Effective Date: June 5, 2019
- The information that Bartleby, its affiliates, Service Providers, and Third-Party Services collect about you.
- How that information may be used.
- With whom your information may be shared.
- How Bartleby protects your information.
- Certain jurisdiction-specific rights (as applicable).
A. Information Collected by Us
1. Information That You Provide
Bartleby and its affiliates (“Bartleby,” "we" or "us") provide its family of Internet sites, services and applications to you (our "Services"). Registration with us is optional, but please keep in mind that you may not be able to use many features of our Services unless you register with us. Depending on how you interact with our Services, you may provide us, our Service Providers, and Third-Party Services with information, which may include:
- Your name, email address, age (to comply with legal requirements), user name, password, address, postal code, phone number, credit card number, gender, school attending, graduation year, and other registration information;
- Information about your preferences;
- Transaction-related information, such as, your orders for any services, downloads or other features, or purchases, if any, that you make from us;
- Information you otherwise provide us, such as when you contact us (e.g., for help); and
- Other information related to your use of particular offerings on our Services.
2. Information Collected Automatically
We, our Service Providers, or Third-Party Services may automatically receive or collect from you certain information when you use the Services. This information may include:
- Your browser or operating system;
- Your manner of connecting to the Internet (including the type of device you are using) and the name of your Internet service provider or wireless carrier;
- Your Internet protocol (IP) address;
- Data relating to malfunctions or problems that occur when you use the Service;
- Log file information, including your Web request, Internet Protocol ("IP") address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on our service, domain names, landing pages, pages viewed, and other such information; and
- Information collected by cookies and other tracking technologies: cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Services or emails, including information about your browsing and purchasing behavior.
We will treat information that does not personally identify you as non-personal information, and we may de-identify, anonymize or otherwise convert your personal information to non-personal information. As permitted by applicable law, we reserve the right to use, process, share and otherwise exploit your non-personal information without limitation.
B. Use of Information
1. Our Use of Your Information
We may use your information:
- To process your registration, manage your account (including your payment information and preferences), and deliver our Services and features desired by you (including any customization features requested by you);
- To improve our Services;
- To fulfill other purposes disclosed to you at the time you provide us with your information or otherwise where we are legally permitted to do so;
- To personalize content and offers and serve you advertising that may be of interest to you;
- To respond to your inquiries;
- To fulfill your request for products or services;
- To provide you with updates and other information regarding the Services;
- To understand your general location (i.e., not your specific geolocation) based on your IP address;
- To keep our Services safe and secure and to prevent detect fraud and abuse;
- To comply with our legal obligations, policies, and procedures;
- To administer and manage our Services including content and layout, site usage, troubleshooting, data analysis, testing, research, statistical and survey purposes; and
We may share your information:
- With our agents, vendors, consultants, and other service providers (“Service Providers”) in connection with their work on our behalf;
- With our family of companies and affiliates who may have content and offers of interest to you. We do not share your personal information to non-affiliate third parties for marketing purposes unless expressly authorized by you;
- In the event of a change of ownership, as described below;
- To comply with law, law enforcement or other legal process, and, where permitted, in response to governmental requests or legal process (for example, a court order, search warrant or subpoena); and
- To other circumstances in which we have a good faith belief that a crime has been or is being committed by a user.
- We may place "cookies" on your Web browser. Cookies are small pieces of information or text files that a website sends to your computer for record-keeping purposes, which information is stored in a file on your computer's hard drive.
- Cookies make Web-surfing and browsing easier for you by saving your preferences so that we can use the saved information to facilitate and improve your use of the Services.
- You can adjust your Internet browsers to reject cookies; however, please note that you will not be able to access and use all of our features if you delete or refuse to accept cookies.
- See our Cookie Disclosure for more information.
- For further information on cookies and other Tracking Technologies, including your choices with respect to the same, see below.
D. Sweepstakes, Contests, and Promotions
E. Information you Disclose Publicly or to Others
F. Third-Party Content, Third-Party Services, Social Features, Advertising, Analytics
1. Third Party Content, Third-Party Services, Social Features
- The Service may include hyperlinks to, or include on or in connection with, the Services (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own Tracking Technologies to independently collect information about you and may solicit personal information from you.
- Certain functionalities on the Service may permit interactions that you initiate between the Service and certain Third-Party Services, such as third party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Bartleby’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see “Information You Disclose Publicly or to Others” section above) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with Bartleby or its affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Bartleby and its affiliates. Also, both Bartleby and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
- We may engage and work with Service Providers and other third parties to serve advertisements on the Services and/or on third-party services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Service (i.e., “retargeting”). Our advertisers' and ad networks’ use of Tracking Technologies are governed by their own privacy policies.
- Your Tracking Technologies Choices
- Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website . Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
- Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
- Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com , but we are not responsible for the completeness or accuracy of this third-party information. You have the right to request information from us about the Services that currently do not respond to "do not track" mechanisms featured in any Internet browser by contacting us according to the “How to Contact Us” section below.
- Many advertisers and service providers that perform advertising-related services for us and third parties participate in voluntary programs that provide tools to opt-out of such interest-based advertising such as the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising for DAA members, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies also are members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices . You can also go to http://www.adroll.com/about/privacy to adjust your advertising preferences with our provider AdRoll.
- 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, participating 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). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your browser-based opt-out may not, or may no longer, be effective.
- We support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising and expect that ad networks that we directly engage to serve you interest-based advertising will do so as well, though we cannot guaranty their compliance. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
- In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our databases (“Matched List Ads”). This is done by using Tracking Technologies, or by matching common factors between our databases and the databases of the third-party services. We are not responsible for these third-party services, including without limitation their security of the data. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions as they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
We use third party services such as Google Analytics and Sailthru to help us analyze our performance and our delivery of services and advertising to you. For example, we use Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager and Google Analytics Demographics and Interest Reporting.
- We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site.
G. Opting Out of Promotional Communications
You can make choices about how your information may be used by us to provide information and offers to you. You may opt out of commercial messages by clicking on the "opt out" or "unsubscribe" link provided with each message. These preferences do not apply to transactional communications, such as those that are related to your registration with us, required or important notices related to your use of our Services, or the fulfillment of a specific transaction.
Children under the age of sixteen (16) are not eligible to use our service and must not submit any personal information to us.
Any California residents under the age of eighteen (18) who have registered to use the Services, and who posted content or information on the Services, can request removal by contacting us in the manner described under the “How to Contact Us” section below, detailing where the content or information is posted and attesting that you posted it. We will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.
I. Links and Other Sites
- You are subject to the privacy policies of those websites.
J. Change of Ownership
In the event that our ownership was to change as a result of a merger, acquisition, or any transaction involving the transfer of some or all of our assets by another company, your Services information may be transferred. We will provide you notice prior to any such transfer of your personal information.
M. How to Contact Us
email@example.com for Bartleby Writing
firstname.lastname@example.org for other Bartleby sites and services
750 Third Avenue, 6th floor
New York, NY 10017
O. Jurisdiction Specific Terms
Your California Privacy Rights
If you are a California resident, in addition to the rights set forth above, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties, for the third parties' direct marketing purposes. California law provides that you have the right to submit a request to us at the designated address and receive the following information:
- The categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year;
- The names and addresses of third parties that received such information, and
- If the nature of a third party's business cannot be reasonably determined from the third party's name, examples of the products or services marketed.
You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. Our designated email address for such requests is email@example.com. You may also mail us requests at 750 Third Avenue, 6th Floor, New York, NY 10017.
If you are located in the European Economic Area (EEA):
1. Controller of your Personal Data
2. Legal Bases for Using Personal Data
We process your personal data only if we have a legal basis to do so, including:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party;
- where you have given consent to our specific use.
The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is further explained below.
Purposes for which we will process the information
Legal Basis for the processing
To deliver services and features desired by you.
It is necessary for us to process your personal data in order to deliver the services and process transactions according to the applicable contract between us.
To improve our services to you.
It is in the legitimate interests of the company to process your data for the purpose of improving services to you. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
To personalize content and offers and serve you advertising that may be of interest to you.
We will personalize content and offers to you and serve you advertising based on your interests and online activities if you have consented to this processing.
To respond to your inquiries.
It is necessary for us to process your personal data in this manner to respond to your inquiries according to the applicable contract between us.
To fulfill your request for products or services.
It is necessary for us to process your personal data to fulfill your request for products or services according to the applicable contract between us.
To use your login user ID and password to register you on your behalf and to give you access to our affiliate websites and services as part of a "single sign-on" feature;
It is necessary for us to process your personal data to use carry out these activities according to the applicable contract between us.
To provide you with updates and other information regarding the Services.
It is necessary for us to process your personal data to provide you with updates and other information regarding the Services according to the applicable contract between us.
To share your information with the company that employed you, engaged you, or authorized you to access and use the Services.
It is in the legitimate interests of the company that employed you, engaged you, or authorized you to access and use the Services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
To analyze statistically site usage and to customize our site's content, layout and services.
|It is in our legitimate interests to process your personal data to analyze our site usage and to customize our site's content, layout and services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.|
To enable our family of companies and affiliates and with trusted business partners that we do business with who may have content and offers of interest to you.
It is in our legitimate interests to process your personal data to enable our family of companies and affiliates who may have content of interest to you. We process your personal data to enable our family of companies and affiliates and trusted business partners to send you electronic offers and market to you only if you have consented to these activities.
To enable our agents and service providers to perform certain activities on our behalf;
It is necessary for us to process your personal data in this manner in order to deliver the services and process transactions according to the applicable contract between us. It is also in our legitimate interest to enable our service providers to perform certain activities on our behalf. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
To offer you the opportunity to use our invitation service and application so that you can tell your friends about the Services.
We process your data for these activities only if you have given your consent to do so.
- To administer our Website including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
- To improve our Website to ensure that consent is presented in the most effective manner for you and your computer, Device or other item of hardware through which you access the Website.
- To keep our Website safe and secure and to prevent detect fraud and abuse; and
- To comply with our legal obligations, policies, and procedures
For all these categories, it is in our legitimate interest to continually monitor and improve our services and your experience of the Website and to ensure network security. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
We may process your personal data to respond:
- To governmental requests or legal process (for example, a court order, search warrant or subpoena);
- To other circumstances in which we have a good faith belief that a crime has been or is being committed by a user;
- To an emergency exists that poses a threat to the safety of you or another person;
- When necessary to protect our property;
- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, asset sale or in the unlikely event of bankruptcy.
We conduct this processing to comply with our legal obligations and to protect the public interest.
To process otherwise for internal administrative and analytics purposes.
It is in our legitimate interest to process your personal data for internal administrative or analytics purposes. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
3. International Transfers
If you are located in the EEA:
Some of our processing of your data will involve transferring your data outside the European Economic Area ("EEA"). Some of our Service Providers are also based outside of the EEA, and their processing of your personal data will involve a transfer of data outside the EEA. This includes the United States. Where personal data is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal data, we take steps to provide appropriate safeguards to protect your personal data, including entering into standard contractual clauses approved by the European Commission, obliging recipients to protect your personal data.
4. Retention of Personal Data
5. Data Subject Access Rights
You have the following rights:
- Right of access to your personal data: You have the right to ask us for confirmation on whether we are processing your personal data, and access to the personal data and related information.
- Right to correction: You have the right to have your personal data corrected, as permitted by law.
- Right to erasure: You have the right to ask us to delete your personal data, as permitted by law.
- Right to withdraw consent: You have the right to withdraw consent that you have provided.
- Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a supervisory authority in the member state of your habitual residence.
- Right to restriction of processing: You have the right to request the limiting of our processing under limited circumstances.
- Right to data portability: You have the right to receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.
- Right to object: You have the right to object to our processing of your personal data, as permitted by law, under limited circumstances.
In order to exercise any of these rights, please contact us according to the "How to Contact Us" section herein. Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
Last Updated: June 5, 2019