Types of Information We Collect
The following are examples of the types of information that we collect about you and how we use that information.
When We Collect Information
Types of Information We Collect
Primary Purpose for Collection and Use of Information
Bernoulli | Locke Membership Program – Obtaining an Application for Membership
If you request an invitation or are referred to us for an invitation to apply to become a Member of the Program, we collect your name, contact information (such as postal address, e-mail address and telephone number) and date of birth. We may also collect financial information about you, information about your education and employment, information about your profile in the community and your presence on social media, information provided in references from third parties, and other information pertinent to your qualifications to become a Member.
We have a legitimate interest in administering the Program, including, among other things, making sure that you meet our qualifications for membership, and sending (or declining to send) an invitation to apply.
Bernoulli | Locke Membership Program – Applying for Membership
If you apply to become a Member of the Program, we collect your name, postal address, e-mail address, telephone number, date of birth, billing address and credit card (or other payment) information. We use reasonable efforts to protect your payment information from unauthorized access, use or disclosure. (For more information see “How We Protect Personal Information” below.) We may also collect financial information about you, information about your education and employment, information about your profile in the community and your presence on social media, information provided in references from third parties, information obtained from background checks, and other information pertinent to your qualifications to become a Member. We may also collect your photograph. If you apply for membership for one or more of your children, we collect the name and date of birth of each child. We may also collect each child’s photograph.
We have a legitimate interest in administering the Program, including, among other things, making sure that you meet our qualifications for membership, processing your application, processing your payment for membership fees, communicating with you about Program benefits, providing you with membership benefits, detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
Email Interconnectivity
If you receive email from us, we use certain tools to capture data related to when you open our message, and click on any links or banners it contains.
We have a legitimate interest in understanding how you interact with our communications to you.
Feedback/Support
If you provide us feedback or contact us for support, we collect your name and e-mail address and possibly other personal information, as well as any other content that you send to us.
We have a legitimate interest in receiving and acting upon your feedback or issues.
Mailing List
When you sign up for one of our mailing lists, we collect your email address and/or postal address.
We have a legitimate interest in sharing with you information about the Program, and products and services we offer, and we use your email address or postal address to share such information. Where required by law, we first obtain your consent to share information about our products or services with you.
Web logs
We collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet), domain name, click-activity, referring website, and/or a date/time stamp for your visit.
We have a legitimate interest in monitoring our networks and the visitors to our website. Among other things, it helps us understand how to best provide visitors with information.
Screen Trackers
We collect information from you about your computer, and your activity on screen when you are visiting our website, including when our website is open on your screen, where on your screen you spend time, your keystrokes, and other activity.
We have a legitimate interest in monitoring your activity when you visit our website. Among other things, it helps us understand website traffic, how our website is being used, how to best provide visitors with information, and how to enhance the experience of visitors to our website.
Cookies
“Cookies” are small pieces of information that a website sends to your device while you are viewing a website. We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). You can manage cookies by following instructions provided by your browser. If you choose to disable cookies, some areas or features of our website may not work properly.
We have a legitimate interest in being able to identify your device. Among other things, cookies help us to make our website operate efficiently, to improve user experience on our website, and to understand website traffic and how our website is being used. Cookies also allow us to provide you with a more personal and interactive experience tailored to your interests.
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates and publicly available sources.
Use and Processing of Your Personal Information
We do not use or process your personal information, except for the uses described above and as follows:
Sharing of Personal Information
We do not share or disclose your personal information, except in the specific situations discussed elsewhere in this Privacy Policy, and as follows:
Your Choices
You can make the following choices regarding your personal information:
How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
How Long We Retain Information
We retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
Information for California Residents
You can exercise these rights by contacting us at [email protected]. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.
Information for Non-US Residents
If you are located outside the United States, and you are not satisfied with our response, you may have a right to lodge a complaint with your local data protection regulatory authority.
Third Party Applications/Websites
We have no control over the privacy practices of websites or software applications that we do not own. To enhance your experience on our website, we may use applications provided by third parties or link to websites operated by third parties. Your use of such services is subject to the privacy policies of such third parties applicable to their applications and websites.
If you have any questions, comments or complaints concerning our privacy practices please contact us at [email protected]. We will attempt, where practical, to respond to your requests and to provide you with additional privacy-related information.
We may change our Privacy Policy and privacy practices over time. To the extent that this Privacy Policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information.
Last updated: September 9, 2020.
California Information Sharing Disclosure
California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 state that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). The table below indicates the categories of personal information we collect and transfer in a variety of situations. Because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself. For example, while we transfer credit card or debit card numbers for our business purpose in order to process payments of membership fees and registration fees, and payments for orders placed with us, we do not collect or transfer credit card or debit card numbers of individuals who only provide us feedback or contact us for support.
Category of Personal Information
Is information collected by us?
Is information transferred for valuable consideration?
Is information shared with service providers for business purposes?
Audio Information (e.g., recordings of customer service calls for quality, training and security purposes)
YES
NO
YES
YES
NO
YES
Bank account number (e.g., if you voluntarily provide it to us in connection with an application for membership)
YES
NO
YES
Biometric information (e.g., your iris scan and fingerprints provided with an application for membership)
NO
NO
NO
Commercial information (e.g., payments you made)
YES
NO
YES
Credit card number (e.g., if you voluntarily provide it to us in connection with an application for membership)
YES
NO
YES
Debit card number (e.g., if you voluntarily provide it to us in connection with an application for membership)
YES
NO
YES
Driver’s License Number / State ID
YES
NO
YES
Education (e.g., in some cases to assess your qualifications for membership in the Program)
YES
NO
YES
Electronic network activity (e.g., browsing history)
YES
NO
YES
Email address (e.g., to send you emails in connection with your application to become a Member of the Program, and to send you promotional emails relating to the Program)
YES
NO
YES
Employment (e.g., in some cases to assess your qualifications for membership in the Program)
YES
NO
YES
Employment history (e.g., in some cases to assess your qualifications for membership in the Program)
YES
NO
YES
Health insurance information
NO
NO
NO
Identifiers (e.g., name you provide to us, or the IP address assigned to your computer when you use the Internet and visit our website)
YES
NO
YES
Insurance Policy Number
NO
NO
NO
Medical information (e.g., when we assess your qualifications to become a Member of the Program)
NO
NO
NO
Other financial information (e.g., when we assess your qualifications to become a Member of the Program)
YES
NO
YES
Passport Number
NO
NO
NO
Physical Characteristics (e.g., if you provide us with a photograph)
YES
NO
YES
Postal address (e.g., in connection with your application to become a Member of the Program, or to send you promotional materials relating to the Program)
YES
NO
YES
Signature (e.g., to process credit card or debit card transactions)
YES
NO
YES
Social Security Number
NO
NO
NO
Telephone Number (e.g., to communicate with you about your application to become a Member of the Program, to respond to you if you contact customer service, or to send you SMS messages if you signed up to receive messages)
YES
NO
YES
Transaction information (e.g., to process your payment of membership fees for membership in the Program)
YES
NO
YES
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