LAST UPDATED: NOVEMBER 20, 2021
This privacy policy (“Privacy Policy”) describes how AT Worthy Technology, Inc., its subsidiaries, affiliates, brands, and entities that it controls, (collectively, “AT Worthy,” “we,” or “us”) collect, use, disclose, and store Personal Data we obtain through your access and use of the websites, social media accounts, content, information, features, tools, resources, online offerings, applications, and other products and services produced, maintained, distributed, or provided by, AT Worthy Technology Inc., or affiliated with us, your interactions with us, and through our normal business activities (collectively, the “Services”). Our Services include your interactions with our websites, customer service representatives, and our other employees.
We will inform you about our substantive changes to this Privacy Policy and update the “Last Updated” date above. To the extent permitted by law, your continued interaction with us and the Services after the “Last Updated” date constitutes your acceptance of the amended Privacy Policy, which supersedes all previous versions.
Information We Collect and Use:
When we refer to “Personal Data,” we mean any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier.
We also collect general information (“Usage Data”) regarding your use of the Services. This Usage Data can refer to personal identifiers (such as IP address and device identifiers), demographic information, information about preferences, interests, search queries, and online activity (such as date and time of your access to the Services, referring URLs, and information about the usage of our Services). When Usage Data includes Personal Data, we treat the Personal Data as described by this Privacy Policy.
We directly and through third-parties collect information that you provide to us, from your use of the Services, and from other sources. The information that we collect and how we process it depends on how you use and access the Services and we combine all of the information we have about you so that we can analyze it and provide better Services to you. We collect information, including Personal Data, as follows:
Your Submissions to Us. Personal Data will be collected when you sign up for an online newsletter or contact us with a question or request. For example, if you submit a request to advertise with us, you may provide us with your personal identifiers (such as your name, email address, telephone number, and address), and professional and employment information (such as your company name). We use this information as necessary to respond to your request or inquiry and to provide and improve the Services and our products and services. We process this Personal Data as long as we have a legitimate interest or based on your consent.
Your Content Submissions. You may be able to submit content, such as images, videos and comments, which we may post on the Services. When you do so, we request your personal identifiers (such as name, email address, and social media page links), information about the video, and a link to your video. We receive any Personal Data in the videos or comments you submit to us, and we use it to respond to you and follow your instructions (such as to make it public on the Services). We process this Personal Data as long as we have a legitimate interest, based on your consent, and necessity for the performance of a contract with you. If, in addition to you, other persons are identifiable in the content, you are obliged to obtain consent from these persons to the publication of the content.
Your Geo-Location. “Geo-Location Data” is collected with your consent or inferred as you use the Services. Such information will include the location of the mobile device or computer used to access the Services derived from GPS or WiFi use, calculated based on your device’s IP Address, or the geographic information you provide to us (e.g., your city). We use this information to analyze the use of the Services, customize and improve the content for you on the Services, send you location-specific content, and show you events or businesses near you. We use and retain the Personal Data for as long as necessary and useful to provide personalized and improved services to you or until you withdraw consent.
Your Social Media Interactions. We receive Personal Data about you when you interact with us using the social media aspects to our Services (such as comment plug-ins), on our social media pages and channels, or on other channels and content. The Personal Data includes personal identifiers (such as your profile name and profile identifier) and the content of your submissions. We use this information to communicate with you and for internal analysis of visitors and content. We use and retain your Personal Data for these purposes until you withdraw consent or we do not use the social media pages anymore. Please review the privacy policies and settings of any websites, mobile applications, or social networks should you have any questions about their privacy practices.
Please bear in mind that any content (e.g., comments, photographs, information and other materials) that you post directly on our Services, including our social media pages, is public and can be read, collected or used by others. Please be cautious when disclosing any Personal Data through public activities or submissions.
Marketing and Other Informational Updates. With your consent and as otherwise permitted by law, we use your personal identifiers (such as email address) and other information we receive from and about you to contact you with information from us about our products and services and others’ products and services, provide special offers and promotions that may be of interest to you. You may withdraw your consent at any time by unsubscribing from such marketing communications. Withdrawing your consent will not affect the lawfulness of the processing before the withdrawal. We may also notify you periodically about important changes to the Services (such as a material changes to this Privacy Policy or notice of a security breach). Withdrawing consent from marketing communications does not affect our ability to send you these communications, such as those related to providing services to you or responding to your requests.
You may opt out from receiving marketing-related communications by either clicking on the unsubscribe link at the bottom of marketing-related emails we send you or by contacting us. We will process opt-out requests without undue delay.
We use and retain your Personal Data until you withdraw your consent or request that we delete your contact information.
Events, Contests and Sweepstakes. We request Personal Data, such as your personal identifiers (name and email address) and personal characteristics (such as date of birth) when you choose to participate in an event, contest, or sweepstakes. We use this information to determine eligibility, process your registration or entry, enforce the terms of the event, contest, or sweepstakes, and contact you about the event, contests, and sweepstakes you are participating in. We may also disclose the Personal Data to third parties or the public in connection with the event, contest, or sweepstakes, such as for winner selection and announcements and prize fulfillment, as stated in the official rules, and as otherwise required by law. We will retain your Personal Data for as long as this is necessary to conduct the contest, i.e. until all prizes have ultimately been distributed and possible accordant time limits for legal actions have lapsed.
Your Employment Applications. You may submit Personal Data to us through our career pages when you express interest in or apply for employment. We may receive your personal identifiers (such as name, email address, and telephone number) and professional, employment, and education information in your resume/CV and cover letter to us. You may also submit Personal Data to us using your social media account, such as LinkedIn. When you do this, we receive the Personal Data you permit LinkedIn to share with us based on your LinkedIn settings, such as your personal identifiers (including your email address and telephone number). We also receive your work experience, education, skills, and recommendation information. We use such information as a necessity to respond to your inquiry and contact you about employment and thus in preparation for the performance of a contract with you. If your application is successful, we retain the Personal Data for the duration of your employment with us, and beyond based on statutory retention periods. If we do not employ you we will delete your Personal Data when accordant time limits for legal actions have lapsed. For the purposes of this paragraph, “we” and “us”.
Automatic Usage Data Collection through Cookies and Similar Technologies. With your consent or as otherwise permitted by law, when you visit the Services (including our social media pages and channels) or open our emails, we and our service providers and trusted third parties, such as advertising networks, social media widgets, affiliate partners, and analytics providers, collect certain information, including Personal Data, by automated means, such as cookies, web beacons and web server logs. The information collected in this manner includes Usage Data, identifiers (IP address and device identifiers), and device characteristics (including browser characteristics, operating system version, language preferences). We use this information, for example, to determine how many users have visited a certain website and social media pages, social media channels, or opened messages or newsletters, to evaluate, improve, and provide the content we send you, evaluate and improve how the Services function, provide you with personalized content and advertising on and off the Services and in email, and to prevent fraud. Our Cookie Policy provides more information about our use of cookies and the retention of your Personal Data collected via cookies.
We may link this data with other information we have collected from and about you. Our service providers and trusted third parties also may collect and combine information collected on our Services and emails with other information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps also use the same vendors. Our service providers use the information only to provide their services to us. The trusted third parties use the information they collect according to their privacy policies and may use it for their own business and commercial purposes. You cannot opt out of service providers collecting and using this information, but you may opt out of certain third parties collecting this information directly from you and using the data for their own business purposes here. For example, we currently use Google Analytics to collect and process certain website usage data for the above purposes and to facilitate our use of other Google tools (e.g., Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting). To learn more about Google Analytics and how to opt out, please visit www.google.com/policies/privacy/partners/. You may be able to change browser settings to block and delete cookies when you access the Services through a web browser. However, if you do that, the Services may not work properly. The Services do not respond to browser do-not-track signals, but they do respond to browser cookie settings. You can learn how to decline or opt-out of cookies by reading our Cookie Policy. You may also learn more about our online advertising practices in the Online Advertising section below.
The processing of your Personal Data for this purpose is based on your consent or necessity to provide the Services to you. We retain the information as described below in this Privacy Policy.
Pseudonymization and Anonymization. In some circumstances, we pseudonymize and/or anonymize your Personal Data for business purposes including to improve our products and services, in which case we use such information without further notice to you. The processing of your Personal Data for this purpose is based on our legitimate interests to provide better products and services. We retain the Personal Data for as long as they are necessary and useful to improve our products and services.
Legal and Other Similar Uses. We process information, including your Personal Data, if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; comply with the law; enforce our Terms and Conditions; or protect your, our, or others’ rights, property, or safety. This processing is based on our legitimate interests in legal protection of our and others’ rights. We retain the Personal Data for as long as allowed or required by statutory laws.
How We Share Information:
We may share any of your Personal Data (listed above) for our business and commercial purposes and as more specifically described below.
We share Personal Data within AT Worthy (including our affiliates and subsidiaries) to fulfill our obligations to you and operate our business consistent with this Privacy Policy and applicable data protection law. In addition to what is already stated in this Privacy Policy, we will also share your Personal Data with others in the following situations and for the following purposes:
Service Providers. We share the Personal Data we collect with our service providers for the purposes described in this Privacy Policy, including so they can provide their services to us and you and to help us communicate with you about products and services, offers, events and promotions that we believe may be of interest to you. Unless stated in this Privacy Policy, our service providers are only permitted to access your information in connection with performing such services.
Trusted Third Parties. We share the Personal Data we collect with trusted third parties. In addition to providing us and you with their services, these third parties may use your information for their own business purposes. In some cases, you are using and directing us to intentionally disclose Personal Data (including personal identifiers) so you can receive their services. You cannot opt-out of this sharing. However, in other situations (e.g., certain marketing and advertising services) where you have not directed us to provide access to your Personal Data you may opt-out of our sharing of Personal Data with them by going here.
Enabling Services on the Site. We offer a variety of services and functions through the Services. Personal Data that is collected through the Services will be used and/or disclosed to third parties in order to enable us to provide the Services. For example, the Services allow you to interface with third-party websites, content, advertising, and features. To facilitate that interaction, we use your Personal Data and/or disclose your Personal Data to the third party operating the websites and features. When you use the services and functions, you are using and directing us to intentionally disclose Personal Data (including personal identifiers) so you can receive the services and functions. You cannot opt-out of this sharing.
Legal and Similar Disclosures. We may access, preserve, and disclose your information, if we believe doing so is required or appropriate to: comply with law enforcement requests and legal processes, such as a court order or subpoena; respond to your requests; comply with the law; enforce our Terms and Conditions; or protect your, our, or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed in connection with the negotiation of such transaction, and/or sold or transferred as part of such a transaction as permitted by law and/or contract.
Public Information. Please note that any information you include in a message you post to any comment box, chat room, forum or other public posting area is available to anyone with Internet access. If you do not want people to know your email address, for example, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.
Online Advertising:
We use industry-standard website tracking and delivery technology to serve you relevant advertising on and off the Services. With your consent, our Services display advertisements to you via targeted advertising methods. This permits us to show you certain advertising about products and services tailored to your individual interests based on information we receive from visitors of the Services and by third parties. You may also see certain ads through your use of the Services because we participate in advertising networks. We have selected ad networks to allow us to target our advertising to users through the use of click-stream, demographic, behavioral and contextual information. The use of third party tracking technologies to collect this information is often subject to their own privacy policies.
Our Cookie Policy provides more information about our use of cookies for tracking usage of the Services. You may opt-out of the collection of Personal Data on the Services by certain of these trusted third parties by going here. Some of the trusted third parties noted herein may be members of the Network Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA). For an explanation of that technology and how to control the tracking, the consumer awareness section of the DAA’s website (www.aboutads.info/consumers) provides a good overview. You may also use the DAA’s opt-out option available at http://www.aboutads.info/choices/. For more information about targeted advertising and the opt-out procedures of NAI members, see http://www.networkadvertising.org/choices/.
Third Party Content, Widgets, and Links to Third Party Sites:
The Services may contain, or link to, content that is hosted and served by third parties, which may include third party widgets (such as those that allow you to share content with third party web sites and online services), functionality, and content. Our Services may also contain links to other third party websites that we do not control. These third parties may collect information about you through the use of their own cookies and web beacons, may independently collect data or solicit Personal Data, and may or may not have their own published privacy policies. We are not responsible for the privacy practices employed by any third party. When you use the widgets, functionality, and content, you are using and directing us to intentionally disclose Personal Data (including personal identifiers) so you can receive the services and functions. You cannot opt-out of this sharing.
Where Personal Data Is Used and Stored:
We operate the services in the United States. Therefore, if you provide us with Personal Data during your use of the Services, we collect, process, and store that information in the United States. We may also transfer that information to our affiliates and subsidiaries or to other third parties, across borders to other countries or jurisdictions around the world. If you are visiting from the European Economic Area or other regions with laws governing data collection and use that may differ from U.S. law, please note that you may be transferring your Personal Data to the United States, which does not have the same data protection laws as the EU or other countries.
We maintain appropriate safeguards to properly protect Personal Data concerning you when it is transferred to the United States. These safeguards are set forth in internal policies that include EU-approved standard contractual clauses that include EU-equivalent data subject rights and remedies. For more information about our data transfer safeguards, please send a request to info ( at ) atworthy ( dot ) com
Privacy Rights:
Certain jurisdictions have specific legal requirements and grant privacy rights with respect to Personal Data, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete Personal Data we have about you, or to consent or withdraw consent to certain uses or sharing of Personal Data. You may be able to use the Services to access and update the information that you have provided to us.
When you make a request, we may require that you provide information and follow procedures so that we can verify a request you make and your jurisdiction before responding to it. The verification steps we take may differ depending on your jurisdiction and the request. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.
We will respond to your request within the time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event.
California Notice and Privacy Rights
As stated elsewhere in this privacy policy, we do not share Personal Data with third parties for their direct marketing purposes, as defined by California Civil Code Section 1798.83, unless we give you choice (opt-in or opt-out) before sharing with those third parties.
If you are a California resident, you may be entitled to additional rights with respect to your personal information pursuant to the California Consumer Privacy Act (CCPA). For more information about these rights and how to exercise them, please see our California Privacy Notice here, which is hereby incorporated by reference into this Privacy Policy.
EU Notice and Rights
While we take various steps to ensure the accuracy and completeness of your Personal Data, we rely upon you to provide accurate and complete Personal Data when interacting with us. You may also have the legal right, for example if you are using the Services from the EU, to request:
– Obtain from us confirmation as to whether or not we process Personal Data from you and, where that is the case, access to your Personal Data;
– Rectification of inaccurate Personal Data;
– Erasure of Personal Data;
– Objection to the processing of Personal Data;
– Restriction of processing of Personal Data; and
– Portability of Personal Data – receive the Personal Data you have provided to us in a structured, commonly used and machine-readable form and transmit those data it to another entity.
Also, where our processing of your Personal Data is based on your consent, you may withdraw consent at any time for the future. Please note that withdrawing your consent will not affect the lawfulness of the processing before the withdrawal.
Any such requests should be submitted by email to info ( at ) atworthy ( dot ) com
Please see for additional information: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
If you are using the Services from the EU, you also have the right to lodge a complaint with an EU supervisory authority if you do not think we are handling your Personal Data in compliance with applicable law. However, if you have a complaint regarding the processing of your Personal Data we kindly request that you first contact us directly by sending us an email at info ( at ) atworthy ( dot ) com, and we will reply promptly.
How Long We Keep Your Personal Data:
We consider several factors to determine how long we keep Personal Data. We consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Once we no longer have a need for your Personal Data, we will securely destroy it in accordance with our standards and applicable laws and regulations.
We will attempt to honor requests to delete your Personal Data, but please note that we may be required to keep such information for legal purposes and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.
How We Protect Personal Data:
We maintain administrative, technical and physical safeguards designed to assist us in protecting the Personal Data we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We also limit access to Personal Data about you to employees or service providers who we believe reasonably need to come into contact with that Personal Data to provide products or services to you or in order to do their jobs.
While we implement these and other security measures on our Services, please note that 100% security is not always possible. We cannot guarantee that the security measures we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be sufficient or effective.
Children’s Privacy:
We especially care about the privacy of young children. Accordingly, we do not direct our websites to children under the age of sixteen or knowingly collect Personal Data from them. If we learn that a user is under sixteen years of age, we will promptly delete any Personal Data that the individual has provided to us.
Enforcement and More Information
When AT Worthy receives formal written inquiries or complaints, we will contact the individual regarding his/her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the handling of Personal Data that cannot be resolved between AT Worthy and an individual.
Changes to this Privacy Policy:
Without prejudice to your rights under applicable law, this Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will notify you of changes to our Privacy Policy in advance by posting the new Privacy Policy here and updating the “Last Updated” date above.
How to Contact Us:
If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by email at info ( at ) atworthy ( dot ) com The Data Controller for the Services is the organization listed below. You may write to us at:
AT Worthy Technology, Inc.
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