GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Barra gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally-Identifying Information, it may be possible for Barra to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Barra analyzes Non-Personally-Identifying Information gathered from users of the Website to help Barra better understand how the Website is being used. By identifying patterns and trends in usage, Barra is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. Non-Personally-Identifying Information
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Barra may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique Barra may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.
We may use third-party vendors, including Google, that use first-party cookies and third-party cookies together to inform, optimize and serve ads based on your past activity on the Website, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/)and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads).
Mobile Device. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
Push Notifications. We may send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally-Identifying Information you submit within the mobile application.
We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Barra may collect a range of Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by Barra about users is information provided by users themselves when (1) registering for our service, including employee, student and parent/family portals, (2) logging in with social network credentials, (3) participating in polls, contests, surveys or other features of our service, or responding to service offerings, (4) communicating with us, (5) creating a public profile or (6) signing up to receive newsletters or other notices. That information may include, but may not be limited to, each user’s name, address, email address and telephone number. We also may request information about your interests and activities, age, date of birth, hometown and other demographic or relevant information as determined by Barra from time to time. Users of the Website are under no obligation to provide Barra with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
Certain Personally-Identifying Information collected from users may be disclosed as a matter of course as a result of your use of the Website. We may provide areas on the Website where you can post comments and other information relating to your activities on the Website. Such postings are governed by our Terms of Service. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.
We may use your name, email address and/or other contact information that you provide to us, to send you notifications regarding services offered by the Barra or the Website that you request, or that we think you may find valuable. Generally, you may opt out of such communications at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, or notices that we deem of importance, even if you opt out of all voluntary email notifications.
Barra will disclose Personally-Identifying Information under the following circumstances:
By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose Personally-Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Barra, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Service or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
Third-Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include providing customer service, supporting the Website’s functionality and supporting educational events, notifications, surveys and other features offered through the Website.
COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.
We are dedicated to protecting all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.
We reserve the right to use any and all Non-Personally-Identifying Information and Personally-Identifying Information that we collect to ensure the safety, security and integrity of the Website.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.