Section 1 – Introduction:
Retinalinkglobal.com (the “Website”) is owned and operated by RetinaLink LLC (the “Company, “we” or “us”). The purpose of this Privacy Policy is to explain how we collect, use, store, share, and protect the personal information of users (“you” or “your”) of the Website.
When we refer to “personal information” we mean information that identifies, or is reasonably capable of being directly or indirectly linked to, a particular individual or household, such as the individual’s name, postal address, email address, social media profile, and telephone number. Personal information includes “personal information” as defined by the California Consumer Privacy Act of 2018 (the “CCPA”) and “personal data” as defined by the European Union’s General Data Protection Regulation (the “GDPR”). When anonymous information is directly or indirectly associated with personal information, the resulting information is also treated as personal information. Personal information does not include aggregate information that we collect about the use of our Website or about a group or category of users from which individual identities or other personal information has been removed. Nor does it include usage information or device identifiers not connected to personal information.
Your use of the Website and any personal information you provide via the Website or through other official contact with us remains subject to this Privacy Policy, as well as the Terms of Use and/or other stated policies, which we encourage you to read carefully. Please note, this Privacy Policy does not apply to the privacy practices of third parties. We encourage you to review the privacy policies of any third-party application or website before providing any information to, or through, them.
Section 2 – Information We Collect:
Information You Voluntarily Provide. Personal information that we collect or have access to includes information you supply when you (i) contact us through the Website or (ii) participate in any online forums or communities offered through the Website or our social media accounts.
- When you contact us through the Website, you do so through an online form that asks you to provide your full name, email address, and your message, which message may contain as much or as little personal information as you choose to provide. You may also contact us through email, in which case we will collect your email address, name, and any other personal information you choose to provide us. We of course remind you not to provide us with any individually identifiable health information under HIPAA or any sensitive personal information, such as social security numbers, credit card information, driver’s license information, race or ethnicity, or political or religious affiliation.
- Our Website does not currently include any comment or chat features, but it does contain links to our social media pages on Facebook, LinkedIn, Instagram, and Twitter, as well as our YouTube page. On those websites and applications, users can send us messages and post public comments, which can include photos and other personal information users choose to provide. We have access to all personal information that you and other users choose to post on our social media pages. We encourage you to exercise caution and use discretion when posting through those forums and to maintain compliance with all applicable laws and rules of conduct. We also encourage you to review the privacy policies of those third-party applications, as this Privacy Policy does not apply to the privacy practices of third parties, such as Facebook, LinkedIn, Instagram, Twitter, and YouTube.
Information Automatically Collected.
- Cookies. From time to time, we may use the standard “cookies” feature of major browser applications that allows us to store a small piece of data on your computer about your visit to our Website, https://policies.google.com/technologies/partner-sites?hl=enGB&gl=uk
We do not set any personal information in cookies, nor do we employ any data capture mechanisms on our Website other than cookies. Cookies help us learn which areas of our Website are useful and which areas need improvement. We permit third-party advertisers to provide advertisements to you through the Website. Such advertisers may download cookies onto your computer, which would enable them to recognize your computer each time they send you an advertisement. As a result, the advertising network would have the ability to deliver targeted advertisements that they believe would be of most interest to you. We do not have access to or control of the cookies that may be placed by third-party advertisers.
- User Devise and Activity Information. Information such as, your internet protocol (IP) address, browser type, browser version, the type of mobile device you use, your mobile device unique ID, your operating system, browser type, browser version, and the pages of the Website you visit and date, time, and duration of your visit, is automatically collected when you use the Website. We use this information to analyze trends, administer the Website, track users’ movements around the Website and gather demographic information about our user base as a whole. Except as noted herein, we do not link this automatically-collected data to personal information.
- Google Analytics. Our Website uses Google Analytics to allow us to better understand how users interact with our Website and assist us in enhancing the Website, promoting content most relevant to our users, and devising marketing strategies. Google Analytics uses first-party cookies and collects data related to users’ devises/browsers, IP addresses, and interactions with the Website, to measure and report statistics about user interactions with our Website. Additionally, Google Analytics uses IP addresses to provide security. Google Analytics prohibits its customers, such as us, from sharing personally identifiable information, such as a user’s email address, mailing address, phone number, precise location, or full name or username, with Google Analytics. To learn more about Google Analytics’ collection and use of your personal information, click here:
- Do Not Track Signals. We do not currently take steps to respond to browsers “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.
Section 3 – How We Use Information We Collect:
Personal Information. We may disclose your personal information, as well as non-personal information, such as aggregate user statistics, demographic information, and usage information, to companies and individuals who perform business functions on our behalf. Such functions may include hosting our Websites, analyzing data, providing technical assistance, or providing content for our Website. All such parties are required to keep your personal information secure and only process it in accordance with our instructions. We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on us, (2) protect and defend our rights or property or the users of the Website, or (3) act under circumstances to protect the safety of the public or users of our Website. We, or our service providers, may use your personal information to do the following:
- enhance our Website and content;
- personalize your experience with our Website based on your individual usage habits;
- provide content or information you request;
- provide notifications;
- recommend content we think would be of interest to you;
- communicate with you about content, services, promotions, and events we offer;
- solicit your feedback;
- post testimonials;
- improve our marketing and promotional efforts;
- respond to your emails, submissions, questions, inquiries, requests, and comments;
- monitor and analyze views and trends and otherwise measure the appeal and effectiveness of our Website and content;
- monitor suspicious or fraudulent activity;
- identify, fix, and troubleshoot bugs and service errors;
- send you confirmations, updates, security alerts, and support-related messages; and
- protect against, identify, investigate, and respond to misuse of our Website or other unlawful behavior.
With your consent, we may use your personal information for a specific purpose not listed above.
Retention of Your Personal Information. We retain your personal information for so long as we have an ongoing legitimate business or legal need to do so. Additionally, you have the ability to disable cookies and other tracking functions through your device or browser.
Anonymous Information. We use anonymous information to analyze our Website traffic, but we do not examine this information for personally identifiable information. In addition, we, or our Website host, may use anonymous IP addresses to help diagnose problems with our server, to administer our Website, or to display the content according to your preferences. Information may also be shared with business partners and advertisers on an aggregate and anonymous basis to help devise marketing strategies.
Section 4 – Security:
We strive to maintain adequate technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. We are not liable for unauthorized disclosure of information that occurs through no fault of our own. If we learn of a data breach that is likely to result in a high risk to your rights and freedoms, we will immediately notify you of such data breach and inform you of (a) the nature of the data breach, (b) the point of contact regarding the data breach, (c) the likely consequences of the data breach, and (d) the measures being taken to address the breach and mitigate its possible risks.
Section 5 – Accuracy of Your Information:
Although we work to ensure that the information we hold about you is accurate and up-to-date, unless we receive an indication otherwise, we can only assume that the information you provide to us is accurate. If you inform us that any of your information processed through our is incorrect, or if we learn that any such information is incorrect, we will work to promptly correct, or if appropriate, erase, such information.
Section 6 – Your California Privacy Rights and Notice at Collection:
This portion of the Privacy Policy is provided under California law, including the California Consumer Privacy Act of 2018 (“CCPA”), and supplements this Privacy Policy by providing certain disclosures to California residents and explaining the privacy rights of California residents.
Categories of Personal Information Collected and Disclosed. Our Website is new, so in the 12 months preceding the date of this Privacy Policy, we have not collected or disclosed any personal information. That said, we intend to collect the following categories of personal information and share them with the following categories of third parties:
A. Identifier, such as, real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
Parties with whom we disclose this category of personal information:
Service providers that perform services on our behalf
With other users – when you share your personal information or otherwise interact in public areas, such as third-party social media platforms, with other users, such information may be viewed by all users and might be shared by other users.
B. Commercial information, including engagement with the Website and content.
Parties with whom we disclose this category of personal information:
Service providers that perform services on our behalf
Advertisers and marketing-related service providers
Social media platforms
C. Internet activity and network activity, including your interactions with the Website, Membership, or content and what led you to the Website.
Parties with whom we disclose this category of personal information:
Service providers that perform services on our behalf
Advertisers and marketing-related service providers
Social media platforms
D. Geolocation data provided through location enabled services such as WiFi and GPS.
Parties with whom we disclose this category of personal information:
Service providers that perform services on our behalf
Advertisers and marketing-related service providers
Social media platforms
E. Inferences, including information about your interests, preferences, and favorites.
Parties with whom we disclose this category of personal information:
Service providers that perform services on our behalf
Advertisers and marketing-related service providers
Social media platforms
F. Additional Information, that you choose to share with us through our Website or on social media platforms.
Parties with whom we disclose this category of personal information:
Service providers that perform services on our behalf
With other users – when you share your personal information or otherwise interact in public areas, such as third-party social media platforms, with other users, such information may be viewed by all users and might be shared by other users.
Categories of Sources of Personal Information. We collect personal information from the following categories of sources:
- Directly from you
- From cookies and similar technologies
- From third-party service providers, data suppliers, and business partners
- From social media platforms and similar services
- From internet service providers
- From operating systems and platforms
Business or Commercial Purposes for Collecting or Sharing Personal Information. See Section 3 – How We Use Information We Collect above for the business or commercial purposes for which we collect or share personal information.
Sale of Personal Information. In the preceding 12 months, we have not sold our users’ personal information, nor do we intend to. However, the term “sale” is defined broadly under the CCPA. As explained above, we do share with our service providers personal information that is necessary for such service provider to perform a business purpose. To the extent our use or disclosure of personal information is interpreted to constitute a “sale” under the CCPA, California residents are entitled to opt-out of the “sale” of their personal information at any time and can do so by contacting us (contact information is below). To our knowledge, we do not sell the personal information of individuals under 16 years old.
Notice of California Residents’ Rights. If you are a resident of California, you have the following rights under the CCPA with respect to your personal information:
- The right to request the deletion of your personal information collected or maintained by us, subject to certain exceptions.
- We may deny your deletion request if retaining the information is necessary for us or our service provider to: complete the transaction for which the personal information is collected, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities; debug products to identify and repair errors that impair existing intended functionality; exercise free speech or ensure the right of another user to exercise his or her free speech, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act; enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; comply with applicable laws; comply with a legal obligation; or make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- The right to opt-out of the sale of your personal information to third parties. We do not sell the personal information of users of our Website. However, the term “sale” is defined broadly under the CCPA. We do share with our service providers personal information that is necessary for such service provider to perform a business purpose. This Privacy Policy describes the limited circumstances in which we share your personal information with third parties. To the extent our use or disclosure of personal information is interpreted to constitute a “sale” under the CCPA, California residents are entitled to opt-out of the “sale” of their personal information at any time and can do so by contacting us as provided below. If, in the future, we do sell users’ personal information to a third party, we will provide users with the opt-out and opt-in rights required under the CCPA.
- The right to request that we provide you with information regarding the processing of your personal information over the preceding 12 months, including the categories of personal information we have collected about you, specific pieces of personal information we have collected about you, sources from which it was collected, categories of personal information disclosed, the business or commercial purpose for collecting or disclosing personal information, and categories of third parties with whom your personal information is shared.
- The right to request that we disclose to you the categories and specific pieces of personal information that we have collected in the preceding 12 months.
- The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred under the CCPA. Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or benefits, or imposing penalties, provide you a different level or quality of goods or services, or suggest that you receive a different price or rate for goods or services or a different level or quality of goods or services, based on your exercise of your rights under the CCPA. If we do choose to offer you financial incentives permitted under the CCPA that result in different price rates, or quality levels, such CCPA-permitted financial incentives will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in any financial incentive program requires your consent, which you may revoke at any time.
To request information regarding our processing of your personal information or request that we delete personal information about you that we have collected, you must submit a verifiable consumer request to us via email or mail addressed to us at the address below.
E-mail: nicole@retinalinkglobal.com
Nicole Sheeler, President
RetinaLink LLC
925 Santa Fe, Suite 103
Weatherford, TX 76086
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request twice within a twelve-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Thus, your verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person.
- Describe your request in sufficient detail that allows us to properly understand, evaluate, and respond to your request.
We will acknowledge receipt of your request and advise you on how long we expect it will take to respond if we are able to verify your identity. We will work to process your request within 45 days pursuant to the CCPA. If we need additional time in order to process your request, we will provide you with an explanation for the delay. If we are unable to honor your request, we will advise you of this fact and provide the reason why.
We will not provide social security numbers, driver’s license numbers, account passwords or security questions and answers, or any specific pieces of information that could lead to unauthorized access, result in identity theft, fraud, or impose an unreasonable risk to data or systems and network security.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that your request warrants a fee, we will inform you of the reason for this decision and provide a cost estimate before completing your request.
Section 7 – UK and EU Residents’ Rights:
If you are located in the European Economic Area or the United Kingdom, you have the rights outlined below with respect to your personal information. When we use the term “processing” or “processor” this refers to the collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, use, transmission, dissemination, combination, erasure, or destruction of information.
Right to Information Regarding the Processing of Your Personal information: You have the right to obtain the following information:
- confirmation of whether and where we are processing your personal information;
- information about the purpose of the processing of your personal information;
- information about the categories of personal information being processed;
- information about the existence of, and an explanation of the logic involved in, any automated processing of your personal information that has a significant effect on you;
- information about the categories of recipients with whom your personal information may be shared; and
- information about the period for which your personal information will be stored or the criteria used to determine that period.
- This Privacy Policy is intended to provide much of the information listed above.
Right to Access to Your Personal information: You may request a copy of your personal information that we, or our third-party processors, collect and maintain. Similarly, you have the right to, when technically feasible, have your personal information transferred to another entity to determine the purpose and means of processing your personal information.
Right to Have Errors Corrected: You have the right to rectification of inaccurate personal information. If you notify us that any of your personal information is inaccurate or incomplete, we have the responsibility to, either directly or through our third-party processors, ensure that such personal information is erased or corrected.
Right to Have Personal information Erased or Processing Restricted: You have the right to have your personal information erased when (i) the personal information is no longer needed for its original purpose and no new lawful purpose exists; (ii) the personal information is being processed based solely on your consent and you withdraw your consent; or (iii) the personal information is being processed unlawfully. Similarly, you have the right to limit our use of your personal information when (i) the personal information is no longer needed for its original purpose, but we still need to maintain the personal information to establish, exercise, or defend legal rights; (ii) the personal information is being processed unlawfully; or (iii) the accuracy of the personal information is contested, but then our use of the personal information is restricted for only so long as it takes to verify the accuracy of the personal information.
Right to Object to Processing of Your Personal information: You have the right to object to our processing of your personal information if the basis for that processing is (a) public interest; or (b) our own legitimate interests in doing so. Additionally, you have the right to object to the processing of your personal information for the purpose of direct marketing or statistical purposes.
Right to Lodge a Complaint with a Supervising Authority: You have the right to lodge a complaint concerning the processing of your personal information with your country’s independent public authority designated to act as its data protection “supervising authority” under the GDPR.
Right to Withdraw Consent to the Processing of Your Personal information: You have the right to refuse to consent to, and to withdraw your consent to, the processing of your personal information. To the extent we rely on your consent to collect and store your information, when you withdraw such consent we must cease collection and retention of such information. Note, however, we do not require your consent to collect or otherwise process your personal information if (a) such information is not personal information or (b) such information is personal information and we have another lawful basis for processing the information (for instance, processing of such information is necessary for the purpose of a legitimate interest of ours that is not overridden by your interests or fundamental rights and freedoms).
Responses to your requests to us regarding your personal information will be provided free of charge (including copies of materials), except that we may charge a reasonable fee for any repetitive requests, manifestly unfounded or excessive requests, or further copies. Similarly, we may refuse to act upon requests that are manifestly unfounded or excessive.
Lawful Basis for Processing Personal Data. We process personal information of users of our Website and content, whether directly or through third-party processors, as needed for purposes of our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of our Website users. Our legitimate interests include responding to communications initiated by you, performing services, informing you of relevant content or changes to our Website, and protecting the security of the Website and your personal information. In some instances, we might request your consent to process your personal information for a particular purpose and in such instances the lawful basis for such processing is your consent.
Section 8 – Notice to Non-U.S. Residents:
Our Website and servers are operated in the United States. If you are located outside of the United States, please be aware that your personal information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Website, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States.
Section 9 – Children:
The Website and content are not intended for use by children and, as such, are not directed to children. Moreover, we will not knowingly allow anyone under the age of 16 to provide us with personal information. Individuals under the age of 13, and in some instances 16, cannot lawfully consent to collection of their personal information. If you are under the age of 16, please do not provide us with any personal information (such as your name, email address, or phone number). If you become aware that your child (under the age of 16) has provided us with personal information, please contact us immediately. Parents have rights under the Children’s Online Privacy Protection Act (“COPPA”) to control what information is collected from their young children online and we respect those rights.
Section 10 – How to Contact Us:
If you have any questions, concerns, or requests related to this Privacy Policy or our practices related to our Website or your personal information, please contact us via nicole@retinalinkglobal.com. If we have reasonable doubts about the authenticity of any request to us, we may request additional information necessary to confirm your identity.
Section 11 – Website Provider – Host Information:
Our Website is hosted by:
Overit
435 New Scotland Ave.
Albany, NY 12208Tel: 888-713-6304
You can find the Overit’s Privacy Policy here: https://overit.com/privacy
Section 12 – Updates and Changes to Our Privacy Policy:
We may modify this Privacy Policy from time to time. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices. If we have your email address, we might notify you of any changes to our Privacy Policy when they occur.