Dated: April 30, 2018
User Consent: By submitting or making available information to Whitepages, including personal information, through our Services or related services, users expressly consent to the collection, use, disclosure, and retention of that information as described herein.
2. INFORMATION COLLECTED
Whitepages collects information in the form of queries submitted to the Services by Customers (“Query Information”). Whitepages also collects usernames, passwords, and information when Customers correspond with us by phone/email or request support for the Services (“Account Information”). If Customers do not provide certain Account Information, such as usernames and passwords, they may not be able to use the Services or take advantages of certain features of the Services. When purchasing the Services, Whitepages may also require Customers to provide billing information, such as billing name and address, ACH or credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”). The Query Information, Account Information and Billing Information we collect may include “personally identifiable information,” which is information about an identified or identifiable individual (“Personally Identifiable Information”), such as first and last name, telephone number, email address, physical address, and IP address of Customers’ employees and customers.
As a Customer uses the Pro Web Site, Whitepages also collects information through using commonly-used information-gathering tools and services, such as cookies, Web beacons, and embedded scripts (“Usage Information”). Usage Information includes, but is not limited to, standard information from a Web browser (such as browser type and browser language), an Internet Protocol (“IP”) address, device identifier numbers, and the actions a Customer takes on the Pro Web Site (such how a Customer interacts with the Web pages and the links clicked).
Query Information, Account Information, Billing Information and Usage Information are sometimes collectively referred to as “Data.”
3. USE OF INFORMATION COLLECTED
Whitepages uses a Customer’s Query Information to provide the Services, and may store that information in logs hosted by Whitepages and other third parties. Whitepages uses Query Information for billing purposes and to provide customer support. Whitepages also analyzes Query Information to aid in identity verification, to improve the fraud detection features of the Service, and to corroborate data to improve the Service. Whitepages keeps Query Information for up to three years.
Whitepages uses Account Information about Customers and potential Customers to perform the services requested by such Customers. For example, Whitepages may contact Customers to confirm a purchase, respond to a request, or notify Customers of changes to their account or to the Services. Whitepages may also use Account Information from Customers and potential Customers for marketing purposes. For example, Whitepages may use Account Information to contact Customers to gauge interest in new features of the Services or to provide details about promotions and events. Whitepages keeps Account Information indefinitely.
Whitepages uses Billing Information solely to collect payment from Customers. Whitepages keeps Billing Information indefinitely.
Whitepages collects and uses Usage Information for a variety of Web site administration and customization purposes. For example, Whitepages may use Usage Information to measure a Service’s traffic, to measure user interests and traffic patterns, and to improve the Services. Whitepages keeps Usage Information indefinitely.
Whitepages’s analysis of Query Information may produce derived information (“Metadata”) that does not identify a Customer, such as the number of times an address has been submitted in a Query of the Services (also known as “velocity”), or the date an email address was first seen by the Service. Whitepages does not treat Metadata as Data hereunder, except if applicable law requires us to do otherwise. Whitepages keeps Metadata indefinitely, and may use it for any legitimate business purpose.
4. USAGE INFORMATION
Whitepages may also use web beacons, small graphic images, or other web programming code which may be included in our Web pages and e-mail messages. Whitepages may use Web beacons (or similar technologies) to count visitors to the Pro Web Site, and to monitor how users navigate the Pro Web Site, among other legitimate business purposes.
Log files, IP addresses, URLs, embedded scripts, and similar data
Whitepages gathers certain information automatically to administer the Services and analyze trends in the aggregate. This information may include IP addresses (or the proxy server a Customer uses to access the Services), device and application identifiers, browser type, Internet service provider, the pages and files viewed, searches conducted, operating system and system configuration information, and date/time stamps associated with usage. Also, Whitepages automatically receives the URL of the Web site from which a Customer came (if a Customer follows a link to the Pro Web Site). This information is used to analyze overall trends, and to provide and improve the Services. For example, Whitepages collects IP addresses from Customers when they log into the Services as part of security features to confirm identity or detect compromised accounts. Whitepages may also use embedded scripts, which are programming code designed to collect information about an interaction with a Web site, such as the links clicked on. The code is temporarily downloaded onto a device from our Web server or a third-party service provider, is active only while you are connected to the Web site containing the embedded script, and is deactivated or deleted thereafter.
Do Not Track
Browser settings may allow users to automatically transmit a “Do Not Track” signal to Web sites and online services, but there is no consensus on how “Do Not Track” should be interpreted. Whitepages currently does not alter its practices when it receives a “Do Not Track” signal from a Customer’s browser.
5. SHARING OF INFORMATION COLLECTED
Whitepages may provide Data to third party service providers to deliver the Services to you as well as for purposes related to the Services’ administration and operation, including conducting analytics. When sharing information to provide services requested by Customers, we will share Personally Identifiable Information only as necessary for the third party working on Whitepages’s behalf to complete its work, and in compliance with contractual confidentiality and security measures. For example, Whitepages may transmit Query Information to a cloud service provider that hosts Whitepages query logs or may provide Billing Information to a credit card processing company to complete a Customer’s transaction.
Third-Party Business Partners
Whitepages occasionally partners with a variety of businesses to market or sell products or services (“Partners”). We may disclose Account Information (including email addresses, but not including other user names and passwords) to our Partners for these purposes. Some of our Partners may co-sponsor events and other offerings with Whitepages. Whitepages may share Account Information that Customers provide when they sign up for events or other offerings with these Partners so they can send marketing communications and other information of interest.
Whitepages reserves the right to use or disclose any information provided to us if required by law; if we reasonably believe that use or disclosure is necessary to protect Whitepages’s rights or property; to comply with a judicial proceeding, court order, or legal process; to protect against misuse or unauthorized use of the Services; or to respond to emergencies, such as when Whitepages believes someone’s physical safety is at risk.
Acquirers of Business
In the event that Whitepages is involved in a sale of some or all of our assets, or we are acquired by another company, the Data and any Personally Identifiable Information we collect may be among the assets reviewed and transferred.
6. LOCATION OF COLLECTED INFORMATION STORED BY WHITEPAGES; DISPOSAL
Data submitted to Whitepages and the Services are hosted and stored in a secure environment provided by Amazon Web Services (“AWS”). The AWS physical architecture that hosts Whitepages is in the United States. By submitting or making available Data, Customers agree to its transfer, storage, or processing in the United States.
On or before the time that Data has reached the retention limits described in Section 4, Whitepages takes all commercially reasonable efforts to securely dispose of the Data in accordance with its information security policies and procedures. Please note that in all cases, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
7. INTERNATIONAL TRANSFERS OF COLLECTED INFORMATION
8. EUROPEAN PRIVACY RIGHTS
Whitepages permits European Union, European Economic Area, and Switzerland (together, the “EU”) data subjects: (a) to confirm whether Whitepages processes their personal data, and to obtain copies thereof; and (b) the option of opting-out of (i) the disclosure of their personal information to third parties or categories of third parties, or (ii) the use of their personal information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Individuals residing in the EU wishing to make an opt-out request, or Customers who have received a request from an EU data subject and previously have provided Whitepages with the data subject’s personal information, should contact Whitepages directly using the information at Section 12, below, so Whitepages may consider and respond to the request.
Whitepages implements reasonable security measures to secure Data. However, no physical or electronic security system is impenetrable. Whitepages cannot guarantee the security of the Services’ servers or databases, nor can we guarantee that information that Customers supply will not be intercepted while being transmitted over the Internet. Customers should take steps to protect against unauthorized access to passwords and API keys.
10. CHILDRENS’ DATA POLICY
The Services are not intended for use by children under the age of eighteen years old. Whitepages does not knowingly collect information from children under the age of eighteen.
12. CONTACT FOR OPTING OUT, DATA ACCESS, AND DISPUTES