or Deleting your Personal Information. If personal information that you have submitted to us changes or if you would like to remove your personal information, please contact us as specified in Section 11 below. We will make good faith efforts to resolve requests to remove information or correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical.
11. Contact Information and Privacy Questions. If you have questions about this Policy or other matters that relate to it, you may contact us by going to the “Send an email” link at the bottom of our home page (under “Contact”) and using the form located there.
Effective Date: November 24, 2015