- Information We Collect About You
Information You Provide To Us:
You may provide personal information to us, if you choose to:
- Submit a help request, a customer services inquiry or other inquiry to us, or fill in any other forms for the purposes of receiving our Services;
- Participate in some of the features accessible via the Services (for example, message boards, games, surveys, polls, promotions, contests, sweepstakes or other incentives);
- Participate in any Services that require registration;
- Enroll in any of our Webinars and/or Courses;
- Contact us about employment opportunities;
- Otherwise use the Services in a manner that you have requested.
Depending on which of these or any other Services you use, the personal information you provide may include:
- Personal details (e.g. name, date of birth, professional title, company name, and household income, investment interests, retirement information, information about your educational background );
- Contact details (e.g. phone number, email address, postal address, or mobile number);
- Account details (e.g. username and password);
- Transaction details (e.g. when you make a purchase or respond to offers);
- Communications (e.g. when you participate or post material in message boards or forums, participate in polls or surveys, write a review or provide a testimonial, or contact us with a question, comment, or request); or
- Professional information (e.g. if you are a Financial Advisor participating in our Advisor Insights program, information about your credentials, including, without limitation, broker CRD number, professional website URL, biographical information, licenses and designations, and profile picture).
Please be aware, that by posting information to message boards, chat groups or social networking facilities available via the Services, you will be making this information available to other users of these Services to the public. You should be careful about revealing any sensitive details about yourself.
If you purchase Courses through the NARUDA LIMITED Academy, please note that we do not currently collect or retain credit card numbers internally. We partner with third party payment providers. All direct payment gateways are required to adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements are intended to promote the secure handling of credit card information.
We also have features that allow you to send an email to yourself and/or others about an item on our site. If you choose to use our email referral service, you will be required to provide the e-mail address or addresses that will be used in the notification. Upon form submission an email will be generated to your recipient(s) inviting them to visit the URL you have recommended. We do not store this information other than for the sole purpose of sending this one-time e-mail.
Information Collected Via Automated Technologies and Interactions:
When you use the Services, we may automatically collect information via automatic means about your computer or device, your preference settings, your location, and your activities, including:
- IP address of your computer;
- Unique mobile device identifiers;
- Technical information about your computer or mobile device such as type of device, mobile device ID number, screen resolution, web browser information, and operating system or platform;
- Your preferences and settings (time zone, language, etc.);
- Internet provider or mobile carrier name;
- The URL of the last webpage you visited before visiting the Website;
- Information about your activity on the Services (e.g., your search queries, mis-formatted DNS entries, search results selected, clicks, pages viewed, search history, comments, forms filled out and submitted, how often you use the Services);
- Information we generate as a result of your use of the Services (e.g. our understanding of your interests as a result of your use of the Services and whether you are a regular or occasional user of the Services); and
- If you are using a mobile device, your mobile device’s geographic location (specific geographic location if you’ve enabled collection of that information, or general geographic location automatically). Please see the section “Mobile Device Location Information” below for further information.
Third-parties who provide us with products and services may also place cookies, ad tags and/or beacons that collect the information outlined above in order to provide us with products and services including:
- Analytics tools (e.g., Google Analytics) allowing us to analyze the performance of our Services.
- Service features and functionalities such as those that enable videos to be played and you to connect to your social media accounts.
- Advertisers and ad networks allowing the delivery of targeted advertisements.
These third parties may also collect information about you from other sources and combine it with other information collected about you from third party websites not affiliated with us. For example, advertiser and advertising networks, as well as data analytics companies who service them, may participate in online behavioral advertising and track your activity across various sites and/or devices where they display ads and record your activities, so they can show ads that they consider relevant to you.
Do Not Track: Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services.
These third parties may also provide us with information about your interactions with their products and services and/or activities on third party websites. For example, use of Service functions that connect to your social media account (e.g., Facebook Connect) may permit us access to your social network profile information, including your first name, last name, gender, birth date and email address, in accordance with your settings on the social network. If you choose to post information to your social media account via the Services, you will be making this information available to other users of these Services. We encourage you to be careful about revealing any sensitive details about yourself via our Services or otherwise.
- How We Use Your Personal Information and the Basis on Which We Use It
We may use the information we collect from and about you for the following purposes:
- Identification and authentication: We use your identification information to verify your identity and/or eligibility for our Services when you access and use our Services and to ensure the security of your personal information. This is so we can comply with our obligations to you.
- Improving our Services: We analyze information about how you use our Services to provide an improved experience for our customers, including product testing, site analytics, and personalizing content to your interests. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our Services and improve them.
- Understanding our users: We also analyze information about our users in order to understand our users (their demographics, what you do on our Services, what features you like, how they use them etc.). It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand our users and improve our Services.
- Operating the Services: We process your personal information to administer our Services, diagnose technical problems, provide customer support, complete your transactions, and otherwise manage our business. This is so that we can comply with our contractual obligations to you.
- Communicating with you: We may use your personal information when we communicate with you, for example if we are sending you communications that you have requested, communications which relate to Services you have purchased or enrolled in, which may be of interest to you in accordance with your preferences, if we are providing information about changes to the terms and conditions, if you contact us with questions, or to provide you with customer support. It is in our legitimate interests that we are able to provide you with appropriate information, responses and provide you with notices about our Services. Please see the section “Reviewing, changing or deleting information” for further information about how you can control these communications.
- Marketing: We may use your personal information to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. It is in our legitimate interest to provide you with more relevant and interesting advertising messages, and inform our marketing strategy. We may use automated decision-making to deliver tailored advertisements based on your personal information. Where necessary, we will obtain your consent before sending such marketing messages.
- Complying with our obligations: We may process your personal information in order to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law.
- Customizing your experience: When you use the Services, we may use your personal information to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests. We may use automated decision-making to customize your experience based on your personal information.
- Compensating our partners: We may process your personal information for purposes of calculating compensation to be paid to our third party product/service providers and distributors and to analyze usage across products, services and distribution partner/channel. It is in our legitimate interest to appropriately determine amounts to be paid to our partners and inform our product roadmap and distribution strategy.
- In Connection with Webinars and Courses: In addition to the uses described above, if you are enrolled in and/or take any of our Webinars and/or Courses, we may use the registration information you provide, including personally identifiable information, to use through your Account for managing and processing purposes, including but not limited to tracking attendance, progress and completion of Course and/or Webinar. As part of our management and processing of each Course and/or Webinar, we may use this information to proctor exams, projects, and other assessments for each Course and/or Webinar. For example, as part of a Webinar that provides CE credits, we will use certain information collected from you in order to verify your identity, or to monitor your performance during the exam to confirm that you are abiding by the rules or requirements for obtaining CE credits. We may share such information that we collect from you when you participate in a Course with the company (if any) and/or lecturer(s) who provided, taught, managed, sponsored, or otherwise oversaw that Webinar or Course, and, where applicable, you will be subject to such third party’s privacy policies; and (ii) that third party may use the personally identifiable information you provide for its own marketing purposes.
- How We Share the Information We Collect
We will not share the personal information we collect about you with any third party except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared. We will share your information in the following ways:
- Our suppliers, subcontractors and business partners: (“service providers”): We may share your data with our services providers and business partners who perform marketing services and other business operations for us for the purposes set forth above. For example, we may partner with companies to process secure payments, fulfill orders, optimize services, serve online behavioral advertising, send newsletters and marketing messages, support email and messaging services, and analyze information. These service providers are required to treat the data in accordance with confidentiality requirements.
- Service requests: We enable you to request information and/or services from third party service providers or partners by filling out a registration, information request, or similar service request form for specific services from them (e.g., filling in a sponsored partner’s form to identify your retirement risk profile and/or submitting a request with such information for more information from that partner or another party). When you fill out and submit a service request form through our Website, you consent to our providing your personal information and request to the third party provider and/or partner. Sharing this information with the party provider and/or partner allows them to contact you using the contact information you provided. Additionally, we have other contractual partners that that utilize their own service provider to supplement our offering, and we share your information with them in order to attempt to provide the services requested.
- Webinars/Courses: We may share certain information with third parties that enable us to provide you the Webinars and/or Courses. For example, but not as a limitation, our Webinar and Course platforms may be hosted by third parties who will use your information to allow you to access the Webinar and/or Course. We also use third party payment providers who will use your information to process payment, subject to their own privacy policies. Additionally, for any continuing education eligible Webinar, we will share information provided to us as well as information regarding your completion of such Webinar with the organization issuing continuing education certificates, including without limitation, for the purpose of verifying your eligibility for the continuing education credits. We may also use third party customer service platform providers in order to help us provide customer service capabilities in connection with your use of one or more of our Services, including without limitation the Webinars and/or Courses.
- Group Companies: We may share your information with our affiliates, which are entities under common ownership or control of our ultimate parent company, IAC/InterActiveCorp for marketing purposes, security, optimization of products and services, and internal reporting. We do this for the purposes set out above.
- In the context of a transaction: we may share your personal information with potential transaction partners, service providers, advisors and other third parties in connection with the consideration, negotiations, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer or all or a portion of our assets or business.
In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-US or the Swiss-US Privacy Shield, NARUDA LIMITED is potentially liable.
- Yous Rights and Your Privacy Choices
You have certain rights regarding the personal information we hold about you, subject to local law. These may include the rights to access, correct, delete, restrict, or object to our use of, or receive a portable copy in usable electronic format of your personal information. You may also have a right to lodge a complaint with your local data protection or privacy regulator.
Choices relating to information we collect: We may be required by law to collect certain personal information about you or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent us from providing certain Services or all of the Services to you.
- Automated Decisions about You
When you use the Services, we may make automated decisions about you based on your personal information in the following circumstances:
- To deliver personalized offers, discounts, or recommendations based on your shopping history, viewing history, and browsing history, and
- To serve you with ads based on various factors such as the content of the page you are visiting, information you provide such as your age or gender, your searches, demographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests.
- Right to Access, Review, Change or Delete Information
To access, review, change or delete personal information we have collected from you, please visit our Privacy Center page and send a message to our Support team. To make changes to your account, you may also login to your account and visit the Manage Profile page.
Your specific rights regarding access, review, revision, or deletion of your information is dictated by local laws.
Legal rights applicable to personal data collected in the EEA. Pursuant to the EU General Data Protection Regulation (Regulation 2016/679) natural persons (called data subjects) are afforded certain rights regarding their personal data, including the right access, correct, delete, restrict or object to our use of, and receive a portable copy in a usable electronic format of your personal information. You also have the right withdraw any consent that you have previously provided to us and to lodge a complaint with your local data protection or privacy regulator.
If you would like to exercise any of the rights outlined above, and the law of your jurisdiction requires us to honor that request, please send your request in writing to the address in the “Contact Us” section below. To assist us in processing your request in timely manner, please make your request in English if you are able to do so. Your request should include any information relevant to your request, including, without limitation: (i) your name, email and postal address; (ii) the specific right you are asserting (e.g., removal); and (iii) if you are requesting removal, a brief explanation of why you believe such information should be removed.
To help us prevent fraudulent removal requests, please also include a legible copy of a document that verifies your identity. You need not provide a government-issued document; a utility bill or similar mailing will suffice. You may also obscure parts of the document such as identifying numbers so long as the document continues to clearly identify you. If you are making the request on behalf of another person, please indicate your relationship to that person and provide evidence of your authority to make such request. All requests for removal will be reviewed by NARUDA LIMITED’s legal and compliance team and we reserve the right, in compliance with applicable laws, to accept or reject, or make further inquiries regarding, any requests.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- How We Protect Your Information
We take the security of your information seriously, and use appropriate technical and organizational measures to protect your information against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also limit access to information about you t employees who reasonably need access to it to provide products and services to you, or in order to do their jobs. However, because no security can be 100% effective, we cannot completely guarantee the security of any information we have collected from you.
- Retention of Your Information
We retain the information we collect about and from you for as long as necessary to fulfill the purpose we collected it for and for the purpose of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information we process, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, accounting, or reporting requirements. In some circumstances we may choose to aggregate and de-identify you information in such a way that you may not reasonably be re-identified by us or any other company in which case we may use this information indefinitely without further notice to you.
In some circumstances you can ask us to delete your date: see Right to Access, Review, Change or Delete Your Information.
- Linked Sites and Advertisements
In this Cookies Policy, we use the term NARUDA LIMITED (and “we”, “us” and “our”) to refer NARUDA LIMITED, LLC.
What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are widely used in order to make websites work, or to work more efficiently, as well as to provide information to the owners of the site
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies may tell us, for example, whether you have visited our Services before or whether you are a new visitor. They can also help to ensure that adverts you see online are more relevant to you and your interests.
There are two broad categories of cookies:
- First party cookies, served directly by us to your computer or mobile device.
- Third party cookies, which are served by a third party on our behalf. We use third party cookies for functionality, performance / analytics, advertising and social media purposes.
Cookies can remain on your computer or mobile device for different periods of time. Some cookies are ‘session cookies’, meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are ‘permanent cookies’, meaning that they survive after your browser is closed. They can be used by websites to recognize your computer when you open your browser and browse the Internet again.