Last Updated: February 15, 2016
This Privacy Notice applies to Information (defined in Section 1) collected from you by or on behalf of Obolus, LLC ("Obolus", "we", "us", or "our") when any user ("User"), including you, accesses or uses our website, located at https://estatepass.com/, and all mobile site adaptations thereof (collectively the "Website").
This Privacy Notice describes how we collect, use, and share Information from Users of the Website (and the Online Services as provided through the Website, as defined and more fully described in our Terms and Conditions of Use (the "Terms") fully incorporated herein by reference), and your choices about the collection and use of your Information. In using or accessing the Online Services, you consent to the collection, use, transfer, disclosure and retention of Information as described in this Privacy Notice. Capitalized terms used but not otherwise defined herein have the meanings assigned to them in the Terms.
By accessing the Online Services, you acknowledge that you have read, understood and agree to our collection, use, disclosure, and retention of Information as described in this Privacy Notice.
- Information Covered By This Privacy Notice
- Information Collected
- How We Use Your Information
- How We Share Your Information
- Your Choices
- Users Outside the United States
- Links, Third-Party Websites, and Social Networking Services
- Information Security
- Notice To California Residents
- Changes To This Privacy Notice
- Contact Us
1. Information Covered by This Privacy Notice
Obolus collects "Personal Information" (which means information that specifically identifies you, such as your name, address, telephone number, and e-mail address) and "Non-Personal Information" (which means information that relates to you but does not directly identify you, such as information about your Internet connection, preferences and your usage of the Online Services), from Users. The term "Information" is collectively used herein to refer to both Personal Information and Non-Personal Information.
This Privacy Notice does not apply to Your Content. Your Content, which may include Personal Information, is publically available and considered non-confidential and non-proprietary. You are responsible for all actions and use of Your Content while using the Online Services.
2. Information Collected
Information You Provide Us
If you register for an Account or correspond with us, you will be asked directly to provide certain Personal Information such as your name, address, e-mail, date of birth, race, social security number and/or EIN, employment background information, and other Personal Information directly or indirectly through any SNS account, such as including, without limitation, a phone number, employment, education and familial connections. If you provide Personal Information to us, directly or indirectly, you are telling us that such Personal Information is both true and accurate, and that you are authorized to provide it to us. We also retain any messages you send through the Online Services.
Information Collected Automatically
The Online Services, and related email messages, web chats, video chats, instant message assistance, phone or VoIP call assistance and advertisements, use various tracking technologies that may include cookies, local storage, web beacons/clear GIFs, embedded scripts, and ETags (collectively, "Tracking Technologies") to collect Information from you automatically. Obolus, along with our subsidiaries, affiliates, business partners, third-party service providers, and advertisers use Tracking Technologies for a variety of purposes, including enhancing your online experience. We treat Information automatically collected as Non-Personal Information. Please see below for more information regarding Tracking Technologies that may be used by Obolus:
Local Storage: Local storage such as Flash Cookies and HTML5 are similar to cookies but stores Information about your visit to a web page in a small database on your mobile device or computer. Because these technologies are similar to browser cookies, they are sometimes called "browser cookies," even though they are stored in different parts of your computer. We may use local storage for purposes similar to cookies, including facilitating the navigation and displaying of information more effectively, to personalize your experience the Online Services, and for analytical purposes.
Web Beacons: We may also use web beacons (also known as pixel tags or clear GIFs), which can be embedded in web pages, videos, or emails, to collect certain types of information from your browser, check whether you have viewed a particular web page or e-mail message, and determine, among other things, the time and date on which you viewed any online content, the IP address of your computer, and the URL of the web page from which any such content was viewed. Such Information facilitates more accurate reporting and improvement of the Online Services.
Embedded Script: Embedded script is programming code that is designed to collect Information about your interactions with the Online Services, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Online Services, and is deactivated or deleted thereafter.
ETag: A feature of the cache in browsers, an ETag is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are forms of device identifiers. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Log File Information: When you use the Online Services, we automatically collect and store certain Information in log files. This Information may include your IP address, device and software characteristics (such as type and operating system), browser type, Internet service provider, URLs, referring/exit pages, date/time stamp, and clickstream data.
Location Data: When you use the Online Services on a mobile device, we may access, collect, monitor, and/or remotely store Information regarding your mobile device as well as real-time "location data," which may include GPS coordinates (e.g., latitude and/or longitude). Location data may convey to us Information about how you browse and use the Online Services.
Device Information: We may collect Information about the computer or device you use to access the Online Services, including the hardware model, operating system and version, MAC address, unique device identifier, phone number, and mobile network information. In addition, the Online Services may access your device's image storage applications, with your consent, to facilitate your use of certain features of the Online Services.
Analytics Information: We may directly collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Online Services. These tools collect Information sent by your browser or mobile device, including the pages you visit and the features of the Online Services you use.
Information We May Receive From Third Parties
We may receive information about you from third parties such as SNS that you provide to them. Any Information that we collect from third parties may depend on the privacy settings you have with any particular service, so please consult each service’s privacy and data practices.
When you view an advertisement, if any, on the Website, whether or not you click on it, the advertiser, ad serving technology companies, and service providers that perform advertising-related services for Obolus, its subsidiaries, affiliates and its business partners may collect Information from or about you. Such Information may include your IP address, device ID, browser information, location information, and internet and on-line usage, as well as Information logged from your hardware or device. The information practices of such third parties are governed by their own privacy policies and are not covered by this Privacy Notice, and we are not responsible for the privacy practices of advertisers or ad serving technology companies.
3. How We Use Your Information
We use your Information that we collect, including Personal Information, for a variety of business purposes, including:
- providing the Online Services and interactive features to you;
- processing, creating, and managing your Account;
- communicating with you;
- personalizing the Online Services, features, and communications to your interests;
- enhancing your use of and experience on the Online Services, including managing and recording your preferences;
- responding to your inquiries, comments, or postings;
- improving and customizing the Online Services;
- customer service, which may include responding to your requests, resolving issues, and/or troubleshooting problems;
- for internal operations such as enhancing our offerings, marketing efforts, and to conduct research and analysis;
- developing new service offerings and features including special promotions, surveys, contests, service alerts and special events;
- for marketing purposes;
- to facilitate the provision of updates and technical support;
- to prevent fraud or potentially illegal activities (including copyright infringement);
- to enforce the Terms;
- to protect the safety of Users and other third parties on the Online Services;
- to comply with applicable laws, regulations, and legal process; and/or
- to protect the security and integrity of our business, the Online Services, Obolus, our subsidiaries, affiliates, business partners and third-party service providers.
We may combine all the Information we collect or receive about you for any of the foregoing purposes.
4. How We Share Your Information
We share and disclose your Personal Information under the following circumstances:
- with third parties that provide a variety of services on our behalf, including the development, maintenance, and support of the Online Services, the distribution of email and mobile messages, and marketing research and analysis;
- with our subsidiaries, affiliates, business partners and joint ventures in connection with the Online Services and for marketing purposes related to Obolus;
- to comply with or respond to the law, a court order, or other legal process or a request for cooperation by a government entity, whether or not legally required, including responding to subpoenas or warrants;
- to investigate or assist in preventing any violation or potential violation of the law, this Privacy Notice, or the Terms;
- to protect the legal rights and interests of Obolus, its subsidiaries, affiliates, business partners third party service providers, and our and their respective equity holders, directors, officers, employees, representatives, insurers and agents;
- to protect the legal rights, safety, and security of Users of the Online Services;
- to protect against fraud;
- for risk management purposes;
- in connection with or during negotiation of any corporate transaction such as a merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.
- in the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset of Obolus;
- if another third party acquires our business or any affiliate’s business, whether through stock or asset purchase, such third party will possess the Information, including Personal Information, collected by us and will assume the rights and obligations with respect thereto as described in this Privacy Notice; and/or
- in accordance with your consent.
5. Your Choices
You can confirm, change, delete, or update Personal Information you have provided to us by logging into your Account and changing your Information or by contacting us via the information provided below in the Contact Us section.
We may periodically send you newsletters and promotional e-mails in connection with the Online Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting us via the Contact Us information provided in Section 12. We use reasonable efforts to promptly process all unsubscribe requests. You will, however, continue to receive services related communications (e.g., Account verification, changes/updates to features of the Online Services, technical and security notices, etc.).
You may be able to opt-out of the automatic collection of some Information by referring to your web browser’s or mobile device’s options or settings menu. However, doing so may disable many of the portions, features, or functionality of the Online Services. For example, most web browsers automatically accept cookies, but you have the choice to set your browser to accept or reject cookies. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences or visit http://www.allaboutcookies.org for more information. For more information about disabling local storage objects or deleting information contained in Flash Cookies see http://kb2.adobe.com/cps/526/52697ee8.html or https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
You can also opt-out of the collection of web viewing data for interest-based advertising and other applicable uses by certain companies. Please visit http://www.aboutads.info/choices for more information. Information regarding your usage of the Online Services may still be collected for research, analytics, or internal operations purposes. We are not responsible for the effectiveness of any such opt-out options.
Data Retention and Deletion
If you completely delete all of your Personal Information, then your Account may become deactivated. Following termination or deactivation of your Account, Obolus may retain your Personal Information for backup, archival, or audit purposes, as well as to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce the Terms, and take other actions otherwise permitted by law.
We do not knowingly collect Personal Information online from children under the age of 13 without parental or guardian consent. If we determine that a child under the age of 13 has provided Personal Information to the Website, we will delete that information as soon as practical. Please contact us via the Contact Us information provided in Section 12 if you believe we may have collected such Information without parental or guardian consent or other than in a manner authorized by law, and we will work to delete it.
Pursuant to 47 U.S.C. § 230(d), as amended, we hereby notify you that parental control protections (such as computer hardware, software and filtering services) are commercially available that may assist you in limiting access to material that is harmful to minors. Information identifying current providers of such control protections is available on the websites GetNetWise (http://kids.getnetwise.org) and OnGuardOnline (http://onguardonline.gov).
7. Users Outside of the United States
The Online Services are provided from within the United States and are subject to the applicable state and federal laws of the United States. If you use the Online Services, you consent to the use and disclosure of your Information in accordance with this Privacy Notice and subject to such laws. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By providing your Information, you understand that it may be transferred to our facilities in the United States and to those third parties with whom we share it as described in this Privacy Notice.
8. Links and Third Party Websites
Our Website, Online Services and communications may contain links to other websites that are not owned or controlled by us (collectively, "Linked Sites"). We are not responsible for the privacy practices, policies, notices or content of any Linked Sites, even if you link to them from the Online Services. This Privacy Notice does not apply to any Linked Sites. We have no control over the collection or use of Information, including Personal Information, on any Linked Site. We encourage you to read and understand the privacy practices, policies, notices and content of any Linked Sites that you visit.
9. Information Security
Obolus keeps your Personal Information secure and implements reasonable technical, administrative, and physical safeguards to help us protect such Personal Information from unauthorized access, use, and disclosure. We also endeavor to request that our third party service providers use commercially reasonable security measures to protect your Personal Information from unauthorized access or use. However, no method of electronically transmitting or storing data is ever completely secure and, therefore, we cannot guarantee that your Information will never be accessed, used, or disclosed in a manner that is inconsistent with this Privacy Notice. You are responsible for maintaining the secrecy of and not to disclose intentionally or inadvertently your User login and password; do not disclose your password to anyone else. Please notify us immediately of any unauthorized use of your Account. In the event that any Personal Information under our control is compromised as a result of a breach of security, Obolus will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose Information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
10. Notice to California Residents
Residents of the State of California may request a list of all third parties to which we have disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us via the Contact Us information provided in Section 12. For all requests, you must put the statement "Your California Privacy Rights" in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
11. Changes to this Privacy Notice
We may update this Privacy Notice from time to time effective upon posting the revised Privacy Notice, along with the date on which it was most recently updated, on the Website. Please check our Privacy Notice periodically to see if it has been updated. If a change to this Privacy Notice materially affects the use or disclosure of your Personal Information, we will notify you by placing a more prominent notice on our home page of the Website. We encourage you to periodically review this page for the latest information on our privacy practices and policies. Your use of the Online Services after such a change will indicate your acceptance of our updated privacy practices and policies.
12. Contact Us
If you have any questions regarding this Privacy Notice or our privacy practices and policies, please contact us via e-mail at: firstname.lastname@example.org.