Last Updated: _________, 201__
We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on the Policy the date it was updated. We encourage you to review this Policy from time to time to make sure that you understand how any personal information you provide will be used. Your continued use of the Site(s) following the posting of changes to these terms will mean you accept those changes. [Note that for material changes, such as how personal information is used and shared, you will need to consult your attorney regarding whether or not to send out a notice to users and obtain each user’s affirmative opt-in to the updated Policy.]
[For ease of consumer use, consider adding a Table of Contents, with hyperlinks to each relevant section included in this Policy.]
What Is Personal Information?
As used herein, the term “personal information” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, date of birth, credit card number, social security number), or information about that individual that is directly linked to personal information. [Note that if Company collects sensitive personal information (like social security numbers, bank details and credit card numbers), all pages collecting the sensitive information must use a secure processing server (https://) and have a clearly visible link to this Policy.] Personal information does not include “aggregate information”, which is data we may collect about the use of the Site(s) or about a group or category of users, from which individual identities or other personal information has been removed. This Policy in no way restricts or limits our collection and use of aggregate information.
How Do We Collect Information, and What Types of Information Do We Collect?
We collect several types of personal information about you in a number of ways when you visit or use the Site:
We collect certain information when you voluntarily provide it, such as if you send us an email [and Insert any means by which users might voluntarily provide information through the Site, e.g., by creating an account on the Site, subscribing to a newsletter, participating in a community forum or chat room, shopping on the Site, making a purchase on the Site, receiving customer or technical support, participating in contests, sweepstakes, events or promotions, etc. If you have purchased ReachLocal’s TotalLiveChat product, be sure to include “receiving customer or technical support (including via an online chat widget).”] or you otherwise provide or request information. Such information may include various types of personal information. Additionally, we may also collect demographic information such as your age, gender, country and zip code of residence, recent purchases, and preferences. This demographic information may be associated with your personal information. If this demographic information is connected with personal information, we will treat the demographic information as personal information. [Only include the foregoing sentences (starting with “Additionally”) if relevant, and revise as appropriate.]
[Only include this if relevant; otherwise, delete.] For some features of the Site, you may be able to submit information about other people. For instance, if you [Insert any features that involve the submission of others’ information, e.g., referring a friend, shipping a purchase to a friend, etc.] you may submit someone else’s personal information. Company will use any such information that we collect from you about another person to carry out your request.
When you use the Site, some information is also automatically collected, such as [Insert the various types of information, if any, that may be automatically collected by users of the Site, e.g., Internet Protocol (IP) address, operating system, browser type, address of a referring web site, activity on the Site, etc.]. We treat this information as personal information if we combine it with or link it to any of the personal information mentioned above. Otherwise, it is used in the aggregate only. [Only include the previous two sentences if they are accurate. Otherwise, disclose how the information will be treated.]
[Insert how the information might be used, e.g., to analyze data, to determine the popularity of content, to deliver targeted advertising, to make recommendations to users, to better understand the Site’s usage or the effectiveness of Ads, to track user actions/behavior on the Site, etc. If you have registered for ReachLocal’s Latent Conversion Tracking and/or enabled Remote Conversion Tracking product(s), be sure to indicate each of the foregoing purposes, as applicable, such as tracking web events or site visits, and emails to you].
You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies, though either of those actions may affect the use of our Site. However, if you wish to opt out of any of the Advertising Cookies, you can do this simply by navigating to http://www.reachlocal.com/opt-out, which will take you to a web page where you will be able to opt out of the Advertising Cookies currently used in connection with ReachLocal’s remarketing product.
If you have any questions regarding ReachLocal and/or the Advertising Cookies, you are encouraged to contact ReachLocal at firstname.lastname@example.org.
[If advertisements are run on the Site(s) via third party ad servers, please consult your attorney to include disclosures pertaining to such practices. Further, if Company obtains non-personal information about users (e.g., demographic, geographic, other usage information) from third parties, consult your attorney to include disclosures pertaining to such practices.]
How Do We Use the Personal Information We Collect?
We use personal information we collect through the Site for the purposes described in this Policy or elsewhere on the Site. For example, we may use personal and other information we collect to [Insert here the various ways that Company might use personal information, e.g., to process transactions, request feedback, communicate with the user, contact the user about their account, respond to user inquiries/problems, deliver targeted ads, provide recommendations, monitor Site usage trends, send promotional messages, confirmations, or security alerts, prevent fraud, conduct surveys, etc. If you purchase ReachLocal’s TotalLiveChat product, include all of the foregoing (other than “deliver targeted ads”, which is not done via personal information collected via TotalLiveChat). Of course, if you use PII to deliver targeted ads, you should include that regardless of whether you purchase TotalLiveChat.] and for any other purpose for which the information was collected.
If you no longer wish to receive [Describe all applicable direct communications, e.g., email, phone calls, direct mail, etc.] from us, you may opt out of all future communications by [Insert the method by which users may opt out of future communications.].
Further, we may make collected personal information available to third parties for their marketing and promotional purposes. If you decide that you do not want us to share your personal information with these companies for their marketing and promotional purposes, please send an e-mail to _____________. In this email state that you would like Company to not share your personal information with third parties for their marketing purposes. Your opt out request will be processed within thirty (30) days of the date of which we receive it. [Remove this paragraph if Company is not going to share personal information for third party marketing and promotional purposes and doesn’t want to reserve the right to do so. Also, please note that if this provision is applicable and you’re a California company or have California consumers, you may have to specifically call out such obligations under a heading entitled “Your California Privacy Rights,” such as the following:
Your California Privacy Rights: The following applies solely to California residents who have an established business relationship with Company. If we collect personal information from you, we may make the personal information available to third parties for their marketing and promotional purposes. If you decide that you do not want us to share your personal information with these companies for their marketing and promotional purposes, please send an e-mail to _____________. In this email state that you would like Company to not share your personal information with third parties for their marketing purposes. Your opt out request will be processed within thirty (30) days of the date of which we receive it.].
What Personal Information Do We Share With Third Parties?
We will not share the personal information we collect from you through the Site(s) with third parties, except as described in this Policy or on the Site(s). For example, we may share personal information as follows: [List all of types of people/companies with whom the personal information is shared and the circumstances under which Company would provide such information, e.g., to service providers in connection with the operation of the Site and/or the marketing of our products and/or services, upon user request or with user consent, to enforce the Policy, to enter you in sweepstakes, contests or promotions, to comply with law, to prevent fraud, in connection with the sale of Company assets, etc. If you purchase TotalLiveChat, be sure to include “to service providers in connection with the operation of the Site and/or the marketing of our products and/or services.”]
Aggregate Information: [If the Site uses or shares aggregate information, consider including the following type of language (with adjustments as applicable).]
Purchase or Sale of Businesses:
Disclosures Required By Law and Disclosures to Help Protect the Security and Safety of Our Websites and Others:
We will disclose personal information when we believe in good faith that such disclosures (a) are required by law, including, for example, to comply with a court order or subpoena, or (b) will help to: enforce our policies; enforce contest, sweepstakes, promotions, and/or game rules; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of our Site(s) or third parties.
How Can You Modify Or Delete Your Personal Information?
You may modify or delete the personal information collected through the Site at any time by [Describe all methods available to users for them to modify or delete their personal information, e.g., visiting your profile, modifying your account, contacting Company via email and/or phone, etc.].
Do We Collect Information From Children Under the Age of 13?
The Site(s) is not intended for use by children under the age of 13, and Company does not knowingly collect or use any personal information from such children. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database. [Include the foregoing if accurate. If, however, personal information is collected from children under the age of 13, additional provisions will be needed, and Company will need to comply with the Children’s Online Privacy Protection Act. Please consult your attorney for further information.]
What Steps Do We Take To Protect Your Information?
[Consider revising this section as appropriate to reflect your actual practices.] We take measures designed to protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. [Consider including the following if relevant.] To protect the confidentiality of personal information maintained in your account, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Site(s) by any person using your password. Please advise us immediately if you believe your password has been misused.
This Policy and the privacy practices of Company will be subject exclusively to the laws of the State of [Insert chosen state.] in the United States. Company makes no representation that this Policy and our practices comply with the laws of any other country or jurisdiction. Users of the Site who reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you reside outside of the United States, by using the Site, you consent to the transfer, processing and use of your information outside your country.
If you have any questions about this Policy, please contact us at [Insert applicable contact information.]