SnapInstruct Privacy Policy

Last revised June 13, 2024

SnapInstruct Inc., together with its affiliates and subsidiaries (collectively, “SnapInstruct,” “we,” “our,” or “us”) understands privacy is important to you, and we are committed to protecting the privacy of our users. This Privacy Policy explains what information we collect about you and use at SnapInstruct, and the choices you have associated with that information. This Privacy Policy applies to the information we collect about you in the course of our business, including through SnapInstruct websites or other Applications (including messaging apps and the SnapInstruct Teams App), and pursuant to any agreements between you or your employer or other entity or person in connection with using SnapInstruct’s Services, and other online or offline offerings or events (collectively, “Services”).

Please carefully review this Privacy Policy to understand how we handle your information. SnapInstruct may maintain a separate agreement with organizations (e.g., your employer or another entity or third party) (collectively, “Customer” or “Customer Admin”), which also may cover processing of information related to the Services (the “Terms of Service”). Your use of SnapInstruct’s Services, including submission of information to us through our website or in accordance with the Terms of Service, constitutes agreement to this Privacy Policy.  The Customer controls any information associated with its use of the Services or the information it receives from you in connection with your use of the Services related to your relationship with Customer.

Information We Collect

SnapInstruct collects information about three types of individuals: 1) Customers; 2) individuals or end users granted access to SnapInstruct’s Services through a Terms of Service (collectively, “Learners”); and 3) individuals who visit our website (“Users”).

The information we collect about you depends on your relationship with SnapInstruct and the Services you use, how you use them, and the information you provide us through use of our Services. The information we collect may include:

* Contact Information, such as name, email address, phone number, and username (“Contact Information”);
* Demographic Information, such as country and state (in U.S.);
* Employment Information, such as employer, job title, role and relationship with others within the organization, employment start date, and employer’s address;
* Training Tracking and Response Information, including time spent on each training module, date of training module start and completion, training completion progress, responses to check-on-learning exercises, responses to culture pulse surveys, and feedback on experience or content;
* Recruitment Information, such as curriculum vitae/resumes, work history, or qualifications for potential or actual applicants for a position at SnapInstruct;
* Online Identifiers, such as IP Address, user agent, or device ID; and
* Any other information that you provide to us that can be used to identify you.

We may also collect information about your use of our websites, such as your browser information, pages clicked, and time spent navigating our websites. If you are a Learner who has participated in a training, this information can be used to identify you, but if you are a User who has never participated in a training, this information will be de-identified and cannot be used to identify you. De-identified information is not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation. However, if this information were to be linked with information above or otherwise become identifiable, we will treat such linked information in accordance with this Privacy Policy.

Cookies and Similar Technologies

We may collect information through cookies and other similar technologies, including when you visit our website and use our online Services.

How We Collect and Use Your Information

We collect information about you through:

* Direct interactions with you, such as when you create an account (if you are a Customer), participate in a training, request information or customer support, join our email marketing list, or otherwise contact us;
* Cookies and automated technologies, such as when you interact with our websites or click on links in our emails;
* Other sources, such as through the Customer (if you are a Learner or User) and analytics providers.

We use your information for the following purposes:
Create and manage Customer and Learner accounts: Customers may be asked to create an administrative account to access our Services and coordinate trainings for the Customer’s workforce. To create a Customer account, Customers will be asked to provide their name, email address and employment-related information (“Employment Information”), and the Customer may be asked to choose a password. SnapInstruct will not receive the password. In accordance with our Terms of Service, SnapInstruct will also create an account for each individual Learner to use when accessing our Services. SnapInstruct will collect from the Customer the Contact Information, Employment Information, and any other information the Customer deems relevant about each Learner to set up and service the Learner account.

We will use the received information for all purposes related to creating and managing each account, including, without limitation, providing administrative, maintenance, and support services; respond to inquiries, requests, or complaints; and servicing both Customer and Learner accounts.

* Enable your use of our Services: We will use your Contact Information, Employment Information, and Training Tracking and Response Information to provide you with our Services at your request or in accordance with our Terms of Services.
* Assist with purchases of our Services: Customers may purchase our Services through use of our online portal. To purchase our Services, we will collect the Customer’s representative’s Contact Information and Employment Information so that we may provide you with confirmation regarding the Customer’s purchase, including the purchase amount. A third-party provider will collect your billing address and payment information, including your payment card number, security/CCV code, and expiration date. The third-party provider will use this information to process your payment.
* Use of electronic mailing lists: We will use your Contact Information to send you communications about SnapInstruct, this Privacy Policy, our Services, and other important administrative announcements. We may also send you news, updates, announcements, newsletters, and other marketing communications via email. Some of these communications will be pursuant to our legitimate interest to keep you informed, while other communications may be pursuant to your consent (if we are required by law to obtain your consent).
* Process surveys, reviews, and feedback forms: We may use online surveys, reviews, and feedback forms to gather opinions, comments, and suggestions about SnapInstruct and our Services. Should you choose to disclose information to us, we will collect and user such information to understand your comments, communicate with you regarding your feedback, and make changes to our Services accordingly.
* Respond to inquiries: You may submit inquiries or complaints to SnapInstruct regarding our Services. We will use your name, email address, and any other information you shared with us to communicate with and respond to you.
* Maintain the security of the websites: We may use your information to detect security incidents, protect the websites against fraudulent and illegal activity, and enforce our Terms of Use.
* Our legal purposes: We may use your information to comply with our legal obligations or to establish, exercise, or defend legal claims.
* Other purposes for which we seek your consent: We may use your information for a specific purpose that we communicate to you. We will ask for your consent to process your information for such purpose in accordance with applicable legal requirements.
The laws in some jurisdictions require companies to tell you the legal grounds they rely on to process your information. Our processing of your information, as described in this Privacy Policy, is based on:
* Our legitimate interests in promoting and protecting SnapInstruct, building and maintaining relationships, and providing our Services;
* Your consent, such as when you create an account or register for our newsletters or alerts; and
* Our obligation to comply with applicable law, when certain information is necessary to satisfy our legal or regulatory requirements.

How We Share Data

We share your information with the following categories of recipients as an essential part of being able to provide our Services to you:
* Our Affiliates and Partners. Subject to our Terms of Services, we may share information within the SnapInstruct family of companies and with our Partners to deliver and enhance our Services, operate and grow our business, and improve your user experience. 
* Service Providers. Unless prohibited by contract or applicable law, we may share information with our third-party service providers that help us operate our business and provide our Services, including payment service providers, website and application hosting providers, cloud providers, analytics providers, security providers, researchers, and marketing companies.
* Our Customers. Subject to our Terms of Services, we may share certain Training Tracking and Response Information about our Learners and other Learner-generated data with our Customers. This information sharing would be limited so that our Customers received information about its Learner employees only and not the Learner employees of our other Customers. We may anonymize and/or aggregate Demographic Information and other Training Tracking and Response Information and share the anonymized, aggregated information with our Customers.
* Transactions or Business Transfers. If SnapInstruct is merged, acquired, or sold, or in the event of a transfer, restructuring of some or all of our assets, or bankruptcy, we may disclose or transfer information in connection with such transaction. You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Policy.
* Government or Law Enforcement Agencies. We may share your information (i) if we determine that disclosure is necessary to comply with any law or legal process applicable to us or a request from law enforcement or other regulatory agency; (ii) to protect the rights, privacy, property, interests, or safety of SnapInstruct, our Customers, Learners, or our users, sponsors, employees, or the general public; (iii) to enforce this Privacy Policy and Terms of Use; (iv) to respond to an emergency; and (v) as otherwise permitted by applicable law.
We share your information with third parties only as described in this Privacy Policy, with your consent, or as disclosed at the time we collect your information.

Your Choices

We offer you choices and opportunities with respect to certain uses of your information.
* Adjust your marketing and communications preferences: You may at any time opt out of receiving marketing electronic mailings from SnapInstruct by using the “opt out” or “unsubscribe” means provided in the electronic mailings you receive. You may also email us at the contact information provided below. Please note that even if we stop all marketing communications, you may still receive other important communications from us.
* Limit the information you provide to us: When you interact with us, you can choose to limit the information you provide. However, if you choose to do so, you may not be able to fully use many of our Services.
* Update your Customer account: Customers may update account sign in details and profile information for the Customer admin account. Customers may also be able to update the profile information for each Learner account affiliated with the Customer.  Customers may make these changes by logging into its Customer admin account and adjusting its account settings.
* Opt out of cookies: Follow the instructions in our Cookies Policy to opt out of our use of certain cookies.
We acknowledge the importance of user privacy and make efforts to respect Do Not Track (DNT) signals set by web browsers. While we aim to comply with DNT settings, we cannot guarantee adherence due to technical limitations or conflicting requirements of our Services. We strive to improve our ability to support DNT preferences in line with our commitment to user privacy.

Notice to Individuals in the UK or EEA

If you are located in the United Kingdom or the European Economic Area, you may request to exercise the following rights with respect to your information:
* Access to, or a copy of, your information
* Correction or amendment of your information
* Deletion of your information
* Transfer of your information to a third party
* Restriction or objection to certain uses of your information

If you have provided consent for us to use your information for a specific purpose, you may request to withdraw that consent.

If you wish to exercise any of your rights, please contact us using the means listed at the end of this Privacy Policy. We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will consider all requests and provide our response within the time period required by applicable law.  Please note, however, that certain information may be exempt under such requests. If we are unable to honor your request, we will let you know why.

SnapInstruct acts as a Processor to Customers and Learners with respect to your use of our Services. There are limited situations where SnapInstruct may act as a Controller, including when processing Recruitment Information.
In addition to the practices described in this Privacy Policy, users in the United Kingdom, the European Union, or other regions governed by the General Data Protection Regulation (GDPR) also agree to be subject to the terms outlined in Appendix A: Data Privacy Addendum. This Addendum provides detailed information about data processing obligations and practices as required by GDPR.

California “Shine the Light” Disclosures

California residents may request information from us once per calendar year about any information shared with third parties for the third party’s own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information, please contact us using the information provided in the “Contact Us” section of this Privacy Policy. Your inquiry must specify “Shine the Light Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state and ZIP code.

Nevada Privacy Law

If you are a resident of Nevada, you have the right to opt-out of the sale of certain information to third parties who intend to license or sell that information. You can exercise this right by contacting us at with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your information as sales are defined in Nevada Revised Statutes Chapter 603A.
Data Transfers to the United States

SnapInstruct’s operations are located primarily in the United States. If you are outside of the United States and submit your information to us or otherwise use our Services, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States, where U.S. law may not offer the same privacy protections as the law of your jurisdiction; and (ii) by visiting our website or using our Services, you explicitly authorize its transfer to and subsequent processing in the United States in accordance with this Privacy Policy.

Children’s Privacy

SnapInstruct’s Services are not directed at children under the age of 16. SnapInstruct does not knowingly collect information from anyone under the age of 16. If we become aware that we have collected information from a child under 16, we will handle such information in accordance with applicable laws.

Security and Retention of Your Information

We are deeply committed to protecting your information and employ robust technical, physical, and organizational security measures. We strive to maintain the highest level of security. However, as with any online platform, absolute security cannot be unequivocally guaranteed. When using your SnapInstruct account, it is important that you select a strong password and do not share it with others. Alert us immediately if you have any concerns about unauthorized access to or use of your account.

We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Policy. We will delete or de-identify information when it is no longer needed to fulfill these purposes, unless a longer retention period is required to comply with applicable laws.

Third Party Websites

Our website may contain links to certain third-party websites not owned or operated by us. When you click on a link to a third-party website, you leave our Site and no longer will be subject to our Privacy Policy. SnapInstruct does not control and is not responsible for the privacy policies or practices or the content of any third-party websites, and such links are not intended to be an endorsement. We encourage you to review the privacy policies of any third-party website prior to providing them with your personal information. Governing Law

This Privacy Policy and it’s Appendix A shall be governed by and construed in accordance with the laws of New York, without regard to its conflict of laws principles. The parties agree to submit to the jurisdiction of the courts located within New York for the resolution of any disputes arising from this Addendum.

Updates and Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our data privacy practices. If we make any material changes, we will provide notice on, and we may notify you by email (sent to the email address specified in your Service Agreement or used to create an account), prior to the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. Any amended Privacy Policy supersedes all previous versions. If you continue to use the Services after those changes are in effect, you agree to the revised policy.

Contact Us

If you have any other questions about our Privacy Policy or wish to exercise any rights you may have with respect to your personal information, please email us at or contact us via postal mail at 217 East 70th Street #128, New York, NY, 10021.

Appendix A: Data Privacy Addendum

This Data Privacy Addendum (“Addendum”) amends the existing Agreement between SnapInstruct and you or your Company (“Company”).  It details the responsibilities and protocols for the protection of Personal Data under GDPR requirements.

The parties agree:

1. Definitions.

For purposes of this Addendum:

1. “Data Protection Law” means all applicable laws, regulations, and other legal or self-regulatory requirements in any jurisdiction relating to privacy, data protection, data security, communications secrecy, breach notification, or the Processing of Personal Data, including without limitation, to the extent applicable, Regulation (EU) 2016/679 (General Data Protection Regulation) (“GDPR”), the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”), and all implementing regulations.  For the avoidance of doubt, if SnapInstruct’s processing activities involving Personal Data are not within the scope of a given Data Protection Law, such law is not applicable for purposes of this Addendum.
2. “Data Subject” means an identified or identifiable natural person about whom Personal Data relates.
3. “Personal Data” means any data and information relating to a Data Subject or is otherwise subject to Data Protection Laws that Company uploads or otherwise inputs into the Service and which is Processed by SnapInstruct or a Sub-Processor in the course of providing Services under the Agreement. “Personal Data” includes “personal data,” “personal information,” and “personally identifiable information,” and such terms shall have the same meaning as defined by the applicable Data Protection Laws.
4. “Process” and “Processing” mean any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, creating, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
5. “Security Incident” means any event that compromises the security, integrity, or confidentiality of Personal Data, including unauthorized or accidental access to, use, disclosure, alteration, loss, or destruction of Personal Data.
6. “Standard Contractual Clauses” means the UK Standard Contractual Clauses, and/or the 2021 Standard Contractual Clauses.
7. “UK Standard Contractual Clauses” means the Standard Contractual Clauses for data controller to data processor transfers approved by the European Commission in decision 2010/87/EU.
8. “2021 Standard Contractual Clauses" means the Standard Contractual Clauses approved by the European Commission in decision 2021/914.

2. Scope and Purposes of Processing.

1. SnapInstruct will Process Personal Data solely: (1) to fulfill its obligations to Company under the Agreement, including this Addendum; (2) on Company’s behalf; and (3) in compliance with Data Protection Laws.  SnapInstruct may use Personal Data to provide and improve its Services. SnapInstruct can use aggregated, anonymized, or de-identified data for internal purposes.

3. Personal Data Processing Requirements.

SnapInstruct will:

1. Upon written request of Company, assist Company in the fulfilment of Company’s obligations to respond to verifiable requests by Data Subjects (or their representatives) for exercising their rights under Data Protection Laws (such as rights to access or delete Personal Data).
2. Inform Company within a commercially reasonable timeframe of any Data Subject request directly received by SnapInstruct exercising their rights in connection to their Personal Data if (i) the request or complaint is received through the contact information specified in the SnapInstruct’s privacy policy and (ii) the request or complaint identifies Company as the SnapInstruct customer to whom it pertains. SnapInstruct will await written instructions from Company on how, if at all, to assist in responding to the request. Additional support relating to Data Subject requests and complaints may be available and would require mutual agreement on fees, the scope of SnapInstruct’s involvement, and any other terms that the Parties deem appropriate.
3. Provide reasonable assistance to and cooperation with Company for Company’s performance of a data protection impact assessment of Processing or proposed Processing of Personal Data, taking into account the nature of Processing and the information available to SnapInstruct. Additional support for data protection impact assessments or relations with regulators may be available and would require mutual agreement on fees, the scope of SnapInstruct’s involvement, and any other terms that the Parties deem appropriate.
4. Provide reasonable assistance to and cooperation with Company for Company’s consultation with regulatory authorities in relation to the Processing or proposed Processing of Personal Data, including complying with any obligation applicable to SnapInstruct under Data Protection Laws to consult with a regulatory authority in relation to SnapInstruct’s Processing or proposed Processing of Personal Data.

4. Data Security

SnapInstruct will

1. Implement appropriate administrative, technical, physical, and organizational measures to protect Personal Data.
2. Provide reasonable assistance to Company to enable Company to fulfill its compliance obligations, taking into account the nature of Procession and the information available to SnapInstruct. Additional assistance beyond what is reasonable will require agreement between the parties on fees and terms of assistance and may be refused by SnapInstruct. 

5. Security Incident.

1. SnapInstruct will notify Company without undue delay, and in any event within seventy-two (72) hours, of any confirmed Security Incident. SnapInstruct’s notice to Company shall summarize, to the extent available, which may be based on incomplete information: (i) the cause of the Security Incident, (ii) the impact of the Security Incident on Company, (iii) the categories and approximate number of Data Subjects potentially impacted, (iv) the affected Personal Data data elements, (v) the corrective actions to be taken by SnapInstruct, and (vi) any other information required by Data Protection Laws. To the extent it is not possible to provide the foregoing information at the same time, the information may be provided in phases without further undue delay.
2. At SnapInstruct’s own expense, SnapInstruct will take steps to mitigate the effects of the Security Incident and reduce the risk to Data Subjects whose Personal Data was involved.
3. Company is solely responsible for complying with Security Incident notification requirements applicable to Company and fulfilling any third-party notification obligations.

6. Sub-processors.

1. Company acknowledges and agrees that SnapInstruct may use SnapInstruct affiliates and other Sub-processors to Process Personal Data in accordance with the provisions within this Addendum and Data Protection Laws.
2. Where SnapInstruct sub-contracts any of its rights or obligations concerning Personal Data, including to any affiliate, SnapInstruct will (i) take steps to select and retain Sub-processors that are capable of maintaining appropriate privacy and security measures to protect Personal Data consistent with Data Protection Laws; and (ii) enter into a written agreement with each subcontractor that imposes obligations on the subcontractor that are substantially similar those imposed on SnapInstruct under this Addendum.

7. International Transfers of Personal Data.

If Personal Data originates from the European Economic Area, United Kingdom, or Switzerland and is transferred by Company to SnapInstruct for Processing in a country not subject to an adequacy decision in accordance with Data Protection Laws (“Data Transfer”), the Parties will conduct such Data Transfer in accordance with this section of this Addendum.       

1. UK Standard Contractual Clauses. For transfers of Company Personal Data out of the United Kingdom, the UK Standard Contractual Clauses will apply and are incorporated into this Addendum by reference, provided that the illustrative indemnification clause within Appendix 2 of the UK Standard Contractual Clauses will not apply. Attachment A of this Addendum will serve as Appendix 1 of the UK Standard Contractual Clauses.
2. 2021 Standard Contractual Clauses. For transfers of Company Personal Data out of the EEA or Switzerland, the 2021 Standard Contractual Clauses will apply and are incorporated into this Addendum. For purposes of this Addendum, the 2021 Standard Contractual Clauses will apply as set forth in this Section 7.2. “Module Two: Transfer controller to processor” will apply and all other module options will not apply. Under Annex 1 of the 2021 Standard Contractual Clauses, the “data exporter” is Company and the “data importer” is SnapInstruct and the information required by Annex 1 can be found in Attachment A. For the purposes of Annex 2 of the Standard Contractual Clauses, the technical and organizational measures implemented by the data importer are those listed in Section 4 of this Addendum. Clause 7 will not apply. For clause 9, the Parties choose Option 2, and the Parties agree that the time period for prior notice of Third Party changes will be as set forth in 3.c of this Addendum. For clause 11, the optional language will not apply. For clause 17, the Parties choose Option 1 and the Parties agree that the governing law will be the Republic of Ireland. For clause 18, the Parties agree that the courts of the Republic of Ireland will apply for subsection (b).
3. Incorporation and Conflict. Each party’s agreement to this Addendum shall be considered a signature to the Standard Contractual Clauses. If required by the laws or regulatory procedures of any jurisdiction, the Parties shall execute or re-execute the Standard Contractual Clauses as separate documents. In case of conflict between the Standard Contractual Clauses and this Addendum, the Standard Contractual Clauses will prevail.

8. Limitations of Liability.

1. SnapInstruct's liability under this Addendum is limited to direct damages only. SnapInstruct is not liable for indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, data, or goodwill. SnapInstruct will have no liability for Security Incidents if: (i) It complies with its security obligations under this Addendum; (ii) The incident is attributable to Company’s instructions, acts, or omissions; (iii) The incident results from Company’s breach of this Addendum or the Agreement; (iv) Company fails to use the Services as per the documentation or fails to use offered security options; (v) The incident is due to factors outside SnapInstruct’s reasonable control, including force majeure events.
2. The total aggregate liability of SnapInstruct, including for its Sub-processors, shall not exceed the fees paid by Company to SnapInstruct under the Agreement in the twelve months preceding the claim. This limitation does not apply to liability otherwise prohibited by law.

9. Conflict.

In the event of any conflict or inconsistency between the Agreement and this Addendum, this Addendum shall prevail.


Attachment A to Data Privacy Addendum

1.1  Subject Matter of Processing: The subject matter of Processing is the Services pursuant to the Agreement.

1.2  Duration of Processing: The Processing will continue until the expiration or termination of the Agreement.

1.3  Categories of Data Subjects: Includes the following:
● Employees and other authorized users of the Services

1.4  Nature and Purpose of Processing: Includes the following:
Nature: Processing of the data uploaded by Company to SnapInstruct’s training and compliance SaaS application.
The purpose of Processing of Company Personal Data by SnapInstruct is the performance of the Services pursuant to the Agreement.

1.5  Types of Personal Information: Includes the following:
● First and last name
● Email
● Managerial status
    ● Employment location
● Information, data and responses submitted by the users of the Services
● Electronic identification data (notably IP addresses and user agent data)

Attachment B: Cookie Policy Addendum

This Cookie Policy Addendum to the SnapInstruct Privacy Policy describes the cookies that SnapInstruct Inc. (collectively, “SnapInstruct”, “we,” “our,” or “us”), and trusted third parties, use when you visit SnapInstruct’s websites. In the spirit of transparency, this Cookie Policy provides detailed information about the types of cookies we use, why we use them, and your choices with respect to our use of cookies.

This Cookie Policy Addendum is incorporated into and forms part of the SnapInstruct Privacy Policy. By agreeing to the Privacy Policy, you also agree to the terms of this Cookie Policy Addendum. SnapInstruct will treat any identifying information collected through our use of cookies in accordance with our Privacy Policy. Please refer to our Privacy Policy for more information and to learn more about our privacy practices.

What is a cookie?

Cookies are small data files that are sent to or accessed from your web browser or your computer’s hard drive by the websites you visit. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires), and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history, and internet activities. If you make multiple visits to our site, cookies allow our website to recognize your browser.

Generally, cookies may be categorized as:

• First-party cookies. These are sent to a user’s device from a platform or domain managed by the entity who operates the website a user visits.

• Third-party cookies. These are sent to a user’s device from a platform or domain operated by an entity who does not operate the website a user visits.

How do we use cookies?

We use cookies for a number of reasons, such as helping us keep our services and site secure, measuring the performance of our site, and counting the numbers of visitors. The cookies we use generally fall into one or more of the following categories:

• Strictly necessary cookies. These cookies are strictly necessary to provide you with services available through our website and cannot be turned off. These cookies allow you to use some of the website’s features, such as granting access to areas that require registration and setting your privacy preference.

• Functionality cookies. These cookies allow you to browse our website or benefit from some of its enhanced features, such as memorizing language preferences. Similar to strictly necessary cookies, if these cookies are disabled, it may impact your experience to use our website and make your experience less personalized.

• Performance cookies. These cookies are used to collect information to count visits and traffic sources so we can measure and improve the performance of our website. All information collected by performance cookies is aggregated and therefore anonymous.

• Social media cookies. These cookies are used when information is shared through a social media sharing button or “like button” on our websites or when you link your account or engage with our content on or through a social networking site such as Facebook, Twitter, or LinkedIn.

How long are cookies stored on your device?

The duration of storage of cookies on your device may vary, depending on whether the cookies are temporary or permanent.

• Temporary cookies. We use temporary cookies on all our secure pages to assign and register a session ID. A temporary cookie does not identify you by name, and it does not leave any information recoverable on your hard drive. Temporary cookies expire when you close your internet browser.

• Permanent cookies. Certain cookies are considered “permanent cookies” and stay on your computer for 24 hours, a week, or several years depending on the cookies’ function. This means that these cookies survive after your browser is closed and can be used by our website to recognize your device when you reopen your browser later.

Your Choices

At any time, you may control our use of cookies while you use our services, and you may disable cookies by changing the settings on your browser, phone and/or devices. Most browsers are set to accept cookies by default, but you can control and manage settings to remove or reject browser cookies manually within your brower’s configuration settings. To manage these settings, please follow the instructions given by your browser.

You can limit how cookies interact with your device or browser by enabling ad tracking functionality on both android and iOS devices. If you use a device to access our website, your device identification may be collected and used for purposes similar to other cookies. Please be aware, if you disable certain cookies, some of the features of our services may not function properly or be available to you, such as those which require identification.

Governing Law

This Cookie Policy shall be governed by and construed in accordance with the laws of New York, without regard to its conflict of laws principles. The parties agree to submit to the jurisdiction of the courts located within New York for the resolution of any disputes arising from this Addendum.

Updates to this Policy

We may update or change the cookies (or similar technologies) we use from time to time. The most up-to-date version of this Policy will be posted on our website at Please revisit this Policy to stay informed about our use of cookies.

Contact Us

If you have questions about our use of cookies or this Policy, please email us at