This Privacy Policy (“Privacy Policy”) describes how GoldenSource and its subsidiaries and affiliates (“GoldenSource,” “us,” “we,” or “our”) may collect, use, and share your personal information in connection with https://www.thegoldensource.com/ and any other websites we operate that link to this Privacy Policy (collectively, the “Site”), and our related services, events, social media pages, and email and other electronic communications (collectively, and together with the Site, the “Platform”), and the choices you have with respect to your personal information. 

This Privacy Policy does not apply to personal information that we may store or maintain on behalf of any of our business customers who use our solutions, where applicable. For more information about the privacy practices of one of our customers, please refer to their privacy policy or notice. 

We reserve the right, at any time, to modify this Privacy Policy. If we modify how we collect, use, or share personal information, we will post the updated Privacy Policy on this page. In some cases, we may notify you about an update by sending you an email, posting a notice about the update on the Platform, or other means as may be required by applicable law. In all cases, your continued use of the Platform following posting or other notification of changes constitutes your acknowledgement of such changes. Please review this Privacy Policy periodically to keep up to date on our most current policies and practices. 

This Privacy Policy covers the following topics:

1. COLLECTION OF PERSONAL INFORMATION
2. USE OF PERSONAL INFORMATION
3. DISCLOSURE OF PERSONAL INFORMATION
4. YOUR CHOICES
5. CHILDREN’S PRIVACY
6. SECURITY OF PERSONAL INFORMATION
7. RETENTION OF PERSONAL INFORMATION
8. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
9. THIRD PARTY SITES AND SERVICES
10. NOTICE TO CALIFORNIA RESIDENTS
11. NOTICE TO NEVADA RESIDENTS
12. NOTICE TO INDIVIDUALS IN EUROPE
13. CONTACT US

Personal Information You Provide to Us. We collect and process personal information when you provide it to us, including, for example:

• Contact information, such as your first and last name, email address, phone number, postal address, or LinkedIn.
• Professional information, such as company name, location, and email, and other details we may collect about your company.
• Account information, such as your login credentials, name, email address or phone number, and details about your use of the Platform.
• Payment information, such as bank account number, banking institution, or financial account details used for payments. 
• Survey responses, such as the information you provide in response to our surveys, questionnaires, or contests.
• Communications, such as communications that we exchange, including when you contact us with questions, feedback, or otherwise.
• Marketing Preferences, such as your preferences for receiving marketing and promotional communications, and details about how you engage with our communications.
• Other Information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Personal Information Collected Automatically. When you visit or interact with the Platform, information about you or your device may be automatically collected or logged by us and our service providers or advertising partners, including:

• Online activity information, such as the website you visited before browsing to the Site, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.

Like many online services, we use cookies and similar technologies to facilitate automatic data collection. Depending on how you interact with the Platform, these technologies may include: 

• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
• Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data. 
• Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of email or marketing campaigns.
• Local storage, which is used to save data on a visitor’s device. We may use data from local storage to, for example, turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our Platform, remember your preferences, or measure ad effectiveness.

Personal Information Obtained from Third Parties. GoldenSource may receive personal information from third parties, such as our service providers, advertising partners, data analytics partners, operating systems and platforms, social media platforms, event sponsors, publicly available sources, or data providers. We may merge or combine such personal information with the personal information we collect from you directly or automatically.

Referrals. Users of the Platform may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.

GoldenSource’s primary purpose in collecting personal information is to provide the services that you request. We also use personal information for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.

To Provide the Platform. We use personal information to provide our Platform and operate our business. For example, we use personal information to:

• process your transactions, including granting access to our Platform and providing our services and technology;
• establish, manage, monitor, and maintain your account; 
• improve and personalize your experience on or with the Platform;
• verify your identity or determine your eligibility for offers and promotions;
• communicate with you, including providing notices about your account or transaction (e.g., confirmations, invoices, technical notices, updates, and security alerts) and responding to any of your requests, feedback, or questions;
• contact you by phone, email, or other form of communication;
• provide any contests, surveys, sweepstakes, or other promotions you participate in;
• provide maintenance and support; and
• fulfill any other purpose for which you provide personal information.

Research and Development. We may use your personal information for research and development purposes, including to study and improve the Platform and our business, and to develop new features, functionality, products, and services. As part of these activities, we create diagnostic and usage-related information and data from the use, performance and operation of the Platform that may include, but is not limited to, usage patterns, traffic logs, and user engagement with the Platform. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.

Direct Marketing. We may send you GoldenSource-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us and our business partners. You may opt-out of our marketing communications as described in the “YOUR CHOICES” section below. 

Interest-Based Advertising. We may work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our services. These companies may use cookies and similar technologies to collect information about you (including the online activity information and device information described above) over time across our Site and other websites or your interaction with our emails, and use that information to serve ads that they think will interest you. You can learn more about your choices for limiting interest-based advertising in the “YOUR CHOICES” section below. 

Compliance, Fraud Prevention, and Safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Platform, business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Platform; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. We will also use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

With Your Consent. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.

In addition to the specific situations discussed elsewhere in this Privacy Policy or at the point of collection, GoldenSource may disclose your personal information to the following entities or persons:

Related Companies. We may disclose your personal information to companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us), such as affiliates and subsidiaries. 

Service Providers. We may disclose your personal information to third parties who perform services on our behalf that are necessary for the orderly operation of our business. For example, we work with service providers that help us perform website hosting, maintenance services, database management, analytics, marketing, customer relationship management, and other purposes.

Advertising Partners. We may disclose personal information to third parties who we partner with for advertising campaigns or that collect information about your activity on the Platform for the purposes described in the “Interest-Based Advertising” section above.

Our Customers. If you joined or were added to our products or services as an authorized user of your employer, we may share personal information about you with your employer to facilitate the services that we provide to them. 

Professional Advisors. We may disclose your personal information to our professional advisors, such as lawyers, bankers, auditors or insurers, where necessary in the course of the professional services that they render to us.

Law Enforcement, Government Authorities, and Private Parties. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). We may also disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “Compliance, Fraud Prevention, and Safety.”

Business Transaction Participants. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).

You can make the following choices regarding your personal information:

Marketing Emails. You may opt-out of marketing-related emails by clicking the “unsubscribe” link at the bottom of the email or by contacting us as described at the end of this Privacy Policy. You may still receive service-related communications, such as those about your account, to fulfill orders for services you have requested, or deliver notifications directly to you through the Platform.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and they may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. 

Analytics. We use Google Analytics to help us analyze how our Site is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here. 

Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), and the Digital Advertising Alliance (https://optout.aboutads.info). Individuals in Europe may also visit the European Interactive Digital Advertising Alliance (available at http://www.youronlinechoices.eu/). Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.

Many of the opt-out preferences described in this section must be set on each device or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. The Platform currently does not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

The Platform is not intended for use by anyone under the age of 18, and we do not knowingly collect personal information from children under 18.

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 the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.

We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

GoldenSource is based in the United States, and we have service providers in the United States and potentially other countries. Your personal information may be collected, used, and stored in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein. European users may view the section below titled “NOTICE TO INDIVIDUALS IN EUROPE” for additional information about data transfers.

The Platform may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and online services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

This section applies only to California residents and supplements the practices described elsewhere in this Privacy Policy. It describes how we collect, use, sell, share, and retain personal information of California residents, and their rights with respect to their personal information. For purposes of this section “personal information” has the meaning given in the California Consumer Privacy Act of 2018, as amended (the “CCPA”), but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.

Personal Information Collected and Purposes of Collection and Use. The list below summarizes the personal information we collect, or have collected in the 12 months preceding the last updated date of this Privacy Policy, by reference to the categories specified in the CCPA. Examples in the list refer to the types of personal information described in the section titled “COLLECTION OF PERSONAL INFORMATION.” 

• Identifiers, such as Contact Information. 
• Customer Records, such as Account Information, Payment Information, Marketing Preferences, and Communications.
• Commercial Information, such as Order History and Survey Responses.
• Internet or Network Activity, such as Device Information and Online Activity Information.
• Audio, Electronic, Visual, or Similar Information, such as recorded calls and chats.
• Professional Information, such as company details or job title.
• Inferences, such as inferences drawn from the personal information identified above to create a profile reflecting your preferences, characteristics, or behavior.

We may collect these categories of personal information as described in the section titled “COLLECTION OF PERSONAL INFORMATION.”

The purposes, including the specific business and commercial purposes, for which we collect and use these categories of personal information are described in the section titled “USE OF PERSONAL INFORMATION.” 

To the extent that we may collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to provide the Platform or our products and services, detect security incidences and prevent fraud, and to verify and maintain the quality of the Platform and our products and services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.

Personal Information Disclosed for a Business Purpose, “Sold,” or “Shared.” Each of the categories of personal information listed above may have been disclosed for business purposes in the preceding 12 months to any of the third parties set forth in this Privacy Policy under the section titled “DISCLOSURE OF PERSONAL INFORMATION.” 

The CCPA defines a “sale” of personal information to mean when a business discloses a California resident’s personal information to a third party for monetary or other valuable consideration. Where a business discloses personal information for purposes of cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as “sharing” under the CCPA. 

In the 12 months preceding the last updated date of this Privacy Policy, we have “sold” or “shared” Internet or Network Activity to our Advertising Partners for purposes of advertising our Platform (including tracking the success of our advertising campaigns) and measuring activity on the Platform as further described in this Privacy Policy under the section titled “Interest-Based Advertising.” We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.

Your California Privacy Rights. As a California resident, in addition to the choices described elsewhere in this Privacy Policy, you have the rights listed below. Please note, these rights are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

• Right to Know/Access. You can request the following information about how we have collected and used your personal information:
  • The specific pieces of personal information we have collected about you; 
  • The categories of personal information we have collected about you; 
  • The categories of sources from which the personal information is collected; 
  • The categories of personal information that we sold or disclosed for a business purpose about you;
  • The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and 
  • the business or commercial purpose for collecting or selling personal information.  
• Right to Delete. You can request that we delete the personal information we collected from you.
• Right to Correct. You can request that we correct inaccurate personal information that we maintain about you.
• Right to Opt-Out of Sales/Sharing. If we “sell” or “share” your personal information, you can opt-out. 
• Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment. 

How to Exercise Your Rights. You may exercise the rights described above as follows:

• Know/Access, Delete, or Correct. You may exercise these California privacy rights by emailing us at privacy@thegoldensource.com . 
• Opt-Out of Sales/Sharing. We use certain advertising cookies on the Site that may constitute the “sale” or “sharing” of your personal information when they collect information about you and your visit. To opt-out, please click the link at the bottom of the Site titled “Your Privacy Choices” and turn off Advertisement cookies. You can also broadcast the Global Privacy Control (GPC) signal when visiting the Site. Note that due to technological limitations, if you visit our Site from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to the Site to select your preferences or rebroadcast the GPC signal.

If you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your right to know/access, delete, and correct. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it. The identity verification process may vary depending on how you submit your request. 

Consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, where permitted by law, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights).  However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

We try to respond to all legitimate requests to know/access, delete, and correct within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit your request us using the contact information listed at the end of this Privacy Policy with “Nevada Opt-Out Request” in the subject line.

The information provided in this section applies only to individuals in the European Economic Area, the United Kingdom, and Switzerland (for purposes of this Privacy Policy, collectively, “Europe”). Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is GoldenSource, 115 Broadway, 13th Floor, New York, NY 10006, United States.

Legal Bases for Processing. The legal basis of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us using the contact information included below.

Use for New Purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Your Rights. European data protection laws may provide you with certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Port. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information in certain scenarios required by European data protection laws.
• Portability. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by contacting us using the contact information at the end of this Privacy Policy. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.

Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us using the information at the end of this Privacy Policy for further information about any such transfers or the specific safeguards applied.

If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at privacy@goldensource.com.