Privacy Policy

Our Privacy Policy was posted on April 26, 2019.  It governs the privacy terms of our website and the tools we provide you (the “Website” or the “Services”).

Your Privacy

Our Website follows all legal requirements to protect your privacy.  Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information. You will see terms in our Privacy Policy that are capitalized. These terms have meanings as described in the Definitions section below.

Definitions

1. Personal Data: Personal Data means data about a living individual who can be identified from such data (or from other information either in our possession or likely to come into our possession).
2. Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
3. Cookies: Cookies are small pieces of data stored on a User’s device.
4. Data Controller: Data Controller means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy. We are a Data Controller of your data.
5. Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
6. Data Protection Authority is the independent public authority responsible for monitoring the application of the General Data Protection Regulation, in order to protect the fundamental rights and freedoms of natural persons in relation to processing and the facilitate the free flow of personal data.
7. Data Subject: Data Subject is any living individual who is the subject of Personal Data.

1. User: The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Please remember that this Privacy Policy does not apply to the practices of companies that we don’t own or control or to people that we don’t employ or manage. We encourage you to read the privacy policies of each and every website and service that collects personal information about you. This Privacy Policy applies solely to information that we collect about you as a user of the Services. This Privacy Policy is incorporated into and subject to our Terms of Service.  Each time you use the Services, you signify that you have read, understood and agree to be bound by this Privacy Policy and the Terms of Service.  If you do not agree to the terms of this Privacy Policy, you must discontinue using the Services and terminate your membership or account.

The purpose of this Privacy Policy is to inform you of our information practices related to the information that you provide when using our Services as set forth below.

1. COLLECTION AND USE OF YOUR INFORMATION
2. When You Register

When you register for the Services, you may be required to provide certain information, such as your name, maiden name (if applicable), mailing address and/or zip code, email address, phone number, birth date or year, marital status and password.  You may also be presented with the option to register for the Services using your Facebook login credentials or similar login processes or co-registration forms from or on other third-party websites, in which case you will be authorizing us to access certain information from your current profile on Facebook or other third-party website (which will be specified in such login process) for purposes of completing your registration. In addition, when you install certain of our applications on Facebook or other third-party websites or devices, you will also be registering for the Services by agreeing to such installation, which takes place when you “accept,” “install” or “allow” (or similar language) such application. Each such application includes a disclosure that this registration will occur upon the acceptance, installation or allowance of the application.

Please keep in mind that, although some of the information described above will not be view able by other members, once you are registered your name, military status and locations and years served will be displayed on the Website and you will no longer be anonymous to us or to other individuals who access this Website. In addition, because this information is publicly displayed on this Website, it may be included in this Website’s “search” tools.We may also publicly display your general geographic location based upon the zip code or other geographical information provided to us, as another means of assisting members in finding each other. However, you have the option of opting out of having your general geographic location publicly displayed by accessing your privacy settings on this Website and changing your preferences.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you.  You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

1. When You Accept an Application

Some third-party websites, such as Facebook, provide their users with access to applications or other tools, such as “social login,” which allow that website’s users to share certain personal information with us. When you accept or allow one of our applications or use another tool to create a connection between us and Facebook or other third-party website, you authorize us to collect, store and use (in accordance with this Privacy Policy) all information that you agreed Facebook or other third-party website could provide to us, which may include such things as your email address, birthday, profile and other photos, school and work affiliations, location, interests, activities and friend information. This authorization may also include the ability to continue to collect such information from Facebook or other third-party website on an ongoing basis. If you choose to remove or delete any such application, or otherwise break our connection with your account on Facebook or other third-party website, we will no longer be able to continue to collect your information from that website. However, deletion or removal of such application does not delete your account from the applicable Website, and we will continue to store and use information that we have previously collected. You can of course edit or delete any of your account information on the applicable Website at any time (see Section 3 below).

Acceptance of one of our applications may authorize us to automatically post information to your profile on Facebook or other third-party website about certain of your activities, such as looking at a reunion, liking a photo, joining a community affiliation, becoming a reunion organizer, updating the details of a reunion, responding to a reunion invitation or tagging someone as “remembered.” We may also provide you with the option to post additional information about your activities or information you have found through the Services to your profile on Facebook or other third-party website.

1. When You Provide a Testimonial

We display personal testimonials of satisfied customers on our Websites, marketing materials and in other places, in addition to other endorsements. We may post your testimonial along with your name and geographical information. If you wish to update or delete your testimonial associated with any of our Websites, please contact Customer Support through the applicable Website.

1. When You Use the Services

Log Files

As is the case with most standard website servers, we use and maintain the information that we obtain from and through your browser on our server logs. This information can include Internet protocol (IP) addresses, browser type, Internet service provider (“ISP”), the pages of our Services that your visit, the time and date of your visit, the time spent on those pages unique device identifiers and other diagnostic data. We may use this information to analyze trends, administer the Services, track user movement, detect fraud or other types of abuse, and gather broad demographic information for aggregate use. We may associate this information with your information to resolve technical issues, support security for our users, and take action on any activity that may violate this Privacy Policy or the Terms of Service.

Cookies

A cookie is a small piece of data that is sent to your browser from an email or a website’s computers and stored in a browser-related file on your computer or other device. Cookies are uniquely assigned to your computer or device and are read by a web server in the domain that issued the cookie to you. We link cookies to your unique registration number and use them to enhance and personalize your experience on the Services, including helping authenticate you when you use the Services, remembering your preferences and registration information, and customizing the content and advertisements provided to you via the Services. For example, storing a cookie on your computer or device allows you to login without typing the registered email address or registration number and password. We also use cookies to deliver information and content specific to your interests through the Services. We, our affiliates and brands, and our third-party advertising partners may also use cookies to target advertisements that you may view when visiting other websites. If you do not want these cookies stored on your computer or device you can delete and/or reject cookies by modifying your Internet browser setting accordingly (each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences). However, if you choose to delete and/or reject cookies, you may not be able to sign in or use certain portions of the Services. Please also note that certain types of emails available through the Services may automatically log you into the Services and/or set new cookies when you click on the links in the emails and that you may need to manually remove such cookies if you do not want them to be stored on your computer or device. We do not respond to or honor Do Not Track (DNT) signals.

Web Beacons

A web beacon (also known as a clear gif) is a tiny graphic with a unique identifier that is placed on a web page or within an email. It is similar in function to a cookie and is used to collect a limited set of information, such as a cookie number, time and date of page view, and a description of the page on which the web beacon resides. We and our third-party advertising partners may use web beacons to compile aggregate statistics about which advertisements and promotions users have seen and how users responded to them. This information helps us better manage content available on the Services by informing us about what content is effective and of interest to users. In addition, we may use web beacons in our promotional email messages to keep track of how many messages and which emails have been opened and acted upon. This use allows us to gauge the effectiveness of certain communications and our marketing campaigns. We associate web beacons with individual members for internal purposes only, in an effort to understand our members’ individual preferences with our email products.

Local Shared Objects

We use Local Shared Objects, such as HTML5, to store content information and preferences. Third parties with which we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

1. When You Purchase a Product or Paid Services from Us

If you choose to purchase a paid Services from us, you may be required to provide us with certain personal contact information, such as your name, email address and billing address. We may also require other information necessary for you to access the paid Services and/or process any applicable payment, such as a credit card or debit card number, card security code and expiration date. We may use the information that you provide to us to bill you for paid Services you request, or to notify you of additional paid Services we may offer. When you sign-up for a paid Services, you are consenting to our delivery of this information to our service providers, which may include banks and credit card companies that we use to process a transaction or other third parties who may provide all or a portion of the underlying paid Services on our behalf. See Section 2(d) below for additional information about sharing your information with our service providers.  We may also show your membership status through the Services so that other members can see what options they have to contact or communicate with you.

1. When You Use the Service

[Clarence, will this be the case?] The Service uses a “double-blind” email system, which hides the email addresses to protect the privacy of both the sender and receiver when a member sends another member an email through these Service. When using these member-to-member communications, it is up to you to choose when you are comfortable disclosing your email address, or any other personal contact information, to others. We respect the privacy of these member-to-member communications and do not read or disclose them unless we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Privacy Policy and/or our Terms of Service or as otherwise permitted or required under Section 2(f) below. Please keep in mind that you will not be able to delete, revise or otherwise recover any message that you send once it has been sent.

1. When You Use any of the Service’s Public Forums

Information and content submitted to comment fields, message boards, events and other public forums on the Services are displayed publicly, so please exercise care in deciding what information and content you wish to disclose. Because this information is publicly displayed through this Service, it may be included in the Service search tools and on third-party websites and devices as described in Section 2(g) below. Please keep in mind that, because of the interactive nature of these forums, in many cases you will not be able to remove or revise the information or content that you submit in these areas of the Service and such information or content may remain on the Service even if your membership is terminated. To protect the privacy of our members, we do not allow the public posting of personal contact information. We have the right, but not the obligation, to monitor any activity and content within the comment fields, message boards, events and other public forums on the Service. Please review our Terms of Service for more information regarding your appropriate use of these areas.

1. When You Use “Invite-A-Friend,” “Email this Page” or Other Email Referral Services

[Clarence will you have such a service?]If you elect to use any of our referral services for informing friends via email about the Service, you will be asked to provide your friends’ names and email address. We will then automatically send your friends a one-time email, plus a reminder email if you so choose (each of which will usually include your name and email address) inviting them to visit the Service. We ask for this information for the sole purpose of sending these emails and tracking the success of our email referral program.

1. When You Build a Personal Profile

We have created tools to enable you to build a personal profile to share as much information about yourself as you wish on the Service. Except as otherwise noted, when you use a specific profile tool all information that you add to your profile is publicly view able and may be included in the Service search tools, and on third-party websites and devices as described in Section 2 (h) below. For this reason, please use care in providing information that you may not want to publicly disclose. To protect the privacy of our members, we do not allow the public posting of personal contact information. Additionally, please see the Terms of Service for more information regarding the limitations on the types of information that you may post on your personal profile and elsewhere on the Service. As provided in our Terms of Service, we may use the information you provide in your profile in a variety of our products and features, such as affiliation-specific emails. This enables us to provide our members with information in a more personalized fashion. If you feel that a profile depicting you or your likeness has been created without your consent, please contact us to request its removal.

1. When You View Other Members’ Profiles

We give you the ability to find other members and view their personal profiles by browsing the affiliation lists, clicking on or hovering over a tagged name, using the search functionality on the Service, or otherwise providing a link on the Website or in an email that takes you to a member’s profile. If you view any portion of another Member’s profile, your name and the date of your visit will be accessible by that Member as someone who visited that Member’s profile unless you remove that specific visit or choose to opt out of having your name automatically left on other Members’ profiles, which you can do by accessing the “Account” section on the Website and changing your preferences[Clarence will this functionality be on the Website?]. If you opt out of automatically having your name left on other Members’ profiles, you will still have the ability to leave your name on specific Members’ profiles on an individual basis.

1. When You Participate in Surveys

From time-to-time we may request information from our users via surveys relating to the Service or on behalf of third-party advertisers. When you participate in a survey, we may request personal contact information (such as your name and email address) or demographic information (such as your zip code, age or income level). We conduct surveys relating to the Service in order to target advertising and content and to better understand Members’ needs and opinions. We may share, in aggregate form, information we collect from these surveys with our advertisers and the general public, but we will not share survey information containing personal information with any third party without your prior consent. Participation in these surveys is completely voluntary, such that you have the choice of whether you wish to disclose the requested information.

1. When You or Third Parties Contact Us

If you contact us by phone, email or letter, we may keep a record of such correspondence. Thus, if you report an issue with the Service, we may collect such information in a file specific to your account. Moreover, if you contact us through our feedback area, we require your name and email address in order to send you a reply. Additionally, if other users or third parties send us correspondence about your activities or postings on the Service, we may keep the information in a file specific to you.

1. How We May Supplement Your Information

In order for us to provide the best overall experience for you and other members of the Service, we may from time to time supplement the information we receive through your use of the Service with information from third-party resources. For example, we may obtain updated email address information or purchase third-party marketing data and address information and add it to our existing database to update or supplement your profile.

2. SHARING YOUR INFORMATION
3. Confidentiality

We only share your personal information with others when we have your permission or under the types of circumstances described in this Privacy Policy. In addition, we limit access to your personal information to only those employees who we believe reasonably need to come into contact with that information to provide products or the Service to you or to do their jobs.

1. Third-Party Advertising and Ad Servers/Networks

While using our Service, you may be presented with advertisements or offers from unaffiliated third parties. We may also use your information to provide you with third-party advertisements or offers that are targeted to your specific needs and interests. These advertisements link directly to third-party websites or services. If you decide to sign-up for or purchase a product or service from a third party, you are providing your information to that party and subjecting yourself to its policies and practices. We have no control over the content or privacy policies or practices of such websites or services, and therefore we encourage you to review such content and privacy policies and practices prior to submitting any personal information to them. We do not control these third parties and you agree that we are not liable for their acts or any failure to act on their part. We do share certain aggregate information, such as demographic information and the number of times that our members have viewed an advertisement, with our third-party advertisers. This information is not linked with any personal information, and we do not provide any such information to third-party advertisers except as otherwise noted in this Privacy Policy.

We may use aggregated, statistical information to describe our membership and to establish advertising and other business relationships with third parties.

We may serve you with targeted advertisements based on your personal information, but we do not provide any of your personal information to an advertiser or any third party with the exception of those uses expressly disclosed in this Privacy Policy. However, if you click an advertisement on the Service, then you consent to the possibility that the advertiser may assume that you meet the targeting criteria, if any, that we use to display such advertisement and, as described above, you will be subject to the advertiser’s privacy policy and information collection and use practices.

We may also allow other unaffiliated companies, called third-party ad servers or ad networks, to display advertisements containing cookies, pixels or web beacons on the Service. We may also share certain limited categories of information about you (such as your gender, age or geographic location), as well as other non-identifiable information (such as hashed identifiers or obfuscated user data), with these third parties to help them deliver more relevant advertisements through their ad networks, subject to their privacy policies. They may also collect information (such as your IP address, device ID, information about your browser or operating system, and depending on your device settings, your geographic location data, including GPS coordinates or similar information regarding the location of your mobile device) directly from your computer or device via the Website or email , combine the data we shared with them with information they have obtained from other sources, and place or recognize a unique cookie, pixel or web beacon on your computer, email or other device. Doing this allows them to recognize your computer or device each time they deliver an online advertisement, either on or off the Service. In this way, ad networks may compile information about where you, or others who are using your computer or device, saw their advertisements and determine which ads are clicked on. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you.

We have no control over these parties’ privacy policies or information collection and use practices.

1. Contests and Sweepstakes

We may run contests, sweepstakes and other promotions on the Service in which we may request entrants to provide personal information. In some cases, entrants may be required to answer survey questions about a range of topics. We use the information collected in the entry form to verify the entrant’s identity and age and to communicate with the entrant. We will not share any of the entrant’s personal information with any third party except to service providers (if any) as described below, as disclosed at the time of entry, if you are a contest winner, or as may be required by law. We may make information about entrants available in aggregated form to advertisers, partners and the general public or use it to supplement your profile.

1. Service Providers

We may use one or more third parties to provide specific services on our behalf, including sending emails to our members, conducting member surveys, processing transactions, providing all or a portion of an underlying product or Service on our behalf, or performing statistical analysis of the Service or data relating thereto. In these cases, we may provide your personal information to these service providers. However, these third parties are required to maintain the confidentiality of this information and are prohibited from retaining, sharing, storing or using this information for any other purposes.

1. Business Transitions

All of our rights and obligations under our Privacy Policy are freely assignable by us to any third party, in connection with a business transition, such as a merger, acquisition, liquidation or sale of all or a portion of its assets, our members’ personal information will, in most instances, be part of the assets transferred. Members may be notified of any such business transition via email and/or notice on the Service.

1. Legal Matters; Protection of Rights, Property and Interests; Safety

We may, without your consent, access and disclose your personal information, any communications sent or received by you, and any other information that we may have about you or your account: as may be permitted or required by law, regulation, rule or court order; pursuant to requests from governmental, regulatory or administrative agencies or law enforcement authorities; or to prevent, investigate, identify persons or organizations potentially involved in, or take any action regarding, suspected fraud, violations of our Privacy Policy and/or Terms of Service or activity that appears to us to be illegal, that may expose us to legal liability, or in order to protect our interests. Additionally, we may disclose your personal information in situations that we believe to be emergencies involving potential threats to the physical safety or any person or property if we believe that your personal information in any way relates to that threat.

1. Display of Information on Search Engines and Third-Party Websites and Devices

Any of your personal information that is publicly displayed on the Service may appear in the results of searches conducted on Internet search engines while you are a member of the Service and potentially for some time period after your membership is terminated, depending upon the search engine’s indexing practices. In addition, we may create applications or other tools for use on various third-party websites and devices, through which certain portions of your information that is publicly displayed on the Service may be shown to the users of those third-party websites or devices. If you do not wish to have your information displayed on these search engines or other third-party websites or devices, you can opt-out by removing your account from the applicable Service.

3. UPDATING OR REMOVING YOUR INFORMATION

We provide you with ways in which you can update your personal information. To make changes to such information as your name, birth date, mailing address, email address, password and payment information, please login to the Service and go to the “Account” or similar section on the Service. We also provide you with certain privacy settings, which can generally be accessed as described above or within specific features of these Service. In addition, you can go to your profile on the Service, where you can edit various pieces of information or content that you submitted to the Service. If you have questions about updating your information, please visit the Help section on the Service.

We will retain your personal information for as long as your membership is in place or as needed to provide you the Service. If you wish to have your membership canceled for any reason, please contact Customer Support.  Upon the cancellation of your membership, we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

4. COMMUNICATIONS FROM US

As a user of the Service, you will receive our customary business communications (e.g., emails, push notifications or other communications facilitating, completing or confirming your registration, upgrade or other transaction, providing you notice of new or updated products or features, alerting you to member-to-member communications or other member activity relating to your membership, or other administrative messages). We may also send certain “welcome” messages that are informational and provide useful details about your account or product usage instructions when you sign up for an account or begin using a particular service. In addition, upon registration you may be automatically enrolled in one or more of our regularly recurring email subscription programs. You may also choose to participate in other email subscription programs that we may make available to you. We also may send you communications regarding special offers or other promotional material for our Services or those of our advertisers. We may send all of these communications to the primary email address that you provide to us, any secondary email address that you may have provided to us if we have determined that your primary email address appears to no longer be valid or otherwise functioning properly, or any email address that we receive as described in Section 1(b) or 1(l). We may also send these communications to your inbox on the Service, if applicable.

While we reserve the right to send you our customary business communications, “welcome” messages and other transactional emails without offering you the opportunity to opt out of receiving them, we do provide you with the opportunity to select whether or not you wish to continue to receive our subscription-based or commercial emails. Each subscription-based email communication from us contains instructions on how you can remove yourself from the mailing list for that specific email subscription program, and each commercial email contains instructions on how you can opt out of receiving further commercial emails from us.

You can also update your email preferences by logging onto the account or similar section of the Service.

Please keep in mind that any changes that you make to your email preferences may take up to ten (10) business days to process and that each subscription-based email and all commercial emails have their own separate opt-out processes. If you have questions about changing your email preferences, please contact the Customer Support team of the Service.

5. THE SECURITY OF YOUR INFORMATION

We have instituted physical, electronic and procedural safeguards to store and maintain your personal information in a secure environment. For example, highly confidential information, such as a credit card or debit card number, is encrypted before being transmitted through the Service. You may also be required to use a password to access certain pages on the Service where certain types of your personal information can be changed or deleted. It is therefore important for you to protect against unauthorized access to your password, to emails which we may send you, and to your computer or other device. You take full responsibility for maintaining the confidentiality of your password. Furthermore, while we have implemented safeguards, you should be aware that Internet security technology rapidly changes. We cannot guarantee that the safeguards we employ today can protect your personal information from the threats of tomorrow. You should also be aware that despite our efforts, factors beyond our control may result in disclosure of your personal information. Accordingly, we are not in a position to guarantee that your information will be secure under all circumstances.

6. LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are from the European Economic Area (EEA), TermsFeed legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

TermsFeed may process your Personal Data because:

1. We need to perform a contract with you
2. You have given us permission to do so
3. The processing is in our legitimate interests and it’s not overridden by your rights
4. For payment processing purposes

1. To comply with the law

Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. TermsFeed aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. 

In certain circumstances, you have the following data protection rights:

1. The right to access, update or to delete the information we have on you.
2. The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
3. The right to object. You have the right to object to our processing of your Personal Data.
4. The right of restriction. You have the right to request that we restrict the processing of your personal information.
5. The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format.
6. The right to withdraw consent. You also have the right to withdraw your consent at any time where TermsFeed relied on your consent to process your personal information. 

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority in the EEA.

7. COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under 13.Minors (those under 13) are not eligible to use the Service, and we ask that minors not submit any personal information to us or use the Service. We will not knowingly collect information from minors or allow minors to become members of our Service. If we later learn that a minor is a member, then that minor’s account will be terminated. We do not knowingly publish information concerning anyone under the age of 13. If you know of information appearing in the Service concerning anyone under the age of 13, please contact us.

8. CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy from time to time as our information practices are modified or changed. If we make any material changes to this Privacy Policy, we will notify you here, by email (sent to the primary email address specified in your account), or by means of a notice on the Website. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have questions or complaints regarding this Privacy Policy or practices, please contact using the information provided on our Contact page.