SECTION 1 – TYPES OF INFORMATION COLLECTED AND HOW WE COLLECT THEM
Personal Information You Provide:
We collect the following personal information you provide when you use our Services, like when you sign up for an account, request a transaction, enroll in a promotion, contest or program, or otherwise engage or communicate with us:
- Identity and Contact Data includes your full name,
your email address, mailing address, and telephone numbers.
- Financial Data includes your payment card data or other payment method data if you win a prize in one of our contests and we transfer payment to your designated financial account electronically.
- Profile Data includes your username and password, purchases or orders made by you, your knowledge assessment results, your virtual trading data created when you use the Service, and your interests, preferences, feedback, and survey responses.
- Usage Information includes information about how you access and use our Services, such as your actions on the Services, including your interactions with others on the Services, photos or media you upload to the Services, your username, and other content you provide (“Usage Information”). We only access your device camera roll and camera with your permission. If you need to update your permissions, you can do so in your device’s settings. Please remember that Meritas may, but has no obligation to, monitor, record, and store Usage Information in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, to protect and defend our rights and property, to better understand and improve our users’ experience with the Services, or for other reasons relating to our provision of the Services. By using the Services, you consent to the recording, storage, and disclosure of such information you send or receive for these purposes.
- Contact List Information With your permission, we may access your contact list on your mobile device or in your email accounts so that you can identify your contacts on the Services and direct the invitation of your contacts. We store and use this information to suggest referrals or connections and for other reasons related to our provision of the Services. We make these recommendations based on your contact list information as well as, with their consent, your contacts’ information if they are also a Meritas customer. We only access your contact list information with your explicit permission. If you provide us with personal data from your third-party contacts, it is your responsibility to ensure that the communication of such data to, and further processing by, Meritas is lawful. For example, when you provide us with information about your contacts, we may use it to let you know which of your contacts have also signed up for our Services or, at your exclusive direction, send messages to your contacts regarding our Services. We will not send messages to your contacts that are not explicitly directed by you.
- Additional Information includes information that you submit via email, text, focus groups, contests/sweepstakes, customer support, or other similar means. We may also collect any communications between Meritas and you (including recording calls made to or by Meritas) and any other information you provide to Meritas.
Personal information collected automatically:
As is true of many digital platforms, we collect certain personal information automatically when you visit our online services, including:
- Usage and Device Data Collected Automatically Through Tracking Technologies.
Tracking Technologies. To provide a personalized and enhanced user experience, we, and our third-party partners, automatically collect certain types of usage information when you visit or use our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location identifying technologies, file information, and similar technology (collectively, “Tracking Technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), and other similar information. We use Tracking Technologies to help ensure that you have a high-quality experience on our Services. We also use Tracking Technologies to aid in the targeted advertising of our services on other platforms. From your device manufacturer, we also may collect the names of other third-party applications that you have downloaded on your device.
If you prefer, you can manage Tracking Technologies through by using the cookie and privacy settings on your browser or mobile device. Some browsers have options that allow the user to control whether the browser will accept cookies, reject cookies, or notify the user each time a cookie is sent. You may elect to reject cookies by adjusting your settings, but doing so will limit the range of features available to you on our Services and other websites. Be sure to read any information provided by your browser developer to understand the limitations of these settings, as they may differ from browser to browser and may not apply to all technologies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email, used our Services, or performed certain functions with it. Our Services also occasionally use “local shared objects” (also known as “Flash cookies”). Like browser cookies, Flash cookies may be used for coordinating content delivery, website functionality, maintaining preferences, advertising, or analytics. Unlike browser cookies, “Flash cookies” are not stored in the browser. You may be able to manage these Flash cookies by visiting the Adobe website here. [Add link] Additional information on how to manage cookies and other tracking devices is available at www.allaboutcookies.org.
Do-Not-Track Signals and Similar Mechanisms. Some web browsers transmit “do-not-track” signals to websites. We currently don’t take action in response to these signals.
Personal Information from Other Sources and Third Parties:
We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.
- Third-party Data includes data that we collect from business partners, marketing, and vendor partners.
- Third Party Services. If you link, connect, or log in to your Meritas Account with a third-party service (e.g. Google, Apple, Facebook, Instagram, LinkedIn), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Publicly Available Data includes contact information, employment-related information, and other information from publicly available sources. We may combine this information with the information we collect from you directly. We use this information to contact you, to send you advertising or promotional materials, to personalize our Services, and to better understand the demographics of our users.
SECTION 2 – HOW WE USE YOUR INFORMATION
- Create and process your account and deliver the Services to you, including to allow you to register for the Services and participate in interactive features and for Meritas to authenticate your identity, handle account management and any payments related to your account, fulfill our legal and regulatory obligations [and complete other administrative matters;
- Send you transactional information related to your virtual portfolio, including confirmations, technical notices, product and services information and announcements, software updates, security alerts, support and administrative messages, and information about your transactions on the Service;
- Communicate with you such as to respond to your comments and questions, deliver newsletters or other content we believe you will be interested in, provide customer service or feedback, conduct surveys, respond to your inquiries about job listings posted on our jobs board, notify you about upcoming events, or for any other purposes in connection with the Services;
- Conduct research and analytics to understand our visitors and account holders and tailor our product offerings;
- Provide you with updates about products and services offered by us and selected partners, as well as facilitate new contests, sweepstakes, promotions, and rewards;
- Make suggestions and recommendations to you about things that are similar to those about which you have inquired or that may otherwise be of interest to you, such as providing you with advertisements based on your interests and activity on the Services;
- Monitor, administer, and enhance our Services, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
- Enhance the safety and security of our Services, business, and users, and investigate or provide notice of fraud, misuse of the Services, or unlawful or criminal activity;
- Perform audits and protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements; and
- Comply with applicable laws and legal obligations.
SECTION 3 – DISCLOSURES OF PERSONAL INFORMATION
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the personal information we collect. We may share your personal information in the instances described below. For further information on your choices regarding your personal information, see the “Control Over Your Information” section below. We do not sell or rent your personal information to third parties, aside from substantial corporate transactions (described below).
- Authorized third-party vendors and service providers. We share personal data with certain authorized and vetted contractors, subcontractors, third-party vendors, and service providers who help us run and protect our business. This includes sending emails, conducting business analytics, marketing, and data processing. For example, we may share personal data with service providers that identify and serve targeted advertisements or provide mailing services, contest fulfillment, web hosting, or analytics services. We may share with some vendors anonymized or aggregated data representing trends and patterns that we observe in the trading activity on the Service. We require such vendors and service providers to protect the confidentiality of information we share with them and to use this information only as permitted in our agreements with them.
- Companies on our job board in which you have expressed an interest. Meritas may provide your name and contact information to requesting companies in which you have expressly indicated an interest.
- Substantial corporate transactions. We may share personal data in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, reorganization, financing, change or control or acquisition of all or a portion of our business by another company or third party, sale of all or substantially all of the company’s assets, initial public offering, or in the unlikely event of bankruptcy or similar proceeding.
- Legal purposes. We disclose personal data to respond to subpoenas, court orders, legal process, law-enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, and security of Meritas, our affiliates, users, or the public.
- With your consent. We share personal data for any other purposes disclosed to you with your consent. We may also share information with others without your consent when the information shared is in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
SECTION 4 – THIRD-PARTY LINKS
Some of the Services may contain links to content maintained by third parties. We don’t control the content or services provided by or through such third party links and are not responsible for the privacy practices of these third parties or the content on the third-party services, and the information practices of these third parties are not covered by this Policy. Please note that these third-party services have their own privacy policies, and we strongly recommend that you read their privacy policies as well as terms and conditions of use to understand how they collect, use, and share your information.
SECTION 5 – THIRD-PARTY TRACKING AND ONLINE ADVERTISING
We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our Services over time so that they may play or display ads on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar Tracking Technologies. For advertising, we may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online on other platforms more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
We’re not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Policy. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please visit http://www.networkadvertising.org/choices or the DAA’s resources, available at http://www.aboutads.info/choices. You may also be able to set your browser to delete or notify you of cookies by actively managing the settings on your browser or mobile device. Please note that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again. You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt out of interest based ads” (Android).
Google Analytics and Advertising. We use Google Analytics and similar services to recognize you and link your devices and when you use our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the Services. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, see “How Google uses data when you use our partners’ sites or apps” linked here: http://www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On, here: https://tools.google.com/dlpage/gaoptout/. We may also use certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features let us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your use of our Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
SECTION 6 – CONTROL OVER YOUR INFORMATION
Account profile. You may update or correct the account profile information that you have provided to us by logging into your account. You may delete this account profile information, but if you do so we will no longer be able to support your account or your use of the Service and Content.
Access to your device data. You may control the mobile app’s access to your device information in your device’s settings. For instance, you can withdraw permission for the app to access your contact list or photo gallery.
How to control your communications preferences.
Emails. You can stop receiving promotional emails from us by clicking on the provided “unsubscribe” link. You may not opt out of service-related or other non-promotional communications (e.g., account verification, transactional communications, changes/updates to features of the Services, and technical and security notices).
Texts. We will send you marketing text messages only if you have given us your prior express written consent on our websites, apps, or otherwise. If you no longer wish to receive text messages from us, you should reply STOP to any text we send to you or contact us at privacy@Meritas.com.
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
SECTION 7 – NOTICE TO CALIFORNIA RESIDENTS
This section provides additional details about the personal information we collect about California residents and the rights afforded to them under the California “Shine the Light” law.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is no longer publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.
SECTION 8 – TRANSFER AND RETENTION OF PERSONAL INFORMATION
Our Services are currently designed for use only in certain select markets. If you are using our Services from a jurisdiction outside the United States, your information collected through our Services may be stored and processed in the United States or any other country in which Meritas or its parent, subsidiaries, affiliates, or service providers maintain facilities or conduct business activities. If you are located in other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data-protection laws as your jurisdiction.
We will retain your information only for as long as reasonably necessary for us to make the Services and Content available to you, subject to applicable legal requirements, the duration of your use of the Services, and as necessary for the protection of our legal interests. Following any retention of your personal information after the closing of your Meritas Account, we will permanently delete such information except as we may need to retain it to defend our legal interests or comply with applicable law.
SECTION 9 – CHILDREN’S PRIVACY
We do not knowingly collect or solicit any information from anyone under the age of 13 on these Services. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 13, please contact us at privacy@MeritasTech.com.
SECTION 10 – SECURITY
We employ reasonable and appropriate measures to assist us in protecting your personal information. These safeguards help us to prevent fraud and unauthorized access to personal information, as well as maintain data accuracy. However, as with all online services, we cannot guarantee absolute security of your information.
SECTION 11 – CHANGES TO THIS POLICY
SECTION 12 – HOW TO CONTACT US
Meritas Technology, Attn: Privacy Coordinator
208 E 51st St
New York, New York 10022.