Last Revised: April 18, 2018
I. What Information We Collect From You
A. Information You Voluntarily Provide
We will collect information that identifies you (“Personal Information”) when you voluntarily provide such information to us through our Website. If you choose to provide us with Personal Information, you consent to the transfer and storage of that information on our servers.
B. Cookies and other Information Collected through Technology
You should be aware that in some cases, your computer needs to accept cookies from a website to take full advantage of its services. This is especially true on sites that require a user ID or a password. In order to provide better service, Menlo may use “cookies” in connection with the Website. Cookies are small files that your web browser places on your computer’s hard drive.
We do not track our users across third party websites and thus our Website does not respond to the Do Not Track (“DNT”) settings in your web browsers. However, some third party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, certain website browsers allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.
II. How We Use Your Information That We Collect Online
A. To Provide Information and Services
We use the information that we collect from you to provide you with the information and services offered through our Website, to support and enhance your use of our Website, to monitor which features of the Website are used most and to allow us to determine which features of the Website we need to focus on improving.
We may also use non-Personal Information collected from users of the Website in the aggregate, so that we can improve our Website and for business and administrative purposes.
B. Diagnose Website Problems
Menlo may use your Internet Protocol (IP) address and other non-Personal Information to help diagnose problems with our computer server, and to administer the Website. Your IP address is also used to gather broad demographic data. It is not stored or linked to your personal profile information, such as name or contact information.
III. Disclosure of Your Information to Third Parties
A. To Provide Services
We will not give, sell, rent, loan or otherwise disclose any of your Personal Information to any third party, unless (1) you have specifically authorized us to do so, (2) we are legally required to do so, for example, in response to a governmental subpoena, court order or other legal process, (3) it is necessary to do so in order to protect and defend our or a third party’s rights or property, or to protect the safety of the public or any person or (4) pursuant to a business transfer as discussed in Section.
B. Third Party Service Providers
C. Business Transfer
D. Law Enforcement
Menlo cooperates with public authorities, government and law enforcement officials, and governmental agencies to enforce and comply with the law. We will disclose any information about you to public authorities, government or law enforcement officials, or governmental agencies as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas and lawful government requests), to protect the property and rights of Menlo or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical or legally actionable activity.
E. Aggregated or De-Identified Information
Menlo may share aggregated and/or de-identified data collected from users of the Website (i.e., data that is not Personal Information) with third parties for various business purposes including product and service development and improvement activities related to our services.
IV. How We Secure Your Information
We have procedures that limit Menlo’s employees and contractors’ access to Personal Information. Only those employees and contractors with a business reason to know have access to such information. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, mandatory training programs, and internal policies on data privacy and corporate integrity. We take appropriate disciplinary measures to enforce employee privacy responsibilities.
Please bear in mind, however, that no Internet transmission is ever 100% secure or error-free. More specifically, information transmitted to or from the Services may not be via a secure connection. As a result, you should take particular care in deciding what information you send via our Website.
We will retain your Personal Information as long as necessary to provide you the services offered there through and the other permitted uses specified in Section II above, and for a reasonable transition time thereafter. We may store aggregated and anonymized information (i.e., information that is not Personal Information) indefinitely.
V. About Minors
Our Services are not directed at or intended for use by minors. Therefore, we do not wish to receive, nor do we knowingly collect, Personal Information from minors via our Website. No one under age 13 may provide any Personal Information to Menlo on or through our Website. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
VI. Transfer Across Jurisdictions
We are a US-based company so the Personal Information that we collect from you may be transferred to, and stored at, a destination outside of your country and the European Economic Area (“EEA”) and, in particular, the United States, which may have different or less protective privacy laws than those in your country. Personal Information may also be processed by any service providers appointed by us who operate outside the EEA and their staff, and/or our own staff based outside of the EEA. By using our Website and providing Personal Information to us, you consent to such transfer to, and processing in, the United States.
VII. Links to Other Sites
VIII. Access, Deletion and Opt-Out Rights
You have the right to access, correct or delete Personal Information held about you by Menlo. To the extent allowed, any requests to exercise such rights may be subject to a small fee to meet our costs in providing you with details of the Personal Information we hold about you. Should you wish to access the Personal Information held about you, please let us know by contacting us at the contact information provided below.
You may also request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes or choose to opt out of such disclosure. Our policy is not to disclose Personal Information collected online to a third party for direct marketing without your approval. To make a request or to opt out at any time, please contact us at the contact information provided below.
IX. Your Consent
X. How to Contact Us
2765 Sand Hill Road, Suite 200
Menlo Park, CA 94025
Telephone: (650) 326-9300