Last Updated: July 2018
2. Data That We Collect and Receive
When you interact with us through the Services, we may collect data from you or from other sources. This “data” may be information that you directly provide to us, such as personal information you provide when you visit the Services, or information that is passively or automatically collected from you, such as anonymous information collected from your browser or device.
The data we collect consists of:
- Data that you provide directly when you register for, or use, the Services. This data will vary, but typically consists of name, email address, postal address, phone number and other similar contact data. We also receive data from the communications you send to us.
- Demographic data, such as age, gender, country and language preference.
- Device data, such as type of device, operating system and other software installed on the device, device settings, IP address, device identifiers and error reports.
- Usage data, such as the programs and features you access, items you purchase, and the timing, frequency and duration of your interactions through the Services.
- Location data, such as IP addresses received from your device.
- Information about your interests and preferences, such as your home city or your communications preferences. In addition to what you provide directly, we may infer your interests and preferences from other data we collect, such as the content and advertisements you interact with while using the Services.
- Third-party integrations. If you connect your use of the Services through a third-party service (e.g., a social media platform), the third-party may share certain information from your third-party account with us.
- Other third-party data, such as data from our affiliates, partners or vendors, data brokers or public sources.
3. How We Use Data
We use the data we collect for the following purposes:
Operating our business. We use the data we collect to operate our business, including providing and improving the Services. Specifically:
- To fulfill transactions that you request.
- To deliver location-based Services and comply with territorial restrictions.
- To diagnose and fix problems with the Services and providing other customer support services.
- For analytical purposes to better understand our customers and how they use the Services, which allows us to continually improve and expand the Services.
Communicating with you. We use the data we collect to communicate with you, including responding to your requests or inquiries. Specifically:
- To respond to your request if you contact us with a question or concern.
- To deliver news, updates and other types of communications, according to your subscriptions, alerts and other preferences.
Marketing and advertising. We use the data we collect for marketing or advertising purposes, on behalf of ourselves, as well as our partners and other parties. Specifically:
- To send you promotional messages and deliver advertisements about products, services, programs or events that may be of interest to you. These may be offered by, or on behalf of, SAXTON HORNE, or by our partners and other third-parties with whom we have a relationship.
The promotional messages and advertisements that you see may be determined by data that we collect or receive about you, such as your demographic data, location data, usage data, interests and preferences. We refer to this as “interest-based advertising”.
Security, compliance and enforcement. We use the data we collect for security, compliance and enforcement purposes. Specifically:
- To protect the safety and security of our clients and our Services.
- To detect and prevent abuse, fraud or other unlawful or unauthorized activities.
- To resolve disputes.
- To enforce our agreements, including our policies and terms of service that govern your use of the Services.
We may also use your data in any other manner as disclosed at the time of collection, or when we have otherwise obtained consent. Please also note that this Policy is not intended to place any limits on what we do with aggregated, pseudonymized or anonymized data.
4. How We Share and Disclose Data
There are times when the data we collect may be shared by SAXTON HORNE. We share your data for the following purposes:
Providing the Services. We sometimes engage or partner with other companies to operate the Services or perform certain functions on our behalf – for example, maintaining our database, delivering messages and advertising, operating our websites and digital platforms. We may provide these companies with access to your data as needed for them to perform these functions in a manner consistent with this Policy.
Among SAXTON HORNE. We share personal data among the companies within SAXTON HORNE for purposes consistent with this Policy.
As part of a change in business structure. In the event of a sale, merger, acquisition, reorganization or similar event, or in contemplation of such an event (e.g., due diligence), your data may be among the transferred assets.
When necessary under certain circumstances. We may disclose your personal data when we believe that disclosure is necessary to:
- Comply with applicable law or respond to valid legal process.
- Protect the safety and security of our clients or our Services.
- Prevent fraud, abuse or other unlawful or unauthorized activities.
- Protect the rights or property of us or third-parties, including enforcing the terms of our agreements.
We may also share your data for any other purpose as disclosed at the time of collection, or when we have otherwise obtained consent. Please note that this Policy is not intended to limit our ability to share or disclose aggregated, pseudonymized or anonymized data.
5. What Choices You Have
You have many choices about how we collect, use and share your data.
Communications choices. You can choose whether you wish to receive messages from the SAXTON HORNE and which types of messages you wish to receive. If you receive promotional messages from us and would like to opt out, you may do so by following instructions within those messages. Please note that these preferences do not apply to informational or transactional communications regarding the Services or other communications that have their own unsubscribe method.
Advertising choices. You can opt out of interest-based advertising. When you opt out, your selection is stored on a cookie on your device. If you delete the cookie from that device or sign in from a different device, you will need to opt out again.
Because the data used for interest-based advertising is also used for other necessary purposes (including providing the Services and for authentication and security purposes), opting out of interest-based advertising does not stop the data from being collected nor reduce the number of advertisements you will see. However, the data will not be used for interest-based advertising, which means the advertisements you do see may be less relevant to you.
When using a mobile application, you may receive interest-based in-application advertisements. Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your device. In addition, each operating system (e.g., iOS for Apple devices, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of interest-based in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating system in order to opt-out of interest-based in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.
Other choices. You also have choices about the data you provide directly to us when you register for or use the Services. Please note, however, that if you choose not to provide data that is necessary to provide certain features of the Services, your use of the Services may not include those features.
You can choose not to share certain location data by adjusting the settings on your device. Please note, however, that if you choose not to share this data, you may not be able to access or use location-based Services.
You can choose to limit the data that third-party services (e.g., social media platforms) share with us using the options provided to you by the applicable third-party service (for example, the options provided by a third-party social media platform when you connect your social media account with the Services). You can also disconnect your use of the Services from the third-party service at any time using the options provided to you by the applicable third-party service. Please note, however, that if you disconnect from the third-party service, that will not delete the data we may have previously collected while you were connected.
6. Cookies and Similar Technologies
- Cookies. Cookies are small text files that are unique to your device or browser. They can either be session-based (i.e., lasting only while your browser is open and automatically deleted when you close your browser) or persistent (i.e., lasting until you delete them or they expire).
- Locally stored objects. Locally stored objects (“LSOs”), also commonly called “Flash cookies,” are stored on your device or browser to provide Services that use Adobe Flash technology.
- Web beacons. “Web beacons” or clear GIFs are small pieces of code placed on a Service to collect data about users of that Service.
- Software development kits. Mobile Software Development Kits (“SDKs”) are bits of computer code used by mobile app developers to enable or enhance various features of a mobile app. For example, an app developer may include an SDK within a mobile app that enables advertisements to be shown, data to be collected, and related services or analytics to be performed in connection with the mobile app.
We use Tracking Technologies for the following purposes:
- Security. We use Tracking Technologies to help detect fraud and abuse of the Services, including attempts to access the Services without authorization.
- Analytics. We use Tracking Technologies to gather usage and performance data about the Services, including counting the number of unique visitors to a particular Service.
- Advertising. We use Tracking Technologies to track how many users have seen or clicked on an advertisement. This allows us to learn which advertising campaigns are most effective and also to help limit the number of times a user is shown the same advertisement.
- Interest-based advertising. We use Tracking Technologies to collect information about your interests so that we can deliver advertising that is most relevant to your interests.
- Tailoring the Services. We use Tracking Technologies to collect information about how you use the Services so that we can tailor your experience based on what is most relevant to your interests.
In some cases, we may work with third-parties (for example, third-party operators of the Services) to synchronize our unique, anonymous identifiers (such as those associated with Tracking Technologies) with the third-party’s own identifiers. This enables us to better achieve each of the purposes described above.
Managing Tracking Technologies. Most web browsers give you the ability to manage Tracking Technologies used on a website, including blocking or deleting them. Please note that if you choose to block Tracking Technologies, you may not be able to use certain features that depend on those Tracking Technologies (such as keeping you signed in or remembering your preferences). If you choose to delete Tracking Technologies, any settings and preferences that were associated with those Tracking Technologies will also be deleted and may need to be reset.
7. Security of Data
SAXTON HORNE takes security seriously. We take a number of steps to protect your data from unauthorized access, use or disclosure. These steps take into account the sensitivity of the data we collect and use, as well as the current state of technology. This includes, for example, storing your data on systems that have limited access and are maintained in controlled facilities. We also use, and require our vendors to use, industry standard security protocols when processing any payments for your use of the Services.
It is important to remember that no system can be guaranteed to be 100% secure. We recommend that you help us keep your data safe by taking reasonable steps such as keeping your passwords private and not disclosing sensitive personal data in places that can be accessed publicly.
8. Children and Parents
SAXTON HORNE Services are not directed at children under the age of 13, and our policy is to not knowingly collect personal data from children under the age of 13.
If you have reason to believe that a child under the age of 13 has provided personal data to us without parental consent, please contact us using any of the methods described in the “How to Contact Us” section of this Policy, and we will endeavor to delete that data from our systems.
For children located in jurisdictions within the EU, we comply with the age limits applicable in each Member State. In these instances, the references above to the age of 13 will be deemed to be references to the age limits applicable in each Member State. Where this Policy refers to consent, this will require the consent of a parent or legal guardian in relation to any person under the age limits applicable in each Member State.
10. Storing Data
Personal data collected by SAXTON HORNE may be stored and processed in the region in which it is collected or in the United States. We take steps to ensure that the data we collect under this Policy is stored and processed in accordance with this Policy regardless of where the data is located. By providing personal data in connection with the Services, you acknowledge and agree that such personal data may be transferred from your current location to the offices and servers of SAXTON HORNE and our authorized third-party service providers located in the United States. Our practice when transferring personal data is to rely on standard data protection contract clauses or individual consent.
We retain personal data for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other necessary purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements.
11. European Privacy Rights
We adhere to applicable data protection laws in the European Union (“EU”). In accordance with the General Data Protection Regulation (“GDPR”), users who are located in the EU have the following rights:
- If the processing of personal data is based on your consent, the right to withdraw consent for future processing of that data.
- The right to request from SAXTON HORNE, a “data controller” as defined under the GDPR, access to and rectification of your personal data.
- Subject to limitations as provided for in the GDPR, the right to request restriction of the processing of your personal data.
- Subject to limitations as provided for in the GDPR, the right to request erasure of your personal data.
- You may contact SAXTON HORNE using any of the methods described in the “How to Contact Us” section of this Policy.
We may change this Policy from time to time to reflect changes in our business, the Services, or our practices and procedures. If we do make changes, we will post any changes on this page and indicate the date on which the Policy was last revised. We encourage you to review this Policy periodically, especially before you provide personal data directly to us through the Services. Your continued use of the Services after any changes to this Policy are in effect constitutes your acceptance of the revised Policy.
13. How to Contact Us
Although we strive to make this Policy as comprehensive as possible, we know you may still have questions or concerns about how we collect, use and share data. If you have a question, concern or complaint regarding our data privacy practices, you may contact us by any of the following methods:
- By writing to us at SAXTON HORNE 85 East 9400 South Sandy, UT 84070
- By sending an email to email@example.com; or
- By calling us at 801-304-1000.