FreeYourID made the following changes to its online Privacy Statement: Reorganized discussion of cookies for greater clarity in the reasons that FreeYourID uses them; modified language regarding collection and use of unidentified user visits to FreeYourID websites and use of cookies and other tracking technologies, such as in retargeted advertising; added more clarification regarding when and how we use cookies; provided better clarity regarding retention of personal information; indicated FreeYourID’s EU/Swiss Safe Harbor certification; changed the company’s address in two instances
Version 2.3 - Effective May 8, 2012
FreeYourID is committed to providing you with excellent service for all of our products and services. Because we respect your right to privacy, we have developed this Privacy Statement to inform you about our privacy practices for the entire FreeYourIDinc.com site and about special privacy practices related to our Safe Harbor Participation. This Privacy Statement is not applicable to any of our other privacy practices, including—without limitation—data collected from other FreeYourID sites (unless these sites direct the user to this Privacy Statement), FreeYourID.com (a website that is not controlled by FreeYourID, Inc.) or offline.
FreeYourID has been awarded TRUSTe's Privacy Seal, signifying that this Privacy Statement and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements, including transparency, accountability, and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our Privacy Statement or practices, please . If you are not satisfied with our response you can also contact TRUSTe. In addition, if you have questions regarding this Privacy Statement, you can . Please specify "Privacy Statement" in the subject line of your email. You may also call us at .
FreeYourID adheres to the EU Safe Harbor Privacy Principles with respect to certain personal data that it receives about European Union residents in the course of providing certain services. Information about FreeYourID's participation in Safe Harbor can be found in the section below entitled "Safe Harbor Participation."
FreeYourID has agreed to disclose its privacy practices and have them reviewed and audited for compliance by TRUSTe. Members of the TRUSTe Privacy Program agree to adhere to TRUSTe's established privacy principles of disclosure, choice, access, and security. Members of the TRUSTe Privacy Program also agree to comply with ongoing TRUSTe oversight and its alternative dispute resolution process. In keeping with TRUSTe's Privacy Program, this Privacy Statement will inform you of:
Privacy is of great concern to most users of the Internet and is a critical part of an enjoyable and satisfactory user experience. We at FreeYourID are acutely aware of and sensitive to the privacy concerns of our subscribers and other visitors to our web site. You should be assured that we do not provide personal information about our customers or site visitors to vendors that are not involved in the provision of FreeYourID's services.
This Privacy Statement applies to the FreeYourIDinc.com site or any other site in which it is expressly displayed. Please note that our site contains links to other sites. FreeYourID is not responsible for the privacy practices, privacy statements, or content regarding these other sites that do not include this Privacy Statement.
FreeYourID supports TRUSTe's comprehensive assurance process. In order to ensure compliance with its Privacy Program, TRUSTe monitors our site by conducting initial and periodic reviews and "seeding" (tracking unique identifiers in our site's database). TRUSTe also relies on online users to report violations of posted privacy statements or specific privacy concerns. If a TRUSTe participant is suspected of not conforming to the TRUSTe principles, TRUSTe will investigate the issue, which could result in penalties, additional audits, or revocation of the participant's right to use the TRUSTe trustmark. Extreme violations may even be escalated to the Federal Trade Commission (FTC). These enforcement measures are intended to provide some trusted assurances that you can rely on in this Privacy Statement. For more information on the TRUSTe assurance process, see TRUSTe's web site. If you feel that we are violating this Privacy Statement, please . Please specify "Privacy Statement" in the subject line of your email. You may also call us at . If you feel that we do not provide you with an appropriate response, you may file a report with TRUSTe.
There are a few ways in which you may explicitly and intentionally provide us with and consent to our collection of certain personal information:
Email Request for Information or Registrations for Guides or Seminars. We use links throughout our site to provide you with the opportunity to contact us via email to ask questions, request information and materials, register or sign up for guides or seminars, or provide comments and suggestions. You may also be offered the opportunity to have one of our representatives contact you personally to provide additional information about our products or services. To do so, we may request additional personal information from you, such as your name and telephone number, to help us satisfy your request.
Enrollment. If you choose to enroll for one of our products or services, we will request certain information from you. Depending on the type of product or service that you request, you may be asked to provide different personal information. For certain products and services, we may require your name, address, telephone number, email address, credit card number, bank account information, IP address, and/or Social Security number. Other products and services may require different or supplemental information from you in order to apply. For a detailed listing of the type of personal information requested for our various products, please refer to the enrollment page for the particular product or service.
We use "cookies" and other statistical and tracking technologies as described in this Section. A cookie is a piece of information that our web site sends to your browser, which then stores this information on your system. Other statistical and tracking technologies, such as web beacons, clear gifs, HTTP headers, also work in ways that collect information about your visit and use of FreeYourID's websites. We use these technologies in four ways:
To provide a service: A cookie may be used to provide you with a specific service. For instance, if you request our site to remember your login password or remember your profile in a response to a blog post, we deposit a cookie on your computer to facilitate that service. If you are logging into an access-controlled section of our site, we set a temporary session cookie to establish that you have been authenticated. The information contained in these cookies consists of random data that is used by the server to authenticate the browser requests to the server for that particular session. These cookies do not include any type of personally identifiable information. This bit of information is erased when you close your current browser window. If you choose not to accept a temporary cookie, you will not be able to navigate in these online applications.
We also use a cookie for when you visit our web site and request documentation or a response from us. When you are filling out a form, you may be given the option of having our Web site deliver a cookie to your local hard drive. You might choose to receive this type of cookie in order to save time in filling out forms and/or revisiting our web site. We only send this type of cookie to your browser when you have clicked on the box labeled "Please remember my information" or another box with an equivalent content when submitting information or communicating with us.
To facilitate website use: If a cookie is used, our web site will be able to remember information about your preferences and movement either until you exit your current browser window (if the cookie is temporary) or until you disable or delete the cookie. For instance, we may deposit a cookie to remember which of FreeYourID’s regional websites you have selected to access. Many users prefer to use cookies in order to help them navigate a web site as seamlessly as possible. You should be aware that cookies are not able to "invade" your hard drive and return to the sender personal information from your computer. If you are accessing our services through one of our online applications our Web server may automatically send your browser a temporary cookie, which is used to help your browser navigate our site. The information contained in these temporary cookies is a direction value that lets our software determine which page to show when you hit the back button in your browser. This bit of information is erased when you close your current browser window.
To understand our visitors: When you visit our site, our computers may automatically collect statistics in aggregate about visitor behavior. We may monitor statistics and other data such as how many people visit our site, the user's IP address, which pages people visit, from which domains our visitors come, which browsers people use and how they move about our website. We use this data about your visit for aggregation purposes only. These statistics are used to help us to understand our visitors’ interests and improve the content and performance of our web site. If you come to our site from one of our business partners, our Web server may also send your browser a temporary cookie that reflects an origination code for that business partner. We use this information for statistical and marketing purposes.
We also use a cookie when we track traffic patterns on our site. Analysis of the collected information by our tracking technologies allows us to improve our web site and the user experience. In both instances of a persistent cookie, if you choose not to accept the cookie, you will still be able to use our web site. Even if you choose to receive this type of cookie, you can always set your browser to notify you when you receive any cookie, giving you the chance to decide whether to accept it in each situation in which one is sent. We may supplement this unidentified user data with other data to better understand our users. For instance, we may relate a user’s IP address to the company to which it relates to better understand our visitors’ interests.
To advertise: We may tailor our advertisements to certain users based on the unidentified user data and related information. Also, we may receive information on unidentified users’ movements on other websites to tailor advertisements to them on our website and, likewise, provide unidentified user information to service providers, such as an ad agency, who places our advertisements on other websites to market to these users that visit them. You can opt out of this tracking by accessing the link below. You will need to invoke these opt-out procedures on each computer you use. If you opt out, you may still see FreeYourID advertisements on other websites you visit, but these ads are not user specific and are not placed because of your past website use. We will use commercially reasonable means not to set advertising cookies on the computers of users who appear to be located in the European Union and Switzerland at the time you access our website.
To opt out of this advertising from AdRoll, access the following link:
http://info.evidon.com/pub_info/573?v=1&nt=1&nw=true
To opt out of this advertising from DoubleClick, access the following link:
https://www.google.com
All major Internet browsers allow you to control cookies. You can learn more about adjusting browser controls at the following site. (Note that FreeYourID does not control this site and is not responsible for its contents. It is provided as information only. For the most current browser-specific information, please consult your browser’s manufacturer.)
http://www.aboutcookies.org
We may use both temporary and permanent cookies based on the cookie’s purpose. A permanent cookie remains on your system, although you can always delete or disable it through your browser preferences.
Third-party social media buttons displayed on our websites may record your IP address, browser type and language, access time and referring Web site addresses. When you are logged in to those social media sites, they also may link this collected information with your profile information on that site. We do not control these third party tracking technologies.
If you respond in a blog forum on this Web site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these blog forums, and could be used to send you unsolicited messages. FreeYourID is not responsible for the personally identifiable information you choose to submit in these forums. You are also responsible for using these forums in a manner consistent with the Rules of Engagement or other terms and conditions set forth on the relevant forum site.
We assure you that the personal information we gather from you is used by us only as explained below.
A. Sending You Responses and Updates
We generally respond to any email questions, requests for product or service information, and other inquiries that we receive. We may also retain this correspondence to improve our products, services, and web site and for other disclosed purposes. Frequently we retain contact information so that we can send individuals updates or other important information about our services and products. Occasionally these updates or other important information may be sent out by third parties on our behalf. Please be assured that any third party who contacts you in this capacity has executed a confidentiality agreement with us that contains a provision ensuring the privacy and security of any transferred information and limits the third party's use of the shared information to sending updates or providing services on our behalf. Our subsidiary companies may also send you information about their services and products. In situations where you have supplied your information in connection with a question or request for information about a product or service offered by a FreeYourID business partner, we may also send the information you have supplied to the FreeYourID business partners that offer such products or services. Please be assured that these FreeYourID business partners have agreed to ensure the privacy and security of any transferred information and may only use the shared information to send you information about products or services about which you asked.
B. Facilitating the Support, Renewal, and Purchase of Our Products and Services
We may use the information you submit to contact you to discuss the support, renewal, and purchase of our products and services. We may provide our subsidiary companies with your information so that they may send you information about their services and products. We may also provide the information you have submitted to us to a FreeYourID subsidiary, business partner, or independent reseller (either within or outside the United States) so that the subsidiary, business partner, or independent reseller can contact you and facilitate the support, renewal, and purchase of FreeYourID products and services. You may receive a communication directly from one of our subsidiaries, business partners, or independent resellers. Please be assured that any subsidiary, business partner, or independent reseller who contacts you for one of these purposes has agreed to use the information we supply only in accordance with a confidentiality agreement. To find out the names and locations of the subsidiaries, business partners, and/or independent resellers to whom we have provided your information, please contact us at the address given at the end of this Privacy Statement.
C. Disclosure by Law and Protection of FreeYourID and Others
If we are required by law to disclose certain information to local, state, federal, national, or international government or law enforcement authorities, we will do so (for example, we may disclose the identity of purchasers of certain software products to the U.S. Department of Commerce, Bureau of Export Administration, as required under the terms of our export licenses). We will also disclose information to third parties as necessary in order to comply with applicable laws and regulations. In addition, FreeYourID may share information in order to investigate, prevent, or take action regarding illegal activities or suspected fraud, or enforce or apply FreeYourID's agreements.
D. WHOIS Server
In order to support security of the Internet, we are required to offer the WHOIS service with respect to the top-level domains (such as .com, .net, .tv, and .name) for which we are the registry. This service allows you or anyone else to determine the availability of domain names and the contact information for the registrar who registered a domain name on behalf of a registrant. In some instances, we are required to operate a "thick," or extensive, WHOIS service that typically contains the registrant’s name, contact person's name, address, telephone number, email address, and/or IP address as provided to us by the registrar for the domain name. Via the WHOIS service, this information may be disclosed to unaffiliated third parties in order to determine the registrant or the registrar in case of (i) technical problems that might occur when accessing its domain; (ii) assisting law enforcement authorities in investigations, crime prevention, and matters of national security; (iii) helping to counter the infringement of third-party legal rights; and (iv) preventing fraud. However, FreeYourID publishes only that data necessary for the purposes described above or when the registrant has agreed to the publication.
E. Business Transitions
Circumstances may arise where, whether for strategic or other business reasons, FreeYourID decides to sell, buy, merge, or otherwise reorganize businesses or business units in some countries. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of it from sellers. It is FreeYourID's practice to seek appropriate protection for information in these types of transactions.
F. Surveys
From time to time, we may request information from customers via surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. Survey information will be used for purposes of monitoring or improving the use of and satisfaction with this web site, and improving our customer service and product offerings.
From time to time, we notify our subscribers of new products, announcements, upgrades, and updates. If you would like to opt out of being notified, please contact us at the address given at the end of this Privacy Statement.
You can also change your preferences online. If you receive a marketing communication from our subsidiaries, business partners, or independent resellers, you should opt out with that entity directly. Please be aware that you may not opt out of receiving information regarding the security, initial use, expiration, product enhancement, or migration of our products or services.
We consider the protection of all personal information we receive from our web site visitors and subscribers as critical to our corporate mission. Please be assured that we have security measures in place to protect against the loss, misuse, and alteration of any personal information we receive from you. As with any transmission over the Internet, however, there is always some element of risk involved in sending personal information. In order to try to minimize this risk, we encrypt all information that you submit in ordering one of our products or services using the Secure Sockets Layer (SSL) protocol. Our security procedures are also subject to at least an annual SAS-70 Type II audit by an internationally recognized accounting firm.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at . We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you would like to update, delete, or correct any personal information in our records, please or at the address given at the end of this Privacy Statement.
If you use FreeYourID's "Email this page" feature to send one-time a copy of that page to someone else, your email address will appear as the sender of the email. Both your email address and the recipient's email address will not be used for any other purpose.
If a material change is made to this Privacy Statement and/or the way we use our customers' personally identifiable information, then, with the prior written approval from TRUSTe, we will post prominent notice of the nature of such change on the first page of this Privacy Statement and also on our home page.
Our mailing address is:
FreeYourID, Inc.
Attention: Customer Support
12061 Bluemont Way
Reston, VA 20190
This Section of the Privacy Statement describes how FreeYourID, Inc., ("Verisign") handles personal data of representatives of certain customers from the European Union. Specifically, FreeYourID adheres to the US-EU and US-Swiss Safe Harbor Privacy Principles (collectively "EU Safe Harbor") with respect to certain personally identifiable information that it receives from customers in the European Union, , European Economic Area and Switzerland (collectively "EU Personal Data"). FreeYourID has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view FreeYourID’s certification, please visit the U.S. Department of Commerce’s Web site.
From its customers, FreeYourID may collect name, title, address, phone, fax, pager number, and other contact information for purposes of contacting customers as necessary or appropriate to provide or support its services. Where permitted by law, FreeYourID may also use this information to communicate regarding FreeYourID products or services, and disclose such data to subsidiaries, business partners and independent resellers of FreeYourID services for the same purposes.
With respect to any sharing of EU Personal Data for purposes of marketing FreeYourID products and services, FreeYourID will provide notice of choice where required and obtains promises from its subsidiaries, business partners, and resellers that such entities will use and disclose the EU Personal Data for purposes of marketing FreeYourID products and services only. Individuals may opt out of further disclosures of their EU Personal Data from FreeYourID to subsidiaries, business partners, and independent resellers, and further uses of their data by FreeYourID for marketing, by contacting FreeYourID. If you receive a marketing communication from one our subsidiaries, business partners, or independent resellers, you should opt out with that entity directly.
To the extent that in providing its services, FreeYourID collects passwords, user names, and other data from customer networks (excluding the customer contact data discussed above), it does so for the exclusive purposes of monitoring the customers’ networks and systems, and otherwise performing the services to customers or complying with its legal obligations. At all times with respect to this data, FreeYourID acts as a mere “data processor” on behalf of its customers.
For information related to use of cookies and tracking technologies, see IV. USE OF COOKIES, OTHER TRACKING TECHNOLOGIES AND GATHERING OF STATISTICAL DATA above. If you access our website from a computer while in the U.S., know that you may receive a cookie that is allowable under U.S. law. You can delete this cookie using your web browser’s privacy controls.
FreeYourID makes reasonable efforts to keep EU Personal Data reliable for its intended use, accurate, current, and complete. FreeYourID also provides customer contacts with the opportunity to access, review, and correct their own customer contact information, and otherwise provides customers access in accordance with the EU Safe Harbor. Individuals may contact FreeYourID as indicated below in order to review their EU Personal Data. However, customer contacts may first wish to contact their company’s representative (i.e., FreeYourID’s customer), as that might be the most efficient means of addressing their issues. FreeYourID will respond to the request within 30 days.
FreeYourID may also disclose EU Personal Data as necessary in connection with the sale or transfer of all or part of its business, provided that it will notify affected customers in accordance with the procedure for changing this Privacy Statement as noted above. In situations where FreeYourID discloses EU Personal Data to any third parties acting as “agents” on behalf of FreeYourID, FreeYourID will require the recipient to protect the data in accordance with the relevant principles in the EU Safe Harbor, or otherwise take steps to ensure that the EU Personal Data is appropriately protected. FreeYourID may also disclose EU Personal Data where required or permitted by law, where FreeYourID believes that such disclosures are appropriate in connection with a law enforcement request, as required in connection with its obligation as an operator of a top level domain registry to provide WHOIS service or otherwise permitted by the EU Safe Harbor, or in order to investigate, prevent, or take action regarding illegal activities or suspected fraud, or enforce or apply FreeYourID’s agreements.
If you have any questions about this EU Safe Harbor Privacy Statement, or if you would like to request access to EU Personal Data that FreeYourID may maintain about you, please contact us as follows:
Global Law Department
FreeYourID, Inc.
12061 Bluemont Way
Reston, VA 20190
Email:
Telephone: specify Safe Harbor)
Any questions regarding FreeYourID's EU Safe Harbor participation should first be directed to the FreeYourID contact above. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you may then contact TRUSTe for further information.