This Privacy Policy governs the manner in which www.adiagrawal.com, Inc and Assume Positive Intent. ( “Assume Positive Intent ” “we,” or “us”) collects, uses, maintains and discloses information collected from users (a “user,” as well as “you,” “your” and similar terms) through our website at www.adiagrawal.com as well as any other online services that we operate and that link to this Privacy Policy (collectively, the “Online Resources”).
By using the website or any of the Online Resources, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Online Resources.
What Information Do We Collect and How Do We Collect It?
We and our third party service providers may collect all or any of the following information:
- Personal Information. “Personal Information” is information that you provide to us that can be used to identify you. When you contact us via email, we collect your email address and any additional Personal Information you provide in the body of the email communication. In the event that we fulfill an order from you, we will collect payment information from you, including billing address. We may also collect your name, address, phone number, and email address with your consent. As part of using our website, we also collect information on the IP address of a user’s device.
- Aggregate Information. “Aggregate Information” is information that is aggregated together such that it is not tied to a particular user. We may collect Aggregate Information on, for example, the type of browser and computer or mobile device you are using, technical information about your means of connecting to our Online Resources (e.g., the operating system and the Internet or mobile service providers utilized), information about other websites you have recently visited, your site activity, and the time and date of your visit, and other similar information. Aggregate Information may be collected when you visit or interact with our Online Resources, independent of any information you voluntarily enter.
- Cookies. A cookie is a data file placed on a device (such as your computer or smartphone) when it is used to visit our Online Resources. Cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Please be aware that if you disable or remove cookies on your device, some parts of our Online Resources might not function properly, and that when you revisit our Online Resources your ability to limit cookies is subject to your browser settings and limitations.
What Do We Do With the Information We Collect?
Personal Information. We use Personal Information only for the purposes for which it has been provided to us. We will not sell or use your Personal Information for any other reason, except to the extent that you consent for us to do so, and in any event only as provided pursuant to this Privacy Policy. We limit access to Personal Information only to those individuals whose responsibility it is to address the user’s specific request.
Aggregate Information. We use Aggregate Information for a variety of purposes, such as to understand how our users as a group use the Online Resources, to improve the Online Resources, to personalize user experience, and to process transactions. We also use Aggregate Information to track numbers of visitors to our site and numbers of visitors to various sections of our site for the purpose of determining trends and user needs. Aggregate information is analyzed and used as input to help us improve our site. No personally identifiable information is available or used in this process.
When Do We Provide Information to Third Parties?
Service Providers. We may use third party service providers to perform certain services on our behalf on the Online Resources, such as hosting the Online Resources, tracking the Online Resources’ activities and analytics, and performing other administrative services. We may provide these service providers with access to user information, including Personal Information, solely to the extent necessary to carry out the services they are performing. These third party service providers are not authorized to retain, share, store or use the Personal Information for any purposes other than to provide the services they have been hired to provide.
Analytics. We use Google Analytics to help us understand how users use our Online Resources, so that we may improve our services. Information about how Google Analytics uses data, and how you may control what information of yours is shared with Google, can be found here.
Compliance with Law. Without limiting the above, we may access, use, preserve, transfer and disclose your Personal Information to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the policies applicable to the Online Resources, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Online Resources or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues.
Business Transitions. We reserve the right to disclose and transfer all user information: (a) to a subsequent owner, co-owner or operator of the Online Resources or applicable database; or (b) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
Do You Retain and Delete My Data?
We will retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. In some circumstances, we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information.
How Do I Change My Information And Communications Preferences?
You may provide updates and changes to the information that you submit to us by contacting us at advisor@adiagrawal.com. If so, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable.
Please note that we reserve the right to send you certain communications relating to use of our Online Resources, such as administrative and service announcements, and these messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about your Privacy Policy or practices described in it, you should contact us by e-mail: advisor@adiagrawal.com.
What Should Parents Know About Children?
The online resources are not intended nor designed to attract users under the age of 16[MJ1] . We do not knowingly collect any Personal Information from children younger than the age of sixteen. We will delete any Personal Information collected that we later determine to be from a user younger than the age of sixteen. If you are a parent or guardian of a child under the age of sixteen and believe he or she has disclosed Personal Information to us, please contact us at: advisor@adiagrawal.com.
Information Regarding Do Not Track Signals and Collection of Personally Identifiable Information for Third Party Advertising
We do not honor “do not track” signals.
We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies.
What are my rights regarding my personal information?
If you are a resident of the European Union or the State of California, you have the right to:
- You have the right to request an accounting of all Personal Information that we have that pertains to you, and to be delivered copies of such information in electronic format (e.g., electronic copies of information attached to an email). We reserve the right to transmit information to you in a manner that complies with all applicable laws.
- You have the right to request that we change any Personal Information that pertains to you that is inaccurate.
- You have the right to request that we delete some or all Personal Information that pertains to you. We reserve the right to carry out such a request in a manner that complies with all applicable laws, such as laws concerning record retention. Note that fulfilling this request requires us to delete Personal Information in our possession, but that this right does not extend to Personal Information that has already been lawfully shared in accordance with this Policy.
- You have the right to request that we cease processing any Personal Information that pertains to you. Note that fulfilling this request requires us to cease processing Personal Information that pertains to you in the future, but does not apply to lawful processing that has already occurred in accordance with this Policy.
- You have the right to exercise all the rights afforded by this Policy without fear of retaliation or discrimination. This means that we treat Users who exercise any of the rights under this Policy the same as Users who do not.
To exercise any of the rights explained above, please contact advisor@adiagrawal.com. Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
If you are a resident of the EU and believe that we have misused your personal data, you also have a right to lodge a complaint with a national Data Protection Authority. Each European Union member nation has established its own Data Protection Authority; you can find out about the Data Protection Authority in your country here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Users In the European Union
For users within the European Union, we transfer data from the EU to data centers located in the United States for processing, pursuant to your consent as indicated when requested. Such processing is performed in accordance with the GDPR. This includes the imposition of required safeguards with respect to accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of data.
Users within the European Union should be aware that the European Commission has determined that the law of the United States does not provide a level of protection adequate to satisfy the requirements of the GDPR.
Will This Policy Change?
We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy. Your continued use of the Online Resources following the posting of revisions to this Privacy Policy will be deemed your acceptance of such revisions. We encourage users to frequently check the email account that they use in connection with the Online Resources, as well as this Privacy Policy, to stay informed about any changes to this Privacy Policy. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically. The date at the bottom of this Privacy Policy will be updated for each revision.
Miscellaneous
This Privacy Policy will be governed by and construed in accordance with the laws of the Commonwealth of Massachusetts, USA, without regarding to conflicts of law principles. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
Questions or Concerns
You may direct any questions or concerns regarding the use or disclosure of your information, or any other matter related to this Privacy Policy, to: advisor@adiagrawal.com.
Effective Date: November 3, 2004.