Privacy Policy

Last modified: November 12, 2024

1. Introduction

Matrix Global LLC (“Company” or “we” or “us”), a Cook Islands company, respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the Company’s website NashvilleTimes.com (collectively “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to the information we collect:

On this Website.
Email, text, and other electronic messages between you and this Website.
Through desktop applications you download from this Website, you can have a dedicated non-browser-based interaction with this Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries) or
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Pr ivacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

2. Children Under the Age of 13

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA“) require us to inform parents and legal guardians (as used in this section, “parents“) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children“). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.

This section notifies parents of:

The types of information we may collect from children.
How we use the information we collect.
Our practices for disclosing that information.
Our practices for notifying and obtaining parents’ consent when we collect personal information from children include how a parent may revoke consent.
All operators that collect or maintain information from children through this Website.

This section only applies to children under the age of 13 and supplements the other provisions of this privacy policy. Only the other provisions of this privacy policy applies to teens and adults.

Information We Collect from Children

Children can access many parts of the Website and its content and use many of its features without providing us with personal information. However, some content and features are available only to registered users or require us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Website.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.

Automatic Information Collection and Tracking.

We use technology to automatically collect information from our users, including children when they access and navigate through the Website and use certain of its features. The information we collect through these technologies may include:

One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services.
Information that identifies a device’s location (geolocation information).

We may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.

For information about our automatic information collection practices, including how you can opt out of certain information collection, see the “Automatic Information Collection and Tracking” and “Choices About How We Use and Disclose Your Information” sections of this policy.

How We Use Your Child’s Information

We use the personal information we collect from your child to:

register him or her with the Website;
communicate with him or her about activities or features of the Website that may be of interest.

We use the information we collect automatically through technology (see Automatic Information Collection and Tracking) and other non-personal information we collect to improve our Website and to deliver a better and more personalized experience by enabling us to:

Estimate our audience size and usage patterns.
Store information about the child’s preferences, allowing us to customize the content according to individual interests.
Speed up your searches.

Our Practices for Disclosing Children’s Information

We do not share, sell, rent, or transfer children’s personal information other than as described in this section.

We may disclose aggregated information about many of our users, as well as information that does not identify any individual or device. In addition, we may disclose children’s personal information:

To third parties we use to support the internal operations of our Website and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
If we are required to do so by law or legal process, such as complying with any court order or subpoena or responding to any government or regulatory request,
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Matrix Global LLC, our customers or others, including to:

protect the safety of a child;
protect the safety and security of the Website; or
enable us to take precautions against liability.

To law enforcement agencies or for an investigation related to public safety.

In addition, if Matrix Global LLC is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

3. Personal Information We Collect About You

We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information

Specific Types of Personal Information Collected

Identifiers (e.g., name, postal address, email address, telephone number, and date of birth or other similar identifiers)

Name, e-mail, telephone number, and country of residence.

Information that identifies relates to, describes, or is capable of being associated with a particular individual, including, but not limited to, his or her name, signature, physical characteristics or description, address, and telephone number.

Not applicable.

Characteristics of protected classifications under California or federal law.

Not applicable.

Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Not applicable.

Biometric information

Not applicable.

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

Internet protocol (IP).

Geolocation data

Not applicable.

Audio, electronic, visual, thermal, olfactory, or similar information

Not applicable.

Professional or employment-related information

Not applicable.

Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)

Not applicable.

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Not applicable.

4. How Your Personal Information is Collected

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our Website. However, we may also collect information:

From publicly accessible sources (e.g., property records);
Directly from a third party (e.g., our business partners);
From a third party with your consent;
From cookies on our website; and
Via our IT systems, including:
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
- Information that you provide by filling in forms on our Website. This includes information provided when registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with our Website;
- Records and copies of your correspondence (including email addresses) if you contact us;
- Your responses to surveys that we might ask you to complete for research purposes;
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website; and
- Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on your computer’s hard drive. You may refuse to accept browser cookies by activating the appropriate settings on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

- Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Flash Cookies. Certain features of our Website may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information .

5. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

6. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information, products, or services you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account and/or subscription, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide though it.
This is to allow you to participate in interactive features on our website.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may also use your information to contact you about our own and third-party goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data or adjust your user preferences. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

Our reasons

To provide products and/or services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or Matrix Global LLC

For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you

Ensuring business policies are adhered to, e.g. policies covering security and internet use

For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

Updating and enhancing customer records

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of selected third parties to:

existing and former customers;
third parties who have previously expressed an interest in our services;
third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

7. Disclosure of Your Information

We may disclose aggregated information about our users and information that does not identify any individual without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Matrix Global LLC about our Website users is among the assets transferred.
To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use or Terms of Sale and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Matrix Global LLC, our customers, or others.

8. Personal Information We Sold or Disclosed for a Business Purpose

In the preceding 12 months, we have sold to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers); and
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement).

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers); and
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement).

9. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

Region-specific privacy terms

10. Brazil

This section pertains to individuals located in Brazil, in accordance with the “Lei Geral de Proteção de Dados” (LGPD).

Legal Basis: For residents of Brazil, we collect and process information only when we have legal grounds to do so under applicable laws. Details about the legal grounds we rely on when handling your Personal Information under LGPD are outlined in the “Information Use” section of our Privacy Policy.

Your Privacy Rights in Brazil: We assure you that exercising your rights will not result in discrimination. If you are a resident of Brazil, you have additional rights beyond those outlined in the “Your Rights” section of our Privacy Policy. These include the right to anonymization and access to information from public and private entities with whom we have shared your Personal Information.

11. PIPEDA (Personal Information Protection and Electronic Documents Act)

The Personal Information Protection and Electronic Documents Act (PIPEDA) is a Canadian law established in April 2000 to regulate the collection of consumer personal information by private sector organizations.

PIPEDA aims to enhance the security and protection of consumers’ personal information in the context of e-commerce and online business transactions.

To comply with PIPEDA, organizations must adhere to 10 fair information principles, including:

Accountability
Identifying purposes
Consent
Limiting collection of information
Limiting use, disclosure, and retention of information
Accuracy
Safeguards
Openness
Individual access
Challenging compliance

These principles empower individuals by providing transparency about the collection, use, and disclosure of their information, ensuring accuracy, implementing safeguards, and granting access to personal data.

Under PIPEDA, organizations must obtain consent before collecting, using, or disclosing user information. Additionally, individuals must receive products or services regardless of their consent to data collection.

According to the Office of the Privacy Commissioner of Canada, organizations found in breach of PIPEDA requirements must promptly notify relevant authorities. Failure to report breaches may result in fines of up to $100,000 per violation if the organization knowingly violated the legislation.

PIPEDA also mandates the inclusion of specific disclosures within a Privacy Policy. Therefore, businesses operating in Canada must ensure compliance with PIPEDA’s requirements.

12. Compliance with Australian Privacy Laws and Principles

Matrix Global LLC operates in accordance with the Privacy Act 1988 (Cth), the primary privacy legislation governing private sector organizations. The Act establishes national standards for the collection, use, and disclosure of Personal Information. It also introduced the Australian Privacy Principles (APPs), effective 12 March 2014, outlining key obligations regarding personal data.

The APPs govern personal information collection, use, and disclosure, giving individuals the right to access and correct their data. Additionally, specific provisions address direct marketing (APP 7) and cross-border disclosure of personal information (APP 8). More details about the APPs can be found on the Australian Government website at www.oaic.gov.au.

Our privacy policy aligns with the Australian Privacy Act and the Australian Privacy Principles. Key aspects of the APPs include:

APP 1: Entities must implement practices ensuring compliance with the APPs and publish their privacy policy.
APP 5: Entities must notify individuals of the collection of personal information at or before or as soon as practicable after the collection.
APP 7: Personal information cannot be used for direct marketing unless exceptions apply.
APP 8: Entities must take reasonable steps to prevent overseas recipients from breaching Australian Privacy Principles before disclosing personal information abroad.

Personal Information, as defined under the Act, encompasses any information or opinion about an identified or reasonably identifiable individual, regardless of its truthfulness or form of recording. This includes customer contact details, billing information, and transaction history.

We strictly adhere to the Australian Privacy Principles for all personal information collected from our customers and any other individuals. Specifically:

We only collect personal information from individuals who have registered for our services, handling unsolicited information according to the APPs and our Privacy Policy.

Personal information is used solely for the purposes outlined in our Privacy Policy, and disclosure is limited to third-party vendors necessary for service provision.

Where feasible, we provide customers with access to their personal information, delete requested data, and retain it only as necessary for service provision.

13. New Zealand’s Privacy Act (1993)

Introduction
The Privacy Act (1993) of New Zealand governs the collection, storage, use, and disclosure of personal information. This policy outlines our commitment to protecting the privacy of individuals and complying with the provisions set forth in the Privacy Act.

Compliance with the Privacy Act
We are committed to complying with all provisions of the Privacy Act (1993) and will regularly review and update our privacy practices to ensure ongoing compliance.

By using our services or providing us with your personal information, you consent to the collection, use, and disclosure of your personal information in accordance with this privacy policy and the provisions of the Privacy Act (1993) of New Zealand.

14. Transferring Your Personal Information Out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

With your and our service providers located outside the EEA;
If you are based outside the EEA; or
Where there is an international dimension to the services we are providing to you.

If you would like further information, please contact us.

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

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to be Forgotten

The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

at any time to your personal information being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

16. Your Rights Under the CCPA

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know:

The categories of personal information we have collected about you;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting or selling personal information;
The categories of third parties with whom we share personal information, if any; and
The specific pieces of personal information we have collected about you.
Please note that we are not required to:
Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
Provide the personal information to you more than twice in a 12-month period.

Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and

The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt out of the sale or disclosure of your personal information. If you exercise your right to opt out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: https://nashvilletimes.com/do-not-sell-my-information/

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Delete your personal information from our records; and
Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
Debug to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act;
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
Comply with an existing legal obligation; or
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

Deny goods or services to you;
Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Provide a different level or quality of goods or services to you; or
Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

17. Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, used, or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

18. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by checking the relevant box located on the form on which we collect your data. You can also always opt out by mailing us at Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands
Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt out by mailing us at Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by mailing us at Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

Residents of certain states in the United States of America, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

19. Accessing and Correcting Your Information

You may send mail to Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

20. Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please mail us at Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Data portability.
Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights, please send mail to Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands. To appeal a decision regarding a consumer rights request, please send mail to Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands

Nevada provides its residents with a limited right to opt out of certain personal information sales. Residents who wish to exercise this sale opt out rights may send mail to Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands

21. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website, such as message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

22. Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active, and deliverable email address for you and for periodically visiting our Website and this privacy policy to check for any changes.

23. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please:

Complete a data subject request form available on our website at ______;
Mail us at Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands.

Please note that you may only request a CCPA-related data access or portability disclosure twice within 12 months.

If you choose to contact us, you will need to provide us with:

Enough information to identify you;
Proof of your identity and address; and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or someone is authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

24. How to File a New Zealand’s Privacy Act (1993) Complaint

To file a complaint under New Zealand’s Privacy Act (1993), identify the specific violation, and then attempt informal resolution by contacting the organization involved. If informal resolution fails or is not feasible, prepare a formal complaint detailing the issue, including evidence, and submit it to the Office of the Privacy Commissioner (OPC) by mail. Be prepared to provide further information if needed during the OPC’s investigation. The OPC will work towards a resolution, which may involve mediation or formal determination by the Privacy Commissioner. If unsatisfied with the outcome, appeal options may exist through the Human Rights Review Tribunal. It’s essential to follow the OPC’s specific procedures and provide thorough documentation to support your complaint.

25. How to File an EEA Complaint

We hope that we resolve any query or concern you raise about our use of your information.

Filing a complaint under the European Economic Area (EEA), typically governed by the General Data Protection Regulation (GDPR), involves identifying a specific data protection violation and the relevant Data Protection Authority (DPA) within an EEA member state. Prepare a detailed complaint, including evidence, and submit it directly to the appropriate DPA, adhering to their submission guidelines. The DPA will investigate, potentially issuing warnings, fines, or corrective measures. Cooperate with the DPA and provide additional information as needed. Additionally, the GDPR grants the right to lodge a complaint with a supervisory authority in the EU or EEA state where you work, live, or where any alleged infringement occurred, ensuring adherence to the GDPR and relevant DPA procedures for effective resolution.

26. How to File an (LGPD) Complaint

To file a complaint under Brazil’s Lei Geral de Proteção de Dados (LGPD) regarding a privacy policy on a website, first attempt informal resolution by contacting the data controller responsible. If unsuccessful or unsatisfied, prepare a formal complaint detailing the alleged LGPD violation, including evidence, and submit it to the National Data Protection Authority (ANPD) through their website or by mail. Ensure to follow ANPD’s specific procedures. The ANPD will review and potentially investigate the complaint, and you may need to provide further information during this process. Once resolved, the ANPD will inform you of the outcome, which could involve warnings, fines, or corrective measures against the data controller. It’s essential to adhere to the LGPD and ANPD guidelines and provide comprehensive documentation to support your complaint for an effective resolution.

27. How to File an (LGPD) Complaint

To file a complaint under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), start by attempting an informal resolution with the organization involved; if unsuccessful or unsatisfactory, prepare a formal complaint detailing the alleged violation, including evidence, and submit it to the Office of the Privacy Commissioner of Canada (OPC) online, by mail, or email. Ensure to include all pertinent details and documentation. The OPC will review the complaint and may investigate further, requiring additional information if necessary. The OPC will inform you of the outcome upon resolution, which may involve mediation or formal determination by the Privacy Commissioner. Adherence to PIPEDA guidelines and providing comprehensive documentation are crucial for an effective complaint resolution process.

28. How to File an Australian Privacy Laws and Principles Complaint

To file a complaint under Australian Privacy Laws and Principles, start by attempting an informal resolution with the organization involved. If informal resolution fails or is unsatisfactory, prepare a formal complaint detailing the alleged violation, including evidence, and mail it to the Office of the Australian Information Commissioner (OAIC). Ensure all pertinent details and documentation are included. The OAIC will review the complaint and may investigate further, requiring additional information if necessary. Upon resolution, which may involve mediation or formal determination by the Commissioner, the OAIC will inform you of the outcome. Adhering to Australian privacy laws and providing comprehensive documentation are essential for an effective complaint resolution.

29. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands.