2. The Types of Information You May Provide. Information you may provide to Lexington Solution via the Website falls into two categories: (i) personal information, and (ii) aggregate information. “Personal Information” is any information that could reasonably be used to identify you, including your name, address, e-mail address, birth date, financial information, photograph, telephone number, or any combination of information that could be used to identify you. “Anonymous Information” is information that does not identify you, and may include statistical information concerning, for example, your use of our Website and any associated services.
3. Personal Information; Our Uses of this Information. We will not share your Personal Information that we receive in connection with the Website with third parties, other than as expressly disclosed in this Section 3 (Personal Information; Our Uses of this Information). We may collect information from you at different points through our Website and through our Services, and use this information as follows:
3.1. Inquiry Forms. You may wish to submit inquiries to us using the contact form available on our Website, such as to ask for more information about the products and services we offer. You may also submit inquiries to us via email at the addresses included on our Site. By communicating with us, you may provide us with Personal Information, such as your name and email address. In these instances, we use any information you provide to us strictly for the purposes for which you submit the information.
3.2. Case Studies. We make available to you through our Site the ability to download case studies that analyze the efficacy of our product and services. In order to download such case studies, you are required to provide us with Personal Information, such as your name, job title, company name, email address and phone number.
3.3. Informational Notices and Bulletins. Periodically, we may choose to send news, bulletins, marketing materials, or other information, and we will use Personal Information to send such communications. We will use Personal Information that you provide to send such communications. If we choose to undertake such communications, you will have the ability to opt out of receiving these communications as provided in Section 9 (Changing or Removing Information; Opting Out).
3.4. Other Uses. We may collect Personal Information from you in ways other than those set out in this Section 3 (Personal Information; Our Uses of this Information); provided, however, that if we do so, then we will explain how we will use such information before you submit it to us, with such explanations included on the Website.
3.5. Extent of Information Collected. Lexington Solution does not collect any more Personal Information than reasonably necessary to provide any related services.
4. Anonymous, Aggregate Information. We use Anonymous Information to analyze the effectiveness of our Website, to improve our services, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our services. We may collect Anonymous Information through features of the software that supports our services, and through other means described below.
4.1. IP Addresses; Logs. Lexington Solution may automatically receive and record information in our server logs from your browser, including your IP address, your mobile device’s name, the type and version of your web browser, referrer addresses, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which may be aggregated with that of other users in order to understand how our Website is being used, and for security and monitoring purposes. None of this data contains Personal Information.
4.3. Tags. We may use so-called “pixel tags” — small graphic images (also know as “web beacons” or “single-pixel GIFS”) — to tell us what parts of our Website have been visited or to measure the effectiveness of user activity on our Website. Pixel tags also enable us to send email messages in a format users can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our users. None of this data includes Personal Information, and you can “opt-out” of receiving these types of emails from us by following the directions provided in Section 9 (Changing or Removing Information; Opting Out). If any Personal Information is collected using such tools, it will be subject to the terms of this Policy.
4.4. Click-Throughs. We may send email messages, which use a “click-through URL” linked to content on our Website. When you click one of these URLs, you pass through our web server before arriving at the Website. We track this click-through data to help determine interest in particular topics and to measure the effectiveness of our communications. If you prefer not to be tracked, then simply do not click text or graphic links in the email or notify us in accordance with Section 9 (Changing or Removing Information; Opting Out).
4.5. Computer Configuration. In order to determine whether your computer or mobile device is supported by our system, we may collect certain Anonymous Information. This information includes, but may not be limited to, your operating system and browser, as well as the presence of any software that our Website may require to operate with your computer or mobile device, or other third party software on your mobile device. This information is kept strictly confidential and is not shared with third parties, except as provided for in this Policy.
6. We Do Not Disclose Personal Information to Unaffiliated Third Parties; Limited Exceptions. We will not disclose your Personal Information collected by Lexington Solution to unaffiliated third parties without your express consent, except in the following limited circumstances:
6.1. Vendors. We may employ other companies to perform functions on our behalf, such as hosting or maintaining the Website, providing services related to the Website, collecting information, responding to and sending email, or other functions related to our business. We may need to share your Personal Information with these companies (collectively, the “Vendors”). We will provide Vendors with only that information necessary to perform their functions, and we will not allow them to use your Personal Information for any other purpose.
6.3. Legal. Lexington Solution will reveal your Personal Information to the extent we reasonably believe we are required to do so by law. If we receive legal process calling for the disclosure of your Personal Information, then we will attempt to notify you via the email address that you provided (if available) and within a reasonable amount of time before we respond to the request, unless such notification is not permitted.
7.1. Categories of Cookies We May Use. We may use the following categories of cookies on our Website:
8. Specific Disclosures for the European Economic Area.
8.1. Applicability. This Section 8 (Specific Disclosures for the European Economic Area) applies to our online data practices with respect to any individuals residing in the European Economic Area and, regardless of residence, to the processing of Personal Data in the European Economic Area. For purposes of this Section 8 (Specific Disclosures for the European Economic Area), the term “Personal Data” means any information relating to an identified or identified natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, or to one or more factors specific to the physical, physiological, generic, mental, economic, cultural, or social identify of such person.
8.2. Data Processing. We may process Personal Data in order to maintain our Site and to provide our services, and such Personal Data may include names, mailing addresses, email addresses, and telephone numbers (the “Relationship Activities”). We may also send marketing materials or communications to potential or existing customers using the Relationship Data (the “Marketing Activities”). We function as the “controller” under the European Union General Data Protection Regulation (the “GDPR”) for purposes of our Relationship and Marketing Activities. Our disclosures with respect to our processing of Personal Data in our capacity as a controller are further set out in this Section 8 (Specific Disclosures for the European Economic Area).
8.3. How We Collect and Use Personal Data. Our collection and use of Personal Data is set out in Section 3 (Personal Information; Our Uses of this Information) and, to the extent applicable, Section 4 (Anonymous, Aggregate Information). Our disclosure of Personal Data is limited to circumstances where we are permitted to do so under applicable European and national data protection laws and regulations.
8.5. Consent for Processing; Withdrawing Consent. If we are not already authorized to process Personal Data pursuant to applicable law, then we will ask for your consent, including in instances where we process your Personal Data in order to contact you with information about offers, products, promotions, and services that we believe may be of interest to you, and for other marketing purposes.
If our processing of your Personal Data is based on your consent, then you may withdraw your consent at any time by contacting us at email@example.com, provided that we are not required by applicable law or professional standards to not honor his withdrawal.
8.7. Provision to Service Providers. Our disclosure of Personal Data is limited to circumstances where we are permitted to do so under applicable national data protection laws and regulations. We use third party service providers to provide us technical infrastructure, communication tools, and other services to help us deliver and support our products and services. We evaluate our third party partners and utilize third party service providers whose practices are consistent with the GDPR.
8.8. Your Rights. You have the right in certain circumstances to request confirmation from us as to whether or not we are processing your Personal Data. Where we are processing your Personal Data, you also have the right to request access to, modification of, or deletion of such Personal Data. You also have the right in certain circumstances to receive the Personal Data concerning you that you provided to us, to restrict processing of your Personal Data, or to transmit such data to another controller. To exercise your rights with respect to your Personal Data, please contact us at firstname.lastname@example.org. As permitted by law, certain data elements may not be subject to access, modification, portability, restriction, or deletion. Furthermore, where permissible, we may charge for this service. We will respond to reasonable requests as soon as practicable and as required by law.
8.9. Right to Lodge a Complaint with a Supervisory Authority. You may have a right to lodge a complaint with a supervisory board.
9. Changing or Removing Information; Opting Out.
9.1. Opt-Out. If we choose to send to you bulletins, updates, or other unsolicited communications that are marketing-related materials, then we will provide you with the ability to decline – or “opt-out of” – receiving such communications. Instructions for opting-out will be provided if and when we determine to send you such a communication. Please understand that you will not be allowed to “opt–out” of formal notices concerning the operation of this Website, or legal and other related notices concerning your relationship to the Website.
9.2. Deleting Information. Finally, if you request, we will remove your name and all other Personal Information from our databases. Please understand, however, that it may be impossible to remove this information completely, due to backups and records of deletions. In addition, please understand that, if you request deletion of your information, you will be unable to utilize associated features of the Website and any associated services. You may not remove de-identified, anonymous, or aggregate data from our databases.
10. Security. We have put in place security systems designed to prevent unauthorized access to or disclosure of Personal Information you provide to us, and we take all reasonable steps to secure and safeguard this Information. Lexington Solution employees are required to acknowledge that they understand and will abide by our policies with respect to the confidentiality of Personal Information. Additionally, we ensure that Vendors’ security policies are at least as protective of your information as our Policy. Moreover, we provide access to our databases containing Personal Information on a need-to-know basis only.
Our security systems are therefore structured to deter and prevent hackers and others from accessing information that you provide to us. We also use software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. Please understand, though, that this information should not be construed in any way as giving business, legal, or other advice, or warranting as fail proof, the security of information provided by or submitted to Lexington Solution. Due to the nature of Internet communications and evolving technologies, we cannot provide, and expressly disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
11. Notice of Security Incident. If we detect, despite the safeguards set out above, an intrusion or other unauthorized access to or use of Personal Information (an “Intrusion”), then we will: (i) notify effected users of the Intrusion if the information at issue is sensitive, in our discretion; (ii) deliver this notice by the means we deem most efficient under the circumstances (such as, for example, first class mail or email); (iii) use contact information for each effected user that is current in our files; and (iv) use commercially reasonable efforts to accomplish these steps and effect this notice in a timely manner. To the extent applicable law requires steps in addition to those specified above, we will under all circumstances comply with applicable law.
12. Participation by Children and Teens; Advisory. Due to federal law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT ALLOW INDIVIDUALS WHO WE KNOW ARE UNDER 13 TO PARTICIPATE IN OUR WEBSITE OR SERVICES. YOU MUST BE AT LEAST 13 YEARS OLD TO USE OUR WEBSITE AND SERVICES. IF YOU ARE BETWEEN 13 AND THE APPLICABLE AGE OF MAJORITY, PLEASE REVIEW THIS AGREEMENT WITH YOUR PARENT OR GUARDIAN. Please understand that we cannot necessarily tell if a user is providing us with her or his true age.
13. Notice to California Residents. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by Lexington Solution to third parties for the third parties’ direct marketing purposes. As described above, we do not disclose users’ Personal Information to third parties for direct marketing purposes. Nevertheless, if you wish to make such a request, please send an email to or write us at:
Mail: One Boston Place, Suite 2100
Boston, MA 02108-4406
14. Do Not Track Notice. Certain web browsers allow consumers to enable “do not track” signals through which a consumer can signal to websites and online services whether the consumer approves of the collection of personal information about its online activities over time and across third-party websites and online services. Lexington Solution does not respond to “do not track” signals.
17. Further Resources. If you wish further information concerning privacy policies in general, you should visit the following site: http://www.ftc.gov/privacy/index.html.
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