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Privacy Policy

—     website terms and conditions.

Privacy Policy (Updated March 24, 2010)

The privacy practices described in this document (the “Privacy Policy”) apply to Personally Identifiable Information (as defined below) that we collect in connection with all products, services and website(s) (collectively, “the Site”) offered by Reach Networks and its subsidiaries (collectively “Reach Networks”). By visiting the Site you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please do not use or access the Site. We reserve the right to change this Privacy Policy without prior notice. You can determine when this Privacy Policy was last revised by referring to the “LAST UPDATED” legend at the top of this page. Any changes to our Privacy Policy will become effective upon our posting of the revised Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Privacy Policy then in effect.

Personally Identifiable Information may be collected by Reach Networks, disclosed to affiliates and third parties, and used by Reach Networks, affiliates and third parties. This Privacy Policy describes the Personally Identifiable Information we collect about you and how we may use and/or disclose that Personally Identifiable Information.

We have organized our Privacy Policy in Q&A format to address the most frequently asked questions. If you have any questions after reading through our Privacy Policy, please let us know. We want to hear from you! You can contact us at the link provided here.

Note Regarding the Use of the Site by Children: The Site is not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide Personally Identifiable Information through the Site.

PLEASE NOTE: Reach Networks reserves the right to change, modify or grant exceptions to this Policy where applicable law permits the Company to do so.

1. What information does Reach Networks collect from me?

a. Personally Identifiable Information

“Personally Identifiable Information” (or “PII”) is information that identifies you as an individual. Reach Networks may collect Personally Identifiable Information in a number of ways, but the two most common are during Site registration or Site personalization and product or service registration or enrollment. In some instances, you may visit the Site and use some of our services without providing PII to us. The PII requested may vary depending on which product, service or Site you are using or accessing. We typically ask for PII about you, such as your name, e-mail address, postal address, telephone numbers and fax numbers. We may also ask for financial information, such as account or credit card number to verify your user identity and to allow you to pay for any purchases you make. If you contact us, we may keep a record of that correspondence or communication, including any PII contained therein. Information on how you communicated with us may also be recorded and can include PII such as your e-mail address, the return e-mail address shown in any e-mail message from you, the return address on any envelope or facsimile number on any facsimile, or the telephone number from which you called. In some cases you will be given or asked to create an ID, and you can create a confidential password to be able to take full advantage of the Site’s many offerings.

In addition to the PII we obtain at the initial stage of registration, we may ask you for PII at other times, such as when you make a purchase or use a service on the Site; when you participate in a contest, survey, or promotion; or when you report a problem with the Site or one of our services. In most cases, the more specific information you provide, the better we are able to personalize your experience with Reach Networks.

b. Non-Personally Identifiable Information

Non-Personally Identifiable Information” (or “Non-PII“) is aggregated information, demographic information and any other information that does not reveal your specific identity. Reach Networks and its service providers collect Non-PII which does not identify you, through “cookies,” environmental variables, pixel tags and other technologies, your communications with us and other information you voluntarily provide.

Cookies: A cookie is a small amount of data that is sent to a browser from a web server, and gets saved on the hard drive of the computer that you are using. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular web site, to your computer. If you choose to reject all cookies, however, you will be unable to use those Reach Networks services that require registration or customization in order to participate. If you choose to accept cookies from us and our service providers, you are granting us and our service providers your consent to set cookies on your computer. To learn more about cookies, please visit

Environmental Variables: We and our service providers may also collect certain environmental variables, including MAC address, computer type (Windows or Macintosh), screen resolution, OS name and version, Internet browser, and Internet browser version. These environmental variables are collected by most browsers, and can be used to optimize your experience on the Site.

Pixel Tags: We and our service providers may also use so-called “pixel tags,” “web beacons,” “clear GIFs,” or other similar technologies in connection with Site pages and HTML-formatted e-mail messages to, among other things, track the actions of Site users and e-mail recipients, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates.

Communications: We and our service providers may also collect Non-PII in connection with how you communicated with us, including country domain, the language you selected for viewing order forms or other documents, your browser type, the currency in which you viewed prices if such feature is available, and your use of a secure or insecure Web page. Additionally, in connection with your registration of an Reach Networks product, service or support requests generated by the Reach Networks product or service you are using, or through submission of an error report, we and our service providers may collect request codes, activation codes, product release, product version, product language, graphics configuration driver name and version, list of applications running at the time of an error, list of Reach Networks products and services installed on the computer, list of recent Reach Networks commands and other Non-PII.

Information That You Voluntarily Provide: Reach Networks also collects Non-PII, such as a mother’s family name or a keyword, company name, title, geographic location, the industry that you work in and your security questions and answers, when you voluntarily provide it to us. Such information constitutes Non-PII because, unless combined with PII, it does not personally identify you or any other user. Additionally, we may aggregate PII in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using PII to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered Non-PII for purposes of this Privacy Policy.

c. IP Addresses and Serial Numbers

Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). Your IP address, machine name and the serial number (or old serial number) of a product or service you have purchased from us is recorded when you visit the Site (along with the time(s) of your visit(s) and the page(s) that you visited), when you register for the Site and/or when you send us an error report.

2. How does Reach Networks use my information?

a. Personally Identifiable Information

Reach Networks may use PII about you in the following ways:

Personalized Experience: One of Reach Networks’s goals in collecting PII is to provide you, the user, with a personalized experience on our Site and/or with our products and services. This includes personalization services (such as content that can be personalized by both you and Reach Networks), interactive communications (such as surveys and email contact with account representatives), online commerce, and many other types of services, many of which may be free to you.

Fulfill Requests: PII about you is used by us and our service providers to respond to your requests and fulfill the purpose for which the PII was provided, (e.g., to process and fulfill your product, service or support requests) and for administrative purposes (e.g., customer service). Additionally, we may use your PII to ensure that you are directed to the right Site, product and/or service for you.

Communications: If you sign up, we may use PII about you to provide you with information about products or services offered by Reach Networks, to recommend Reach Networks products and services and to enable you to take advantage of the many features they offer. If you later change your mind and no longer wish to receive such marketing communications from us, you may opt-out of such communications on a going-forward basis as set forth in Section 9 below. From time to time, in our sole discretion, we may use PII about you to send you important information regarding the Site or changes to our terms, conditions, and policies and/or to send you other administrative and/or operational communications. Because this information may be important to your use of the Site, products or services, you may not opt-out of receiving such operational communications.

Standardization: Reach Networks may also clean-up and standardize PII when it is collected. For example, Reach Networks may abbreviate the term: “street” to “St.” or correct a spelling mistake made when Reach Networks collected the PII.

Verification and Delivery: The PII you provide during product or service registration or enrollment will also be used by Reach Networks to identify you as an authorized user of an Reach Networks product or service and to issue your authorization code or password to enable Reach Networks to provide you with the product or service as set forth in the relevant documentation.

Promotions: PII that we obtain from voluntary programs such as surveys, promotions, and contests (“Promotions”) may be subject to additional or different privacy terms. If different terms do apply, details of the use of this PII will be outlined in the specific terms and conditions or rules of these Promotions. For example, we may share such PII you provide in connection with Promotions with third party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to such Promotion. Please be sure to read those specific terms and conditions or rules because they may alter what is written in this Privacy Policy on a case-by-case basis. To the extent that such terms and conditions or rules concerning the treatment of PII about you conflict with this Privacy Policy, such terms and conditions or rules shall control.

Purchases: When you make a purchase through the Site, we may use your PII in order to fulfill your purchase.

Matching: The PII you provide to this Site may be combined with other PII and information about you that is publicly available, or with other PII and information about you that we may otherwise obtain to better target our advertising and customize the content presented to you on the Site.

Compliance with our Terms and Conditions: We also use PII, including IP addresses, and other information to help us to identify unregistered or illegal versions of our products and services, or when we otherwise believe there has been a violation of law or other interference with or violation of Reach Networks’s or other individuals’ rights or property, and to take appropriate action.

Internal Business Purposes. We may also use PII about you for our internal business purposes, such as data analysis, audits, business continuity, disaster recovery, backup storage, data replication and so forth.

Careers: You may be able to submit PII through the Site in connection with career opportunities. All such PII will be governed by a separate privacy policy that applies such PII, and not this Privacy Policy.

b. Non-Personally Identifiable Information

Because Non-PII does not personally identify you, we may use such Non-PII for any purpose. For example, we may use Non-PII we collect to get a better understanding of our subscriber base by analyzing on an aggregate basis our users’ demographics, interests, and behavior. In addition, we reserve the right to share such Non PII, which does not personally identify you, with third parties, for any purpose.

In some instances, we may combine Non-PII with PII (such as combining your name with your geographic location). If we do combine any Non-PII with PII, the combined information will be treated by us as PII hereunder as long as it is so combined and used.

c. IP Addresses and Serial Numbers

We use IP addresses, machine names and serial numbers for purposes such as calculating Site, product and service usage levels, helping diagnose server, product and service problems, and administering and troubleshooting the Site and our products and services. Reach Networks also may use IP addresses, machine names and serial numbers for system administration and to report aggregate information to our advertisers. We also use IP addresses, machine names and serial numbers to help us to identify unregistered or illegal versions of our products and services, and to take appropriate action in connection with the same. Further, we use and disclose IP addresses, machine names and serial numbers for all the purposes set forth in Section 2(a) above and Section 3 below. Please note that we treat IP addresses, machine names, serial numbers and related information as Non-PII (and may use and disclose them as we use and disclose Non-PII), except where we are required to do otherwise under applicable law.

3. With whom does Reach Networks share my PII?

Our Business Partners, Strategic Alliance Companies: If you submit PII to Reach Networks in order to purchase a product or service from a partner or a company with which we have a relationship, we will need to share that PII with the relevant partner/company so that Reach Networks or the partner/company can process your order(s) to ship, supply, maintain, renew or service the products or services that you requested and you may be contacted by the partner/company for any of these purposes. From time to time we may share your PII with any partner or a company with which we have such a relationship for any of the purposes set out in this Section or for any of the purposes set out in Section 2 above. We require any such partner or company to agree to implement reasonable safeguards to protect the PII and to use the PII only for the purposes for which it was provided. Additionally, Reach Networks may combine your PII with other data and share that combined data with its partners.


Marketing Relationships: If you opt-in, we may share your PII with third parties so that they can provide you with information about their products and services. If you do not want your PII shared with such third parties for marketing purposes, you may opt-out of such sharing as described in Section 9 below.

Within Reach Networks: PII about you may be shared within Reach Networks, Inc. and its wholly owned subsidiaries for the purposes of providing you with products or services you have ordered or for which you have registered and to provide information to you about our products or services. (Contact List for Reach Networks and its Subsidiaries) Reach Networks is the party responsible for the management of the jointly-used PII.

Special Cases: Reach Networks may also use and/or disclose PII in other special cases when we have reason to believe that using and/or disclosing this PII is necessary to identify, contact, or if Reach Networks deems necessary, bring legal action (including action outside your country of residence) against someone who may be violating Reach Networks’s Terms of Service, end user license agreements and/or intellectual property rights. The same policy applies in cases where we believe an individual may be causing injury to or interfering with (either intentionally or unintentionally) Reach Networks’s rights or property, other users of an Reach Networks Site or service, or anyone else that could be harmed by such activities. Reach Networks may disclose or access PII when we believe in good faith that the law (including laws outside your country of residence) requires it, to comply with the legal process, to respond to requests from public authorities including public authorities outside your country of residence and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services, to protect our operations and to permit us to pursue available remedies or limit the damages that we may sustain. This includes exchanging PII with other companies and organizations for fraud protection and credit risk reduction.

Service Providers: We occasionally employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, sending postal mail and e-mail, removing repetitive PII from customer lists, ensuring accuracy of PII, analyzing data and providing related services, providing marketing assistance, fulfilling purchases and processing credit card payments. We may share PII about you with third parties for the purpose of enabling these third parties to perform such functions.

Assignment: As we continue to develop and expand our products and services, we may sell or buy businesses or product or service lines. In such transactions, customer PII is generally one of the assets transferred. As such, we reserve the right to transfer any and all information that we collect from Site users to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Reach Networks’s business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In addition, in connection with any such transaction, we reserve the right to share PII about you with our consultants and advisors (such as accountants and lawyers).

4. Forums

We and our service providers may make available through the Site services (for example, public forums, chat rooms, message boards, and/or news groups, among other services) to which you are able to post information and materials. If you visit such a service on a Site, please remember that any information that is disclosed in these areas becomes public information and may be available to visitors to the Site and to the general public. In addition, when you choose to make a posting on such services, certain PII (for example, your user name), will be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose PII about you, or any other information, on the Site. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PII YOU VOLUNTARILY DISCLOSE THROUGH THE SITE.

5. What about Reach Networks® Hosted Solutions?

Please note that if you receive an invitation to participate in an Reach Networks Hosted Solution (such as HostGator® or GoDaddy® amongst others) the invitation is usually sent by an employee of one of our customers or licensees who uses the Hosted Solution service. Any PII you provide to our customers or licensees (or employees of our customers or licensees) in order to join or participate in an Reach Networks Hosted Solution is available to our customers or licensees, and not to us unless the Hosted Solutions service is being administered or maintained by Reach Networks itself. Reach Networks does not control the PII maintained by our customers and licensees or the use and/or disclosure of that PII. Reach Networks IS NOT RESPONSIBLE OR LIABLE FOR THE USE AND/OR DISCLOSURE OF PII ABOUT YOU BY SUCH CUSTOMERS AND LICENSEES.

6. What about the Customer Involvement Program (CIP)?

The Customer Involvement Program (“CIP”) is a program that improves the way Reach Networks designs software and measures product performance and quality. It provides a way for customers to become involved in helping make Reach Networks products meet their needs better. If a customer chooses to participate in CIP, CIP automatically collects information about the customer’s use of product features, system configuration, and software errors. About once a day, a small file containing this CIP information is sent in encrypted form to Reach Networks’s CIP servers. The CIP data is analyzed to help improve existing products and products in development. The data collected by CIP also may be used as set forth in Section 2 and Section 3 above. By participating in the CIP, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please refrain from participating in CIP.

What information is collected? The following types of information may be collected from all CIP participants:

  • Operating system name and version
  • System configuration information, such as processor, memory, and graphics card
  • Reach Networks product commands and operations used
  • Name, serial number and version of Reach Networks products
  • Error conditions
  • Format and source of data imported or exported from Reach Networks products
  • IP address

If you participate with contact information:

In addition to the information listed above, CIP allows a participant to submit contact information (such as the participant’s email address and company name), along with the product serial number. Contact information is required if a participant seeks to participate in beta (pre-release) programs, and if the participant is willing to receive communication from Reach Networks developers and product managers.

I would like to stop participating in CIP. What do I do?

You can choose to participate or stop participating in CIP at any time by opening the CIP dialog box in the product Help menu and following the relevant instructions. Your choice applies to all Reach Networks products installed on your computer.

If you have any questions regarding the CIP program, please contact

7. What about Customer Error Reporting (CER)?

Reach Networks’s Customer Error Reporting (“CER”) makes it easy for you to send the details of a software error to Reach Networks for analysis.

The Customer Error Report dialog box appears whenever the Reach Networks product you are using closes unexpectedly. If you choose to send an error report to Reach Networks, the CER feature records the portion of program that was in use when the error occurred, the recent command history, and basic system information. In addition, you can include your e-mail address and a step-by-step description in the report. The customer error report is sent to Reach Networks in encrypted form. When Reach Networks receives the error report, automated systems sort the reports so that Reach Networks developers can review and analyze the data. Once a software error is believed to be fixed, it is included in either a future maintenance update or the next release of the product. Reach Networks may also notify those customers who initially reported the error, if they included their email address in the customer error report. Additionally, the data collected by CER also may be used as set forth in Section 2 and Section 3 above.

What Information Is Collected? If PII or confidential information is in the system memory when the software error occurs, it may be sent to Reach Networks with the error report through the CER feature. If you have concerns about information being sent to Reach Networks through CER, please do not send the error report.

CER collects and sends the following information as part of the error reporting process:

  • Operating system name and version
  • Reach Networks product name, version, and serial number
  • Graphics configuration driver name and version
  • List of Reach Networks applications loaded when an error occurs
  • List of recent Reach Networks commands
  • Portion of Reach Networks program in memory when an error occurs

If you provide optional information: In addition to the above information, you may choose to include the following optional information:

  • E-mail address: if you provide it in the Customer Error Report dialog box
  • Step-by-step description of the error: if you provide it in the Customer Error Report dialog box

8. What about Reach Networks partner services, strategic alliance companies, or linked sites?

Certain products and services are made available through an Reach Networks Site but are provided by partners, either through their own web sites or on web sites that they share with Reach Networks. When ordering, using or purchasing products or services from these partners, you will be entering into an agreement with that partner, and not with Reach Networks, and will be providing PII about you to such partner, not to Reach Networks. In these cases, this Privacy Policy does not apply; instead, the privacy policy of the partner actually providing the goods and services will apply. We urge you to read and understand our partners’ policies before entering into agreements with them.

Also, we may provide links to a partner’s or an advertiser’s site, or to other sites from the Site. These linked sites are not under Reach Networks’s control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on a Site does not imply endorsement of the linked site by Reach Networks. If you provide any PII through any such third party web site, your transaction will occur on such third party’s web site (not the Site) and the PII you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties.

If you have questions about our partners’ privacy policies or the privacy policies of these other sites, we encourage you to contact them directly. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

9. What are my choices regarding the use of my PII?

If you do not want to receive marketing information from us, or if you would prefer that we do not share PII about you with our affiliates or our partners so that our affiliates and partners can send you such marketing information, be sure to indicate that on your registration form if the form requires you to specify your choices.

In addition, if you change your mind, and no longer wish to receive marketing information from us on a going-forward basis, or if you would prefer that we do not share PII about you on a going-forward basis with our affiliates and/or with our partners for such affiliates’ and/or partners’ marketing purposes, you may opt-out of receiving such marketing-related information and/or from such sharing by submitting a request to change your marketing preferences.

Alternatively, directly contact your local Reach Networks office in writing. In all cases, please include your registered address with your request. Please specify clearly which of the following choices you are opting out of:

i. Receiving marketing-related e-mails from Reach Networks;

ii. Allowing Reach Networks to share PII about you with Reach Networks’s affiliates (including its subsidiaries) for their marketing purposes; and/or

iii. Allowing Reach Networks to share PII about you with partners for their marketing purposes.

We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove PII about you from the databases or third parties with which we have already shared PII about you (i.e., to which we have already provided PII about you as of the date that we implement your opt-out request). If you wish to cease receiving marketing-related e-mails from such third parties, please contact such third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related e-mails.

I would like to update the PII I originally provided to Reach Networks. What do I do?

If the Site requires registration, you can edit your profile on the Site. Just follow these instructions:

For Reach Networks Hosted Solutions: You can access and update the PII in your Reach Networks profile or edit your profile at any time by logging into your account and manually changing your profile information. Remember to have your username and password handy; you won’t be able to access your profile without them. If you have forgotten your password, please visit the Site login screen to have your password e-mailed to you. If you have any problems signing in to an Reach Networks Hosted Solution please contact the administrator of that Hosted Solution or the customer support number for the relevant product.

For the Subscription Center: You can access and update the PII in your Subscription Center profile at any time by logging in and selecting the “Edit Subscription Center Profile and Log-in” link. If you have any problems signing in to the Subscription Center, please submit the Subscription Customer Service form.

Subscription Customers and Licensees: You may change the contact persons for Subscription Centers by contacting Reach or using the Subscription Customer Service form.

In all other cases, you may send an e-mail to the applicable address specified in Section 9, above, in order to review and edit PII about you. Alternatively, directly contact your local Reach Networks office in writing. In all cases, please include your registered address with your request.

11. Can I cancel my Reach Networks Site accounts?

Yes, your Reach Networks Site account can be deleted or deactivated anytime. Once you do so, however, you won’t be able to access any members-only area of the Reach Networks service you’ve deactivated. To delete your account, please follow the instructions below:

Reach Networks Hosted Solutions: If you are a customer or licensee of an Reach Networks Hosted Solution, your account can be deleted or deactivated at any time. Once you do so, however, you won’t be able to access that Hosted Solution. To delete a user from your account, please contact your administrator and be sure to include your username. To delete or disable an entire account (including all users), please send an e-mail to the applicable email address specified above in Section 9 or the customer support number for the relevant product. In the event you send a written request to Reach Networks to delete PII about you, Reach Networks will, subject to any legal obligations imposed on Reach Networks to maintain such records, destroy PII about you or make it unidentifiable in a commercially reasonable amount of time.

In the event you are a participant in an Reach Networks Hosted Solution who has been invited to participate in the Hosted Solution by a customer or licensee or Reach Networks, please contact such customer or licensee directly to delete your account. Reach Networks IS NOT RESPONSIBLE OR LIABLE FOR ANY FAILURE BY ANY SUCH CUSTOMER OR LICENSEE TO DELETE YOUR ACCOUNT OR TO DESTROY OR MAKE UNIDENTIFIABLE PII ABOUT YOU.

The Subscription Center: If you are a customer or licensee of Reach Networks, you can delete your Subscription Center account at any time. Deleting your Subscription Center account does not affect your subscription contract with Reach Networks, and you will still receive subscription notifications pertaining to your contract. To delete your account, please contact subscription-team@Reach and be sure to include your Subscription Center member name

You must deactivate your account separately at each Reach Networks Site where you are registered.

12. What kinds of security precautions are in place to protect my PII?

If you register and create a profile on the Site, your profile is password-protected. We recommend that you do not divulge your password to anyone. Also remember to sign out of your Reach Networks account and close your browser window when you have finished your work. This is to prevent others from accessing PII about you. We use reasonable organizational, technical and administrative measures to protect PII you provide through the Site that is under our control. However, since no data transmission over the Internet or data storage system can be guaranteed to be 100% secure, we cannot ensure or warrant the security of any information you transmit to us, we transmit to you or that we store. Please do not send us sensitive information through email. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with this Privacy Policy (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).

13. Where is my PII stored?

PII about you may be processed and stored in the United States or other countries. You hereby consent to the transfer of any PII to the United States or any other country outside of your country of residence where Reach Networks or its licensees, agents or service providers are providing services or processing or storing PII in accordance with the terms of this Privacy Policy, which countries may provide a different level of data security than in your country of residence. Reach Networks does not represent or warrant that the Site, or any part thereof, are appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

14. How long is my PII retained?

We will retain PII about you for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required by law.