Updated as of: September 15th, 2020
Types of Data Collected
We gather Personal Data and Other Data (as described below).
Collection of Personal Data
Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number (“Personal Data”). We may need to collect and process Personal Data in order to provide requested information, products or services to you (including the Site) or because we are legally required to do so:
- • Whiterock requests Personal Data from you if the Site requires registration. The registration process requests that you provide your name, business
email address, business address, business phone number, and company affiliation, and agree to the User Agreement presented at the time of
- • Whiterock may receive Personal Data from social media platforms. For example, if you elect to use your social media credentials to log-in to your
Site account, certain Personal Data from your social media account will be shared with us, which may include Personal Data that is part of your social
- • Whiterock may collect Personal Data voluntarily provided by you, including in emails to the Site, online forms, order and registration forms, surveys,
promotion participation, phone calls and online chats with Whiterock customer service and through other means.
- • We may use third-party payment services (each, a “Payment Service”) to collect payments made through the Site. If you wish to make a payment through
the Site, you may be directed to a webpage that is hosted by the Payment Service (or the Payment Service’s service providers) and not by Whiterock. Any
Personal Data that you provide through a Payment Service page will be collected by Payment Service and not by Whiterock, and will be subject to Payment
information collected through the Payment Service page.
- • Whiterock collects information through various other means, including participation at conferences and events, individual introductions, from employers
that enroll their employees in our services, and from selected third-party business partners. From time to time, we may also acquire from third parties
certain lists containing the names and contact information of individuals who may be interested in our products and services.
Use of Personal Data Collected
We use Personal Data for legitimate business purposes, including the following:
- • Fulfillment of Requests. Whiterock may use Personal Data about you to deliver products and services to you, and provide you with information about
products and services you’ve ordered. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal
- • Other Communications. From time to time, we may use Personal Data about you to inform you of products, programs, services and promotions that we believe
may be of interest to you. If your employer is a Whiterock customer, we may also inform you of such products, programs, services and promotions using
Personal Data about you that your employer provided to Whiterock.
- • Promotions. We may operate sweepstakes, contests and similar promotions (collectively, “Promotions”). If you choose to enter Whiterock’s Promotions,
we typically ask you for certain Personal Data when you enter and, if applicable, win a Promotion. You should carefully review the rules of each
Promotion in which you participate, as they may contain additional important information about our use of Personal Data about you. To the extent that
such rules shall control. We use this information to operate the Promotions.
- • Other Business Purposes. We may also use Personal Data about you for other business purposes, such as data analysis (for example, to improve the
efficiency of our services), editorial and feedback purposes, providing customer support, customizing and improving the content and layout of the Site,
completing business transactions (for example, to confirm content requested is received by customers), development of marketing and promotion plans and
materials, statistical analysis of user behavior (for example, to understand what parts of the Site are of most interest to users), product development,
market research, administering individual accounts, and meeting government regulatory requirements such as sales tax collection, audits, etc.
- • Administrative Communications. Whiterock reserves the right to use Personal Data to send to you important information regarding the Site, products,
of the Site, products and/or services. Because this information may be important to your use of the Site, products and/or services, you may not opt-out
of receiving such communications. We will engage in this activity to manage our contractual relationship with you and/or to comply with a legal
Collection and Use of Other Data
- • Monitoring Data. Whiterock and its service providers may collect and/or track other information such as demographic information, domain names,
computer type, browser types, screen resolution, and other statistical data involving the use of the Site (“Monitoring Data”). We use Monitoring Data
to help us understand who uses the Site and to improve and market it, as well as our other web sites and services. Unless combined with Personal Data,
Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
- • Aggregated Data. We may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site,
for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information may also
be used for any purpose.
- • Cookies. To enhance the Internet experience on the Site, Whiterock and our service providers may use ‘cookies’ on the Site. Cookies are data that a web
allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a
particular web site, to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about disabling
- • Tools. We and our service providers may also use various common Internet tools such as 'pixel tags', 'action tags', 'web beacons', '.gif tags',
track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and
response rates. Tools allow us to count users who have visited certain pages of the Site, to deliver services, and to help determine the effectiveness of
promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened.
revisit the Site, Whiterock may recognize you by a Tool and customize your experience. For example, once you have completed the registration process, a
cookie and/or Tool will be used to avoid having you register again. We believe cookies and Tools add value to the user experience.
We do not respond to browser do-not-track signals at this time:
report on activities and trends. The service may also collect information regarding the use of other websites, apps and online resources. You can learn
about Google’s practices by going to https://policies.google.com/privacy/partners, and opt out
of them by downloading the Google Analytics opt-out browser add-on, available at
- • Verification. We may use third-party services to verify that you are a human user. Any information collected as part of such verification is subject
- • IP Addresses. When you visit and interact with the Site, we and our third-party service providers may collect Internet Protocol (IP) addresses. Your
IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified
and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited.
We use IP addresses to understand how the Site is used by our users, to improve the Site and to enhance user experience of the Site. We may also derive
your approximate location from your IP address.
We give you choices regarding our use and disclosure of your Personal Data for marketing purposes:
- • If you no longer want to receive marketing-related emails from us on a going-forward basis, you may stop receiving these marketing-related emails by
sending an e-mail to firstname.lastname@example.org
We will try to comply with your request(s) as soon as reasonably practicable.
Use of this Site by Minors
This Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through this Site.
Sensitive Personal Data
We ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through this Site or otherwise to us.
Contact Information for Whiterock
Questions or concerns regarding Whiterock’s data protection practices should be addressed to:
375 Hudson Street
New York, NY 10014