Effective Date: 2019/04/16
2. INFORMATION MAXMIND COLLECTS
Information You Provide
We collect information that you voluntarily provide to us while using the Services, such as when you register an account, make a purchase of one of our products or services, respond to our customer surveys, submit a data correction request, communicate with our customer service team, or apply for a job.
The information we collect includes information relating to identified or identifiable natural persons. Some examples of information we collect include the following: contact data, including your first and last name, telephone number, email address, and postal address; billing information; credentials, including your passwords; content data, including the content of the messages you send to us; IP addresses or IP ranges you submit; and resume data, including data necessary to consider you for a job opening (such as your employment history, writing samples, and references). We also use third party payment processes to collect and process payment data, including your payment instrument and security code associated with your payment instrument, on our behalf.
You may choose to voluntarily submit other information to us through the Services that we do not request, and, in such instances, you are solely responsible for such information.
Information Collected Automatically
We automatically collect information about your device and how your device interacts with our Service. The types of data we collect and the methods by which we may collect such data include the following:
Cookies, Web Beacons, and Embedded Scripts
MaxMind may also use web beacons, small graphic images or other web programming code (also known as "1x1 GIFs" or "clear GIFs"), which may be included in our web pages and e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
MaxMind may also use embedded scripts in connection with the provision of its Services. "Embedded scripts" are programming code designed to collect information about your interactions with a website, such as the links you click on, and may assist our customers in providing us with information used to provide the Services. The code is temporarily downloaded onto your device from our web server, our customer's web server, or a third party service provider, is active only while you are connected to the website containing the embedded script, and is deactivated or deleted thereafter.
Log File Information
Your web browser automatically sends information to every website you visit, including ours. For example, our server logs may receive and record information such as the pages you access on the Services, referring URLs, your browser type, your operating system, the date and time of your visit, and the duration of your visit to each page.
User Agent Strings
Log file information may also include a user agent string, a series of characters automatically sent with your Internet requests that provide information necessary for smooth Internet communications, such as the operating system and browser you used. A user agent string might be used to identify the device originating a message.
MaxMind may also request access to or otherwise receive information about your device location when you access the Services. Your location data may be based on your IP address and other location-aware technologies. We use location data in connection with providing the Services and to help improve the Services.
Unique Identification Number
Information MaxMind Receives from Third Parties
3. HOW MAXMIND USES INFORMATION
We use information for our legitimate interests, including for the following purposes:
Providing Our Services
As stated above, MaxMind uses information such as your first and last name, telephone number, email address, postal address, billing information, or other contact information we obtain from you, our customers, or our business partners, for the purposes of providing, enhancing, or improving our IP geolocation, fraud detection, demographic targeting, databases, and other services and products.
Communications with You
MaxMind maintains one or more contact lists (with email addresses and other information) to allow MaxMind to communicate with individuals who do business with MaxMind or who have expressed an interest in the Services. We may contact you to confirm your purchases or respond to requests that you make, notify you of changes to your account or the Services, for marketing purposes, or to otherwise inform you of information related to our business or your account with us.
Website Administration and Customization
MaxMind uses the information we collect about you for a variety of website administration and customization purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customize features and advertising that appear on and off the Services, deliver the Services content to you, measure Services traffic, measure user interests and traffic patterns, and improve the Services.
Usage of IP Addresses
The MaxMind services, including the minFraud service, use IP addresses to help organizations detect and prevent fraudulent activity. Among other things, MaxMind obtains IP addresses and order information (including customer name and billing address) through its minFraud service. MaxMind uses the billing location from this data along with other data to create databases that pair IP addresses with the locations in which they are likely being used, down to a postal code level of resolution.
We also use information with your consent, including for the following purposes: to allow you to participate in our surveys; to serve advertising tailored to your interests on our Services and third party services; and to fulfill any other purpose disclosed to you and with your consent.
Some of our lawful bases for processing your information stem from our customers on whose behalf we provide services.
MaxMind uses information that does not identify you for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see Section 6 below.
4. HOW MAXMIND SHARES INFORMATION
Sharing with Our Service Providers
We provide your information to our third party service providers, contractors, business partners, and advertisers, for the purpose of delivering services to you as well as for purposes related to Services administration and operation, including conducting analytics and helping us with sales tax compliance. When sharing information for the purpose of providing you with the services you request, we will share your information only as necessary for the third party working on MaxMind's behalf to complete its work for us. For example, if you use a credit or debit card to complete a transaction on the Services, we will share your credit or debit card number with a payment processing and/or a fulfillment company in order to complete your transaction.
Sharing of Databases
We share your information with our customers in connection with us processing your information on their behalf. For example, we share your information with our customers to respond to your questions and comments, fulfill your requests, and otherwise comply with applicable law.
We may share your information with third parties for purposes of providing you with tailored advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.
MaxMind integrates with the service Have I Been Pwned to verify whether your account password has previously appeared in a third party data breach, which may allow MaxMind to evaluate the strength of the password, provide a warning, and/or block the password outright. We are not responsible for the effectiveness or accuracy of their information. For more information on Have I Been Pwned, please visit the website at https://haveibeenpwned.com.
Security and Compliance with the Law
We reserve the right to disclose your information to appropriate third parties if we are required to do so by law or we believe that such action is necessary in order (a) to comply with a legal process such as a search warrant, subpoena, or court order; (b) to protect the company's rights and property; (c) to investigate reports of users sending material using a false email address or users sending harassing, threatening, or abusive messages; (d) to protect against misuse or unauthorized use of the Website or Services; or (e) to respond to emergencies, such as when we believe someone's physical safety is at risk. MaxMind may be required to disclose information in a life-threatening emergency or in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Transfer of Business
Over time, MaxMind may buy or sell various assets. In the event that we sell some or all of our assets, or our company is acquired by another company, or during the negotiation of such sale or acquisition, our databases and any information we collect may be among the transferred or negotiated assets.
We may share your information for any other purpose disclosed to you and with your consent.
Without limiting the foregoing, in our sole discretion, MaxMind shares information that does not identify you with third parties, including our customers, for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see Section 6 below.
5. THIRD PARTY ANALYTICS; ONLINE TRACKING
6. YOUR RIGHTS AND CHOICES
Opt-Out of Email Communications
If you are a registered member of the Services, you can make changes to your account information by logging into the Website and modifying your preferences. If you do not wish to receive email notifications from us, you may opt-out by contacting us at email@example.com with your request. In addition, certain email communications we send to you, such as newsletters and promotional announcements, contain a clearly worded "Opt-Out" or "Unsubscribe" link allowing you to withdraw your permission for future mailings. Please note that we reserve the right to send you certain communications relating to your account or use of the Services (for example, administrative and service announcements) and these transactional account messages may be unaffected even if you opt-out from marketing communications.
Opt-Out of Database Sharing
(a) You will only be able to opt-out to the extent that we can identify information we have about you. It is possible that even after you opt-out our databases will contain some residual information about you.
(b) MaxMind will cease sharing your information in any databases created after your opt-out date. Our customers may continue to have access to legacy database information.
(c) Even if you do opt-out of having us share the information we have about you in our databases, MaxMind must continue to gather, retain, use, and share such information for fraud detection purposes. This is because your IP address may be associated with information that we have received from numerous customers.
(d) If you opt-out based on your IP address, MaxMind will process the opt-out only if the IP address is associated with a single individual or household. Many IP addresses are shared by several if not hundreds of devices, and MaxMind cannot process an opt-out for sharing for such IP addresses. Further, since some IP address assignments are subject to change or are dynamic, MaxMind will only process an opt-out for sharing of information related to such an IP address until such time that MaxMind reasonably believes the IP address has been assigned to another device (however, in no event will MaxMind remove such an opt out in a time period of less than one year).
Data subjects in Europe have additional rights as set forth in the section entitled "European Privacy Rights" below.
Blocking or Deleting Cookies
You can manually delete cookies, which are normally located in your temporary Internet folder or cookie folder. You can also reset the preferences in your web browser to notify you when you have received a cookie or, alternatively, to refuse to accept cookies. Deleting or blocking cookies will prohibit your ability to make online purchases on the Services and to use and access portions of the Services that require logging in with a username and password, and may affect other functionality.
Analytics and Advertising
Some of the advertisers and service providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about the DAA and how you can exercise certain choices regarding interest-based advertising, visit https://www.aboutads.info/choices. Some of these companies may also be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, see https://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). MaxMind is not responsible for effectiveness of, or compliance with, any third-parties' opt-out options or programs or the accuracy of their statements regarding their programs.
Your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit; however, there is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, the Website currently does not alter its practices when it receives a "Do Not Track" signal from a visitor's browser. To find out more about "Do Not Track," you may wish to visit https://www.allaboutdnt.com.
Your California Privacy Rights
California's "Shine the Light" law permits customers in California to request certain details about how a business shares their personal information as defined by "Shine the Light" with third parties (and in some cases affiliates) for those third parties' or affiliates' own direct marketing purposes.
MaxMind does not share personal information as defined under California's "Shine the Light" law with third parties or affiliates for those third parties' or affiliates' direct marketing purposes. California customers may request information about our compliance with this law by contacting us by e-mail at firstname.lastname@example.org or by mail at the address set forth in Section 12 below. Any such inquiry must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email or mail address.
European Privacy Rights
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Services. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Services. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us using the information at Section 12 below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If your information has been processed by us on behalf of one of our customers and you wish to exercise any rights you have with such information, please inquire with our customer directly. If you wish to make your request directly to MaxMind, please provide the name of the MaxMind customer on whose behalf MaxMind processes your information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.
If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.
7. INTERNATIONAL TRANSFER AND PRIVACY SHIELD
MaxMind complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data from the European Union and Switzerland to the United States, respectively. MaxMind has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.
MaxMind is subject to the investigatory and enforcement jurisdiction of the United States Federal Trade Commission in complying with its commitments under the Privacy Shield Principles. We hereby affirm our commitment to subject to the Privacy Shield Principles all personal data transferred from the European Union and Switzerland in reliance on Privacy Shield. This means that MaxMind shall be liable to you for any third party agent to which we transfer your personal data and that processes such personal data in a manner that violates the Privacy Shield Principles, unless we can demonstrate that we are not responsible for the resulting damages. MaxMind takes reasonable steps to ensure that personal data is relevant to its intended use and is accurate, complete, and current and retained only as long as needed for an intended or compatible purpose.
MaxMind implements reasonable administrative, physical, and technical security measures to help protect your data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no physical or electronic security system is impenetrable. MaxMind cannot guarantee the security of the Service's servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.
9. POLICY REGARDING CHILDREN
The Services are not intended for use by children under the age of thirteen years old. MaxMind does not knowingly collect information from children under the age of thirteen. If you are a parent or guardian, and believe we have collected information about your child in violation of this policy, please contact us at the address set forth in Section 12 below.
11. DATA CONTROLLER
EU data protection law makes a distinction between organizations that process personal data for their own purposes (known as "controllers") and organizations that process personal data on behalf of other organizations (known as "processors").
MaxMind also operates as a controller with respect to certain of its services and/or databases. For example, MaxMind operates as a controller in connection with personal data collected from visitors through its website, including through data correction requests. Also, when MaxMind combines personal data from different customers, like many kinds of analytics services, it may do this both as a processor at its customers' instruction and as a controller itself for the purpose of providing services to all of its customers. For example, MaxMind may process and aggregate some of the personal data that a customer shares with MaxMind in order to make that personal data part of another database for one or more other services provided to MaxMind customers.
If you are a data subject located in Europe and want to learn more about how to exercise your rights, please see the section above entitled "European Privacy Rights".
12. CONTACT FOR ADDITIONAL INFORMATION, OPTING OUT, DATA ACCESS AND CORRECTION, AND DISPUTES
By email: email@example.com
Jason Ketola (Privacy Agent)
14 Spring Street, Suite 3
Waltham, MA 02451
For EU-specific requests, including our compliance with Privacy Shield, please contact our Data Protection Officer at:
By email: firstname.lastname@example.org
Data Protection Officer
14 Spring Street, Suite 3
Waltham, MA 02451