Effective Date/Last Modified: [August 23, 2018].
The terms “we” “our” and “us” refer to The Harbor Group, Inc., its subsidiaries and affiliates (collectively “The Harbor Group”), and the terms “you” or “your” refer to any individuals who access Interstates.com (the “Website”), which is comprised of various web pages and features operated by us.
- Information that we receive from you when you interact with the Website
- Information that we receive from you when you interact with the Website
- How we use and process the information that we receive
- If and why Personal Information may be disclosed to third parties
- Your choices regarding the collection and processing of your Personal Information.
If you are a “Data Subject” under the European Union (“EU”) General Data Protection Regulation (the “GDPR”), this is a required notice to you. The Harbor Group is a “Data Controller” for purposes of this Policy. This means that we are responsible for deciding how we collect, hold, and process your Personal Information (as defined below). It is important that you read this Policy, together with any other privacy notice we may provide on specific occasions, when we are collecting or processing your Personal Information.
IN GENERAL, YOU CAN VISIT OUR WEBSITE WITHOUT REVEALING ANY PERSONAL INFORMATION (DEFINED BELOW) ABOUT YOURSELF TO US. WE DO NOT COLLECT, OR REQUIRE INDIVIDUALS TO TRANSMIT, ANY PERSONALLY IDENTIFIABLE FINANCIAL INFORMATION (AS DEFINED UNDER FEDERAL REGULATION P (12 C.F.R. § 1016.3(Q)), SOCIAL SECURITY NUMBERS (SSNS), OR DRIVER’S LICENSE NUMBERS THROUGH OUR WEBSITE. WE ALSO DO NOT AUTOMATICALLY COLLECT ANY OTHER PERSONAL INFORMATION ABOUT YOU THROUGH OUR WEBSITE. THE ONLY PERSONAL INFORMATION WE COLLECT IS INFORMATION YOU CHOOSE TO PROVIDE US THROUGH VOLUNTARY FORMS, FEATURES, AND SERVICES ON OUR WEBSITE.
INFORMATION WE COLLECT
Types of Information
We collect various kinds of information that you provide to us through the Website as well as information we obtain from your use of the Services. Some of the types of information that we collect include:
“Personal Information”—information associated with or used to identify or contact a specific person. Personal Information includes: (1) contact data (such as name, e-mail address, telephone number and employer); (2) demographic data (zip code); and (3) employment information (such as education, experience, and interest in certain fields).
This definition of “Personal Information” encompasses the GDPR definition of “Personal Data,” which can be found at https://gdpr-info.eu/art-4-gdpr/. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified. It does not include ‘anonymous data’ (i.e., information where the identity of the individual has been permanently removed). However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
“Usage Data”—information about an individual’s online activity that, by itself, does not identify the individual, such as:
- technical information, including your browser type, service provider, IP address, operating system and webpages visited; and
- information about what you’ve searched for and looked at while using the Website or Services.
“Location Data” is information collected about the location of a mobile device or computer, including:
- the location of the mobile device or computer used to access the Services derived from GPS or WiFi use; and
- other information made available by a user or others that indicates the current or prior location of the user, such as information that you or others post indicating your location, or geotag information in photographs.
We do not collect any “Special Categories of Personal Information” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
How We Collect Information
From You. We collect information from you when you:
- Use the Services. We collect Personal Information from you when you use our Services, contact us for help or information, or otherwise voluntarily provide your Personal Information to us. We collect the information and content that you submit to us, such as when you enter comments, request information, submit a review, live chat, or apply for a job.
From Our Business Partners and Service Providers. Third parties that assist us with our business operations also collect information (including Personal Information, Usage Data and Location Data) about you in connection with the Services and share it with us. For example, our vendors collect and share information with us to help us detect and prevent fraud. You agree we may rely on any such third party collection and sharing as being authorized by you, and we are under no obligation to verify the authorization of any information shared with us by a third party.
Usage Data. We automatically collect Usage Data when you interact with the Website.
Location Data. We automatically collect Location Data when you interact with the Website.
Types of cookies we use:
|Olivia Chat||The Paradox cookie used by the Olivia Chat program allows us to identify the job seeker when they visit the career site. If they have spoken to Olivia previously, we are able to show their previous conversation.|
|Twitter Pixel||Twitter Pixel shows us how web users react to our advertisements shown on Twitter. It also lets us measure our return on investment from a particular ad/ad campaign.|
|Facebook Pixel||Facebook Pixel is embedded within our Site to link the use of different websites and viewing of different advertisements by Visitors, as well as to optimize and convert the outcome of such analysis.|
Our Website may also use web beacons or pixel tags and other similar technologies, which are not placed on your computer but instead are embedded on certain pages of our Website or in emails. When you visit a page or read an email with a pixel tag, web beacon, or other similar technology, a generic notice of your interaction is generated.
Opting Out of Cookies, Web Beacons, and Similar Technologies. You can manage cookie preferences and opt out of having cookies and other similar collection technologies used by adjusting the settings on your web browser. If you do not want cookies stored on your computer, you can change the settings on your browser to notify you when a cookie is about to be saved or block cookies entirely. How to access these settings, which settings are available, and how to turn on these settings varies by browser type and we encourage you to further investigate your browser’s privacy settings if you wish to opt out or adjust these settings in any way. If you choose to decline or block cookies, you may not be able to fully utilize all of the interactive features of the Website.
You cannot decline web beacons; however, setting your browser to decline cookies or to prompt you for a response, or installing an ad-blocker, may keep web beacons from tracking your activity.
How We Use Your Information
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Depending on your role, we may process your Personal Information for one or more of the following purposes:
We may use the information we collect for any of the following purposes:
- to provide the Services to you;
- to operate, improve and personalize the products and Services we offer, and to give each user a more consistent and personalized experience when interacting with us;
- for customer service, security, to detect fraud or illegal activities, or for archival and backup purposes in connection with the provision of the Services;
- to communicate with users to inform when a relevant post has been added to the Website;
- to better understand how users access and use the Website and the Services, for the purposes of trying to improve the Website and the Services and to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users’ usage of the Website and the Services;
- to help us develop new products and Services and improve our existing products and Services;
- to provide users with relevant advertising and direct marketing;
- to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Services; and
- for other business or marketing purposes as determined by us in our sole discretion.
Aggregation and Linking of Information. In order to provide you with a better experience and to improve the Services, information collected through the Website may be used in an aggregated or individualized manner. For example, Personal Information collected during use of the Services may be used to suggest particular content that can be made available to you in connection with another of the Services or be used to try to present more relevant advertising in another of the Services.
If we need to use your Personal Information for an unrelated purpose, we will update this Policy.
How We Share and Disclose Usage Data and Location Data
How We Share and Disclose Your Personal Information
We may share and disclose your Personal Information as follows:
When you consent. We may share Personal Information with third parties if you have given us your consent to do so.
To perform services. We may disclose Personal Information to third parties in order to perform services requested or functions initiated by users, such as adding users to mailing lists. In addition, we may disclose Personal Information in order to identify a user in connection with communications sent through the Website. We also may offer users the opportunity to share information with friends and other users through the Website.
With third party service providers performing services on our behalf. We share information, including Personal Information, with our service providers to perform the functions for which we engage them (such as hosting and data analyses). We may share information as needed to operate other related services.
For legal purposes. We also may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Information as required to pursue available remedies or limit damages we may sustain.
In aggregated form. We may share Personal Information about you in an aggregated form—that is, in a statistical or summary form that does not include any personal identifiers—with third parties in order to discover and reveal trends about how users interact with our Website.
During corporate changes. We may transfer information, including your Personal Information, in connection with a merger, sale, bankruptcy, restructuring, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part) to any actual or potential purchasers, transferees, or owners.
In compliance with applicable law. We may share or disclose your Personal Information in any way that is legally permissible, including, without limitation, to conduct research and surveys and to inform you of products or Services available from us or our affiliates.
Information Storage and Security
We may retain information as long as it is necessary and relevant for our operations. We also may retain Personal Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, and other actions permitted by law.
We employ industry-standard security measures designed to protect the security of all information submitted through the Website. However, the security of information transmitted through the internet can never be guaranteed. Therefore, we make no warranties or representations regarding the security of your information. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of the Website. In order to protect you and your data, we may suspend your use of the Website or Services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of the Website is restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.
It is important to us that you are able to access and review the Personal Information we have about you and make corrections to it or delete it, as necessary. If you have any questions about how to access your Personal Information, or want to make changes to your Personal Information we have stored, please contact us at website@Interstates.com. We may require you to verify your identity before we change our records.
Links, Widgets, Embeds, Social Media, and Other Third Party Features
Disclaimer: Not Child-Directed
Our Website is not directed to anyone under the age of 18, and by using this Website, you are confirming that you are 18 years of age or older. While this Website does not knowingly solicit, collect or store information of children under 13, it is possible that through fraud or deceit we may receive information pertaining to children under age 13. Parents or guardians may report unauthorized use of our Website by a child by contacting us at website@Interstates.com. If we are notified of unauthorized use by a child under 13, upon verifying the information, we will immediately delete the unauthorized information from our servers and records.
Your California Privacy Rights
California Civil Code Section 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to website@Interstates.com.
If you have a complaint regarding this Notice or with our practices in relation to your Personal Information, you may contact us at website@Interstates.com. We will reply to your complaint as soon as we can.
If you are located in the EU, under certain circumstances, you may have certain legal rights under the GDPR, including:
- To access the personal data we maintain about you
- To receive information about how we process your personal data
- To correct your personal data
- To have your personal data erased
- To object to or restrict how we process your personal data
- To request your personal data be transferred to a third party
- To withdraw any consent you may have given us to process your personal data
We may rely upon one or more legal bases defined in the GDPR to collect, use, share and otherwise process the personal information of individual located in the EU, including where:
- Necessary to perform a contract we have with you;
- You have consented to the processing (in which case you may revoke your consent at any time);
- Necessary for us to comply with a legal obligation, or to establish, exercise or defend legal claims;
- Necessary to protect your vital interests or those of others;
- Necessary in the public interest; and
- Necessary for the purposes of our legitimate interests or those of a third party, provided that those interests are not overridden by your interests or fundamental rights and freedoms.
Where we collect, use, disclose and otherwise process your information based on legitimate interests, we may rely on the following interests:
- Keeping our services safe and secure: We use your information in certain instances as necessary to pursue our and your legitimate interests of keeping some of our services, such as our domains, websites, apps, offices and events, safe and secure. For example, we collect IP addresses and process log files to ensure our website and apps are not subject to fraudulent access.
- Marketing our services: We use your information as necessary to pursue our legitimate interests in marketing our services.
- Providing, improving and developing the services: We use your information as necessary to pursue our legitimate interests in tailoring and improving our services.
- Providing seamless services with affiliates of The Harbor Group: In some cases, the services require the engagement of, or sharing of your information with, other companies affiliated with The Harbor Group.
If you are an EU resident, you have the right to object to our processing that is based on legitimate interests by contacting us at the address or number below. If you are located in the EU and you believe that we have infringed your rights under the GDPR, please contact us by sending an email to website@Interstates.com or calling us at: (712)722-1662.
How to Contact Us