Privacy Policy

Who is PCR?

 

PCR is a financial services technology company that delivers investment data aggregation services to banks, registered investment advisors and other firms (Providers).  We do not provide services to individuals or consumers directly. Providers have sub-contracted with PCR through documented contracts including a Data Processing Agreement which sets out what data we can aggregate, for whom we can aggregate it,  how we must protect the data,  limitations on what we do with the data and how we must satisfy requirements for transparency with their customers.  These agreements establish a clear Intended Purpose for our service.

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Our Commitment to Protect the Privacy of Your Information

 

PCR is committed to protecting the privacy and security of the personal information we receive or collect from you.  We also believe in transparency and are committed to informing you about how we treat your personal information. PCR has prepared this Privacy Policy (the “Policy”), together with any documents referenced therein, to inform you (“you”, “your” or “user”) of our practices regarding personal information that we collect, use, and share through our website and other marketing and support services provided by us.  The Policy also describes certain rights and options that you have with regard to your personal information. This Policy covers all personal information collected by PCR through our website, mobile applications, software application, client support sites, events or webinar registrations, or offline sources, (collectively the “Sites”) and through the provision of licensed software, technology and services to you. 

 

Please read this Privacy Policy carefully to understand how we treat your personal information and  choices and rights available to you.  If you do not agree with the terms and conditions of this Policy, you should not access or use the Site or our services. 

 

Our Role in Protecting the Privacy and Security of Your Personal Information 

 

PCR is responsible for implementing applicable data protection principles and safeguarding the personal information that you provide to us through our Website or the PCR Application. If you are a user in in the European Union (the “EU”) or European Economic Area (“EEA”), PCR will be the controller of the personal information we collect from you outside our role as a sub-processor for purposes of the E.U. General Data Protection Regulation, 2016/679 (the “GDPR”). 

 

What Personal Information Do We Collect and Why 

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We may collect and process the following personal information from you for the following purposes:

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Contact Information: When you visit our Sites or ask for services, we may ask you for your name, address, telephone number, email address or other contact details in order to respond to your requests or inquiries about our Site, our products or our services.  

Event Registration Information: When you register for an event or webinar hosted by us, we collect your contact information and other details necessary for processing the registration.  

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Business Information: When you seek services from us in the course of contractual or customer relationships between you, your organization, and PCR, we collect business contact information and other personal information in order to provide you with the services you have requested.  

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Financial and Payment Information: When you purchase goods or services from PCR, we may collect your bank account and other information necessary to process payments, including credit card numbers, security codes, expiration dates, and other related billing information.  

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Location Information. When you use our Sites, we may collect information about your use of our Sites and services for advertising, analytics, and content development purposes and to maintain and improve the security of our Site and services.  Location information collected may include your Internet Protocol (IP) address, internet tags, or other similar location-tracking technologies.

Cookies. When you visit our Sites we use cookies to improve your site experience and capture statistics on the use of our sites.  If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly.  

Email Interconnectivity. If you receive email communications from us, we may use certain tools to capture data related to whether or not you open our message and click on any links it contains. We use this information to enhance our marketing efforts and determine what content people find most useful in order to tailor future offerings.  

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Employment. If you apply for a job, or become an employee, we collect personal information necessary to process your application or employment.  This may include, among other things, your contact information, your social security number, employment history, etc.  

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Feedback / Support / Inquiries. If you provide us with feedback or contact us for support or ask us questions, we will collect your name, email address, other contact information and other information needed to respond to your feedback, request for support, or answer your question.  

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Sensitive Personal Information. When necessary in order to respond to your requests for services or employment, we may collect information regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, financial information, or data concerning your sex life or sexual orientation.  PCR will only collect this sensitive personal information with your express consent or as otherwise permitted by applicable law.   In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly-available sources. 

 

How Will We Use Your Personal Information? 

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In addition to the uses described above, PCR uses the personal information collected to improve your experience on the Site, to provide services to you, and to communicate with you about the information you have requested.  Additionally, PCR may use your personal information in the following ways:

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• To provide you with services you have requested and to manage our relationship with you, including administering your account, processing payments, accounting, auditing, billing and collection and taking other steps necessary to the performance of our business relationship with you;

• To present and improve Site functionality;

• To determine user interests, needs and preferences;

• To provide notice of changes to our Site or the services we offer or provide through it;

• To conduct research and analysis;

• To develop new products and services;

• To manage and maintain the security of our Site and services;

• To market our services to you. We will only provide you with marketing related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time. We do not share or distribute this information to third parties or use it for any other purpose unless you explicitly request or give us permission to do so for specific purposes – e.g. if you agree to participate in an external press interview, speak at an event or share a success story on the implementation of our software.

• To comply with legal and compliance obligations, including maintaining records, performing compliance audits, etc.

• For insurance purposes;

• To exercise and defend our legal rights, or to comply with court orders;

• For any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your personal information was provided to us;

• In any other way we may describe when you provide the information; and

• For any other purpose to which you have consented or for which we have a legitimate basis under the law.

• We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:

• because it is necessary to perform the services you have requested, to comply with your instructions or requests, or other contractual obligations between you and PCR;

• to comply with our legal obligations as well as to keep records of our compliance processes;

• because our legitimate interests, or those of a third party recipient of your personal information, makes the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;

• because you have chosen to publish or display your personal information on a public area of the Site, such as blog or comment area;

• because it is necessary to protect your vital interests;

• because it is necessary in the public interest; or

• because you have expressly given us your consent to process your personal information in a particular manner.

 

Disclosure of Your Personal Information 

 

We may share your personal information in the following contexts:

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Subsidiaries and Acquisitions: We may share your personal information with our corporate subsidiaries and affiliates.  If another company acquires PCR, we will share your personal information with that company.  

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Disclosures With Your Consent: We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy.  We will only disclose your personal information in this context with your consent.  

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Disclosures Without Your Consent: We may disclose your personal information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws.  We may also share your personal information in order to establish or exercise our legal rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property or a violation of our Terms of Use, or to comply with your request for shipment of items ordered from us to the provision of services by a third-party.  

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Public: Some areas of our Site may provide the opportunity to post comments or reviews, in a public forum.  If you decide to submit your personal information in these areas, you do so at your own risk and acknowledge that the information will be publicly-available.  

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Directories: You may consent through account or conference/seminar registrations to having your contact information shared with other account holders or conference/seminar registrants.  

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Third Parties: Only with your consent or at your request will PCR provide personal information about you to third parties that offer products and services specifically requested by you.  

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Service Providers: PCR may share your personal information with our service providers.  Among other things, service providers may help us to administer the Site, support our provision of services requested by you, provide technical support, send marketing, promotions and communications to you about our service, payment processing and other legitimate purposes permitted by law.  

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How Long Do We Store Your Personal Information? 

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PCR will retain your personal or business information as needed to fulfill the purposes for which it was lawfully collected.  PCR also will retain and use your personal or business information as long as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, provide our services, and enforce our agreements. When we no longer have a purpose to retain your personal information, we will destroy your personal information in accordance with applicable law and our policies. 

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Security of Your Personal Information

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PCR has put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized manner, altered, or disclosed.  While our security measures seek to protect your personal information in our possession, no security system is perfect and PCR cannot promise that your personal or business information will remain absolutely secure in all circumstances. The safety and security of your personal and business information also depends on you. Where you use a password for access to restricted parts of our support Sites or the PCR software application, you are responsible for keeping the password confidential. Do not share your password with anyone. If a security breach causes an unauthorized intrusion into our Site or systems that compromises your data, we will notify you and any applicable regulator when we are required to do so by law. 

 

Updating Your Personal Information 

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If any of the personal information you have provided to us changes, please let us know.  For instance, if your email changes, you wish to cancel any request you have made of us, or if you become aware of inaccurate personal information about you, use our Contact Us details to update your information.  You may also edit your account details if you have a user account through our Site. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete personal data that you provide to us. 

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Your Rights to Access and Control Your Personal Information 

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Right of Access.  If required by law (e.g., under the GDPR), upon request, we will grant reasonable access to the personal information that we hold about you. 

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Accuracy.  Our goal is to keep your personal information accurate, current, and complete.  Please contact us if you believe your information is not accurate or changes. 

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Right to Object. In certain circumstances, as permitted under applicable law, you have the right to object to processing of your personal information.  If you would like us to stop using or wish to restrict our processing of your personal information, please contact us and we will let you know if are able to agree to your request. 

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Right to Erasure and Deletion of Your Personal Information. You may have a legal right (for instance, if you are located in the EU or EEA under the GDPR) to request that we delete your personal information when it is no longer necessary for the purposes for which it was collected, or when, among other things, your personal information has been unlawfully processed.  All deletion requests should be sent to the address noted in the Contact Us section of this Policy. We may decide to delete your personal information if we believe it is incomplete, inaccurate or that our continued storage of your personal information is contrary to our legal obligations or business objectives.  When we delete personal information, it will be removed from our active servers and databases and our Site, but it may remain archived when it is not practical or possible to delete it.  We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements. 

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Right to Withdraw Consent.  If you have provided your consent to the collection, processing and transfer of your personal information, you have the right to fully or partially withdraw your consent.  To withdraw your consent, in full or in part, please notify us using the information in the Contact Us section of this Policy and you may follow opt-out links on any marketing communications sent to you. Once we have received notice that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal or business information for the provision of our services.

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Right to Complain. If you wish to file a complaint with us about our privacy practices, you may do so by contacting us using the information provided in the Contact Us section of this Policy and we will do our best to respond to and, if possible, resolve your complaint.  If you believe that your rights relating to your personal information have been violated, you have a right to lodge a complaint with the applicable enforcement authority, or seek a remedy through the courts. 

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Online Tracking.  We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. 

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California Residents. California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing.  If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the Contact Us section of this Policy. 

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European Union or European Economic Area Residents.  If you are located in the EU or EEA and believe we have not processed your personal information in accordance with applicable provisions of the GDPR, you may file a complaint with your local data protection or supervisory authority. 

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Cross Border Transfers of Personal Information 

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PCR is located and established in the United States and therefore, your personal information may be transferred to, stored or processed in the United States.  While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the security and privacy of your personal information.  By using our Site or requesting services from us, you understand and consent to the collection, storage, processing and transfer of your personal information to our facilities in the United States and those third parties with whom we share it as described in this Policy. 

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Residents of the EU / EEA

 

We rely on recognized legal bases to lawfully conduct cross-border transfers of personal information outside of the European Union (EU) and European Economic Area (EEA), such as your express informed consent (as noted above), when transfer is necessary for us to deliver services pursuant to an agreement between PCR and you, or when the transfer is subject to safeguards that assure the protection of your personal information, such as the European Commission’s approved standard contractual clauses.

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Links to Other Sites 

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This Site may contain links to, and media and other content from, third party websites.  These links are to external websites and third parties over which we have no control or supervision.  If you click on an embedded third-party link, you will be redirected away from this Site to the external third-party website.  You can check the URL to confirm that you have left this Site. PCR cannot and does not (i) guarantee the adequacy of privacy, security, practice content or media provided by third parties or their websites, (ii) control third parties’ independent collection or use or your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Site. Any personal information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. 

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Children

 

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the internet.  Our Site and the services are not directed to children aged 17 or younger, nor is information knowingly collected from children under the age of 18.  No one under the age of 18 may access, browse, or use the Site or provide any information to or on the Site.  If you are under 18, please do not use or provide any information on this Site.  If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule. 

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Changes to Our Privacy Policy 

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We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we treat your personal information or in response to changes in law.  We will post any changes we make to this Policy on this page.  If we make material changes to how we treat your personal information, we will notify you through a notice on the Website home page and through email communication, when appropriate.  The date this Policy was last revised is identified at the top of this Policy. 

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Contact Details 

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If you have questions or comments about this Policy, wish to access personal information we hold about you; believe the personal information we have about you is incorrect, or wish to lodge a complaint with us about how we have handled your personal information, please contact us using the contact details at the top of this policy.

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TEMPLATE COOKIES AND SIMILAR TECHNOLOGIES POLICY 

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PCR (also referred to as “we”, “us”, and “our”) respects the online privacy of its members and other visitors (“you”) to www.pcrinsights.com (the “Site”).  This Cookies and Similar Technologies Cookie Policy (the ”Cookie Policy”) describes the information we collect through the use of cookies and similar technologies, how and why we use cookies and similar technologies, how our third party business partners use cookies and similar technologies, and ways you can opt out of using cookies and similar technologies. 

 

Our Privacy Policy, of which this Cookie Policy is part, is available above and provides further information about our privacy practices. 

 

What is a Cookie? 

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A “cookie” is a small file created by a web server that can be stored on a user’s device for use either during a particular (“session” cookie) or future (“persistent” cookie) browsing session.  This file may include information about internet protocol (IP) addresses, browser type, internet service provider (ISP), URLs of any referring or exited webpages, operating system, and/or date and time stamps. PCR uses cookies to enable certain website functions, develop web browsing analytics, store and track your preferences, and enable the delivery of advertising and marketing, when applicable.  For example, we track the number of “hits” or visits to our Websites, the most popular times of day and sections visited, and the range of devices and browsers most commonly used to view the Websites.  PCR does not sell any of this information to third parties. 

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First-Party Cookies

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 First-party cookies are set by the website you are visiting, and they can only be read by that site.  Certain features of our Website use session, persistent, and flash cookies.“Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session or after a set time period. “Permanent” cookies remain stored on a user’s hard drive until they expire or are deleted by a user. We use permanent browser cookies on our Website for log in purposes and to recover certain preferences set for use by you during repeated visits to our Website.

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Third Party Cookies 

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You also may encounter third party cookies on our Website.  Third Party Cookies are cookies that are stored on your web browser by a party other than PCR and may gather browsing activity (such as information you have entered or choices you have made) across numerous websites that you visit and across numerous browsing sessions.  These cookies also help improve how PCR’ websites and services function and perform, customize your interaction with our Websites, and help provide more relevant messaging and marketing communications to you. PCR is currently using third party cookies to track and analyze usage. If you wish to delete Third Party Cookies, you should adjust your browser settings as described in the “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION” section of this Cookie Policy.

If you like more detailed information about first party and third party cookies in use on or related to this Website, please contact us.  You also may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/ and http://youronlinechoices.eu/ (if you are located in Europe). 

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How Does PCR Use Cookies and Similar Technologies

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Like most websites, as you navigate through and interact with our Website, we may passively collect information about your browsing activities using cookies and other automatic data collection technologies, such as Internet tags, or web beacons (clear gifs., pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.), to improve website functionality and analytics.

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Web beacons: These are tiny graphics (sometimes called “clear GIFs” or “web pixels” with a unique identifier that are used to understand browsing activity. In contract to cookies, which are stored on a user’s computer hard drive, web beacons are rendered invisible on web pages when you open a page.

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Social Widgets: These are buttons or icons provided by third-party social media providers that allow you to interact with those social media services when you view a web page or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.

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UTM Codes: These are strings that can appear in a URL (the “Uniform Resource Locator”, which is typically the http or https address entered to go to a web page) when a user moves from one web page or website to another, where the string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

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Application SDKs: These are mobile application third-party software development kits that are embedded in Apps (and are used in many mobile applications). These app SDKs permit the collection of information about the App itself, activity in the App, and the device application on which the App is running.

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The aggregate data collected by these passive technologies typically does not target any personally identifying information (PII) or other personal data, but personal information we store about you may be linked to information stored in and obtained from cookies in order to improve our marketing, analytics, or website functionality.

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Google Analytics and Similar Technologies 

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In addition to cookies, there are other similar technologies used by PCR on the Site.  These include: We use Google Analytics (the “Analytics Technologies”) to collect and process statistical data about the number of people using our Website and to better understand how they find and use our web pages.  This does not include personally identifiable information, nor do we store or associate such analytics with personally identifiable information collected elsewhere.

 

You may learn more about Google Analytics and the performance tracking cookies that it uses by visiting https://www.google.com/policies/privacy/partners/ as well as Google’s restrictions on data use by visiting the Google Privacy Cookie Policy at: https://www.google.com/policies/privacy. 

 

To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout  and install the opt-out browser add-on feature.  For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en).

 

Other Third Party Technologies 

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Some third parties may use automated data collection technologies to collect information about you when you when you browse the internet.  The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content.  We do not control these third parties’ technologies or how they may be used.  If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies. 

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Choices About How We Use Information 

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We provide you with choices regarding the personal information you provide to us and have created ways to give you control over our use of your information. Most web browsers are set by default to accept cookies.  If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies, or to alert you when cookies are being sent by website tracking technologies and advertising. Note that, if the user declines the use of cookies, the user may not have access to the full benefits of the Website. When a user registers with our Website, the Website will prompt the user to confirm whether he or she approves of the use of a cookie. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies,  but will need to log in each time you want to enjoy the full functionality of the Website. Please be aware that adjusting the Cookie Settings for our Website may not fully delete all of the cookies that have already been created.  To delete them, visit your web browser settings after you have changed your Cookie Settings for our Website.

 

Additional information is provided below about how to disable cookies or manage the cookie settings for the leading web browser providers: 

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• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en 

• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences 

• Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies 

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