Privacy Policy

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.

This Privacy Policy describes:

  • 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.

Please note that this Privacy Policy does not apply to information collected by third-party websites, applications, or services that you may access through the Website (“Services”). Your interaction with any third party website, application or Services will be governed by the privacy policy of the third party providing such website, application or service.  This Privacy Policy applies to information we gather or you submit or provide to us through our Website.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you submit information to us or otherwise use the Website, you consent to the collection and processing of your information as described in this Privacy Policy.

By using the Website, you agree to accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy.  By using this Website, or continuing to use this Website, you also agree to our Terms and Conditions of Use (“Terms”).

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.

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE WEBSITE OR ANY OF THE SERVICES AVAILABLE THROUGH THE WEBSITE (“SERVICES”).

The Effective Date of this Privacy Policy is set forth at the top of this Policy. Your continued use of the Website or the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

GENERAL

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.

Our Website automatically collects your Usage Data and Location Data (defined below).  The Usage Data and Location Data we automatically collect does not enable us to personally identify you and is used to better understand our Website traffic, analyze the interests of our Website users, improve our Website and diagnose technical errors, and for business or marketing purposes.  Although the Usage Data and Location Data we automatically collect does not enable us to personally identify you, if your Usage Data or Location Data becomes linked to your Personal Information, such information may be shared according to how we share Personal Information as described in this Privacy Policy.

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

Whether we collect certain types of information and how we process it depends on how you use and access the Website and our Services. Some information is collected automatically through use of cookies and similar data collection tools. We collect information about you in the following ways:

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.
  • Connect with social media though the Services. We may offer you the ability to use Facebook Connect or other social media services (collectively, “social media”) in conjunction with certain Services. When you access the Website or Services through your Facebook or other social media account, we may, depending on your privacy settings, have access to information that you have provided to the social media platform. We may use this information for the purposes described in this Privacy Policy. When you associate your social media account with the Services and authorize us to have access to this information, you agree that we may collect, use and store the information provided by social media services as described in this Privacy Policy.
  • When you complete a market research survey. We may offer you the ability to complete a market research survey in conjunction with certain Services. When you access the Website to complete a market research survey, you agree we may collect, use, and store the information you provide in response to the survey for the purposes described in this Privacy Policy.

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.

From Cookies and Other Data Collection Tools. Our Website uses cookies and other similar technologies which are automatically generated, sent to your browser, and stored on your hard drive to record information about how and when you use our Website.  These cookies and other similar technologies identify a web browser on a specific computer or device and reveal certain non-personally identifiable information such as browser type, language, time zone, and operating system.  The cookies and other similar technologies used by our Website do not identify the user personally, but allow the user to remain anonymous.  Our Website may still be used with cookies disabled, but some Website functionality may be impaired.

Types of cookies we use:

NameDescription
Google AnalyticsGoogle Analytics uses “cookies”, to help the Website analyze how users use the websites, applications or services. The information generated by the cookie about your use of the websites, applications or services (including your IP address) will be transmitted to and stored by Google on servers. Google will use this information for the purpose of evaluating your use of the Website, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser or within the application, however please note that if you do this you may not be able to use the full functionality of the Website.
Google Adwords RemarketingThe Website uses Google AdWords Remarketing to advertise on third-party websites to previous visitors to our site. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network. Third-party vendors, including Google, use cookies to display ads based on someone’s past visits to the Website. Of course, any data collected will be used in accordance with our own privacy policy, as well as Google’s privacy policies.
ClickDimensions  We use ClickDimensions marketing and analysis software. ClickDimensions collects and analyzes data about user behavior on specific websites. Such data include visits to websites and their subpages, the length of time spent on the website, and the website from which the user accessed the website that uses ClickDimensions. The purpose of using ClickDimensions is the provision of targeted information on the basis of your behavior on the Website (including its subpages) and the related optimization of our marketing activities. ClickDimensions uses cookies that are stored on your computer and that enable analysis of your use of our website. In general, the data stored in the cookie are transmitted to a ClickDimensions server and stored there. The data transmitted to ClickDimensions are used on our behalf to analyze the use of the Website, to compile website activity reports, and to perform further services related to website use and internet use.
Olivia ChatThe 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 PixelTwitter 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 PixelFacebook 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.

Non-personally identifiable information collected through our Website may be used in aggregate for statistical purposes, and some of our analytics and digital marketing tools may combine the non-personally identifiable information collected from our Website with non-personally identifiable information gathered from you through other websites for target advertising, remarketing, retargeting, or tracking referral purposes.  Our third-party vendors, like Google and Facebook, use cookies, web beacons, and similar technologies from our Website and generated from their systems, to: (i) serve ads to you based on past visits to our Website; (ii) to collect or receive information from our Website and elsewhere on the internet, and use that information to provide measurement services and target ads; and (iii) show you our ads on websites and apps across the Internet.  Your use of other websites and apps across the Internet is governed by the privacy policies of those websites and apps.

Our servers also log non-personally identifiable information about our Website users and their interactions with our Website.  All non-personally identifiable information we gather using cookies, pixel tags, web beacons, server logs, or other similar technologies are used as described in this Privacy Policy.  For information on how to opt-out of having cookies, web beacons, and other similar technologies used on your web browser, please see the “Opting Out of Cookies, Web Beacons, and Similar Technologies” section of this Privacy Policy.

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 can opt out of a third-party vendor’s use of cookies, web beacons, and similar technologies by visiting the Network Advertising Initiative opt-out page, or learn more about your choices for limiting or disabling these tools by visiting http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.

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.

Do Not Track Signals.  Some browsers may send Do Not Track (DNT) signals to our Website.  Our Website does not currently respond to these DNT signals, and Website users are subject to the same information tracking and use as detailed in this Privacy Policy.

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 enforce our Privacy Policy, Terms, or other applicable policies;
  • 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.

We may combine the information we collect from you with information from other sources and use the combined information as described in this Privacy Policy.  Usage Data and Location Data we collect may become linked to Personal Information if you provide Personal Information to us through our Website.  Any Usage Data or Location Data linked to Personal Information is subject to our Personal Information sharing practices detailed in this Privacy Policy.

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

The Usage and Location Data that is collected about your visit to our Website is used for analytics purposes to better understand our Website traffic, analyze the interests of our Website users, improve our Website and diagnose technical errors, and for business or marketing purposes as determined by us in our sole discretion.   This information may be aggregated and shared with third parties, but will not identify you personally.  However, as noted above, the Usage and Location Data we collect may become linked to personally identifiable information if you provide Personal Information to us through our Website.  Any Usage or Location Data linked to Personal Information is subject to our Personal Information sharing practices detailed in the “How We Share and Disclose Your Personal Information” section of this Privacy Policy.

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.

Your Rights

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

Our Website may provide links to other websites for the convenience of our Website users.  Our Website may also make use of widgets, embeds, social media, or other third party features that are hosted by a third party or hosted directly on our Website.  Your interactions with any link or third party widget, embed, social media, or other feature are governed by the privacy policy of the third party providing the widget, embed, social media, or other third party feature, or the privacy policy of the linked website.  The privacy policies of third parties may be substantially different than this privacy policy, and any personally identifiable information collected by or provided to third parties will be guided by the privacy policies of such third parties. We neither own nor control third party websites, widgets, embeds, social media, or other features that are accessible through this Website. Therefore, before visiting the website of a third party, or making use of a third party feature on our Website, whether by means of widget, embed, social media feature, or otherwise, you should first consult that third party’s privacy policy (if any) and inform yourself of the privacy practices (if any) used by that third party.

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.

Complaints

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.

GDPR Notice

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.

Policy Changes

We reserve the right to change this Privacy Policy at any time without advance notice to you.  Each time any content in our Privacy Policy changes, we will update the Effective Date on the Privacy Policy available through our Website.  Your use of the Website or Services after the Effective Date constitutes your consent to be subject to our then-current and active Privacy Policy. We encourage you to review our Privacy Policy for every new or continued use of our Website.

How to Contact Us

If you have questions about our Privacy Policy or seek to contact us in any way about our Privacy Policy, please email us at website@Interstates.com.

Previous Privacy Policies: Privacy Policy April 2018