Privacy Policy

Data Protection
Purposes and legal basis for processing
We process personal data on the following legal bases, in accordance with Article 6 of the European Union's General Data Protection Regulation 2016/679: (1) with your consent; (2) as necessary to perform our agreement to provide Services to you; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy.
Individual Rights
You have the following rights under Chapter 3 of the GDPR. To make a request or otherwise exercise your rights, please follow the procedure described on the FAQ page.
• The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
• The right of access; this is your right to see what data is held about you by a Data Controller.
• The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
• The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
• The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
• The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
• The right to object; the Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
• Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.

The personal data that we collect
From SEC Filings
Information that has been filed with the Securities and Exchange Commission, and has been disseminated or made publicly available by them, is public information, since one of their organizational functions is to mandate “full disclosure” within the securities markets that they regulate. We process and re-publish this public information, which may contain all categories of “personally identifiable information” as originally disclosed by Filers and the SEC pursuant to Federal securities law. If there is anything that you consider “private” on our site which you want removed, such as a Social Security Number, see our FAQ page for instructions on how to request redactions.
From users of our Services
Device information - such as your hardware model, Internet Protocol (IP) address, other unique device identifiers, operating system version, browser type and settings, such as language and available font settings, and settings of the device you use to access the Services.
Usage information - such as information about the Services you use, the time and duration of your use of the Services and other information about your interaction with content offered through a Service, and any information stored using cookies, mobile ad identifiers, and similar technologies that we have set on your device. For detailed information about our use of cookies, web beacons, and other technologies, see the Online Tracking and Advertising section below.
Location information - such as your computer’s IP address, your mobile device’s GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain Services.
From third parties
We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you.

How we use information
To Deliver Targeted Advertising
We may use your information to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and advertisers, on and off the Services. Please see the Online Tracking and Advertising section for further information about our and third parties’ use of cookies, web beacons, mobile ad identifiers, and other tracking technologies to provide you relevant ads, as well as information about how to disable cookies and make other choices related to targeted advertising.
To Better Understand Our Users
The Services conduct research on our users’ demographics, interests and behavior based on the information we collect. We do this to better understand and serve our users, and to improve our services.
To Protect the Rights of the Services and others
We may use your personal information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, its employees or agents, or other users and to comply with applicable law.

Sharing of Information
Third Parties that Provide Content, Advertising, or Functionality
When you use our Services, third parties may collect or receive certain information about you and/or your use of the Services (e.g., hashed data, click stream information, browser type, time and date, information about your interactions with advertisements and other content), including through the use of cookies, beacons, mobile ad identifiers, and similar technologies, in order to provide content, advertising, or functionality or to measure and analyze ad performance, on our Services or other websites or platforms. This information may be combined with information collected across different websites, online services, and other linked or associated devices. These third parties may use your information to improve their own services and consistent with their own privacy policies.
Site Operations and Analytics
We use Google Analytics third-party partner to enable features that are necessary for providing you the services on our site and to allow us to understand how our services are being used, track site performance, and improve our services. To learn more about your rights with respect to Google Analytics, including any opt-out rights, you can review its respective privacy policies at policies.google.com/privacy.
Advertising
We use Google Adsense third party to deliver advertising, including personalized advertising based on your preferences or interests across services and devices, and to measure and analyze the effectiveness of ads, on our platforms or elsewhere. To learn more about its use of data and to opt out from data use, visit policies.google.com/technologies/partner-sites
Embedded Content and Links to Third-Party Sites and Services
Our Services may embed content from, or link to, third-party websites and services, including social media platforms, that are outside of our control. We are not responsible for the security or privacy of any information collected by other websites or other services. This Privacy Policy does not govern these third party’s content or services, and we encourage you to review the privacy statements applicable to the third-party websites and services you use.
International Transfers
Information that we obtain as a result of your use of the Services is collected, processed and stored in the European Union and is not transferred internationally, in accordance with the General Data Protection Regulation 2016/679. Information obtained by our third-party partner Google Inc through its Analytics and AdSense/DoubleClick cookies is collected, processed and stored in the United States.

Online Tracking and Advertising
We and third parties that provide content, advertising, or functionality or measure and analyze ad performance on our Services, may use cookies, web beacons, mobile ad identifiers, and similar technologies to facilitate administration and navigation on the Site, to better understand and improve our Services, to determine and/or improve the advertising shown to you here or elsewhere, and to provide you with a customized online experience.
Cookies
Cookies are small files that are placed on your computer when you visit a website. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes. For example:
• Cookies can remember your sign-in credentials so you do not have to enter those credentials each time you visit a Service;
• Cookies can help us and third parties understand which parts of our Services are the most popular because they help us see which pages and features visitors access and how much time they spend on the pages. By studying this kind of information, we are better able to adapt our Services and provide you with a better experience;
• Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you access a Service.
Most browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. If you disable browser cookies or flash cookies, it may interfere with the proper functioning of the Services.
The Cookies We Set - Site preferences cookies
In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.
Third Party Cookies
This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.
The Google AdSense service we use to serve advertising uses a DoubleClick cookie to serve more relevant ads across the web and limit the number of times that a given ad is shown to you.
We use adverts to offset the costs of running this site and provide funding for further development. The behavioural advertising cookies used by this site are designed to ensure that we provide you with the most relevant adverts where possible by anonymously tracking your interests and presenting similar things that may be of interest.
Beacons
We, along with third parties, also may use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and third parties use beacons for a variety of purposes, including to analyze the use of our Services and (in conjunction with cookies) to provide content and ads that are more relevant to you.
Local Storage & Other Tracking Technologies
We, along with third parties, may use other kinds of technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage, in connection with our Services. We also may use unique identifiers associated with your device, such as mobile ad identifiers. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings. For HTML5 local storage, the method for disabling HTML5 will vary depending on your browser. For Flash cookies, information about disabling or deleting information contained in Flash cookies can be found here.
Additional Choices With Respect To Targeted Advertising
As described above, we and third parties may use cookies and other tracking technologies to facilitate serving relevant ads to you. For example, these technologies help us determine whether you have seen a particular advertisement before, tailor ads to you if you have visited our site before, and avoid sending you duplicate advertisements. You can learn more about certain types of targeted advertising by visiting the Digital Advertising Alliance website or our Ad Choices section below.
In addition to disabling cookies and other tracking technologies as described above, you may opt-out of receiving targeted advertising from participating ad networks, audience segment providers, ad serving vendors, and other service providers by visiting websites operated by the Network Advertising Initiative and Digital Advertising Alliance.
Due to differences between using apps and websites on mobile devices, you may need to take additional steps to disable tracking technologies in mobile apps. Many mobile devices allow you to opt-out of targeted advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our apps using the standard uninstall process available on your mobile device or app marketplace.
Ad Choices - How to opt out of advertising cookies
• Online advertising for IncJournal.com is delivered by the vendor DoubleClick. DoubleClick places cookies on your browser to facilitate serving particular ads – for instance, to help determine whether you have seen a particular advertisement before, to tailor ads to you if you have visited our site before, and to avoid sending you duplicate advertisements. You can opt out of DoubleClick’s use of cookies for these purposes by visiting google.com/intl/en/privacy/.
• In some cases, we and advertisers on IncJournal.com and other sites work with other third-party vendors to help deliver advertisements tailored to your interests. These vendors include ad networks and audience segment providers, and they use cookies, beacons, mobile ad identifiers, and similar technologies to collect information about your online activity (e.g., the sites and pages you have visited and mobile apps you use) in order to help advertisers deliver particular ads on our site and other sites that they believe you would find most relevant. You can opt out of those vendors’ use of cookies to tailor advertising to you by visiting aboutads.info.
If you wish to disable cookies, you may do so through your individual browser options. More detailed information about cookie management with specific web browsers can be found at the browsers' respective websites.
Due to differences between using apps and websites on mobile devices, you may need to take additional steps to disable tracking technologies in mobile apps. Many mobile devices allow you to opt-out of targeted advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our apps using the standard uninstall process available on your mobile device or app marketplace.
• Often our advertisers contract with a third-party service to host their ads. In this case, an ad serving vendor contacts the advertisers’ hosting service for a particular advertisement. In that case, an independent cookie may be used by the third-party service. We do not have a mechanism to allow visitors to opt-out of cookies from vendors with whom we do not have a contractual relationship.
Log Files
IncJournal.com records certain traffic data in log files. The information inside the log files includes type of browser, Internet Protocol (IP) address, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and number of clicks to analyze trends, administer the site, track user's movement around the site, and gather demographic information. The data that we record cannot identify you personally.

Data change policy
Corrections
If you request a correction to your Registrant information (as a Filer, Issuer or Filing Agent), such as your name / address / phone number, or some Filing-specific piece of information (in the Submission data), you should contact us by registered mail or e-mail.
Deletions
We don't do full filing deletions.
Redactions
In compliance with the EU's General Data Protection Regulation 2016/679, this is our change-request process. We will only delete your personal data (such as name, address, phone number or Social Security Number), not entire filings.
Social Security Numbers (SSNs)
SEC Filings (meaning their contents, including SSNs) are filed pursuant to Federal securities law in effect when the Filings are made. SEC Filers have been making such “full disclosure” Filings per SEC Rules & Regulations since 1933. Until June 2007, the disclosure of SSNs has been mandated (see “S.S. or I.R.S. Identification No.” in a ‘Schedule 13G’), encouraged (see “IRS Ident. No.” in a ‘Form 144’), voluntary (see “Social Security Number... (Voluntary)” in a ‘Form 3’) or allowed (see “Tax Identification #” in a ‘Proxy Statement’). In June 2007 the SEC changed its policy and SSNs in Filings made after that time were and are now automatically redacted by the SEC, but only if they are formatted in the hyphenated 3-2-4 style (###–##–####) and not as just nine digits. Because the SEC only dealt with that 3-2-4 format (and did so erroneously as a quick fix, since fewer than 22% of any “numbers” in that format are indeed SSNs), there remain many thousands of SSNs on the SEC’s site that have yet to be redacted. But even when any are redacted on the SEC’s site, there is no way to communicate these changes via the EDGAR Dissemination System. So, if you have found an SSN on our site, it is because the SEC Form or Document/Exhibit that was filed before June 2007 either required or allowed the disclosure of the SSN at the time it was filed, pursuant to Federal securities law as implemented by the SEC and adhered to by the Filer. Although some States have passed laws with respect to SSNs, those laws always defer to Federal law so that there is no conflict. To quote California Civil Law as an example, it “... does not prevent the collection, use, or release of a social security number as required by state or federal law...”. Our site therefore renders SEC Filings exactly as they were filed, in conformance with over-riding Federal law and the original intent of the Filer. Please understand that we have no way of knowing that an SSN is on our site unless you tell us. Any nine-digit number on our site could actually be a CUSIP Issue Number, US IRS TIN (EIN, SSN or ITIN), Canadian CRA SIN, SEC File Number, US UCC-1 Loan Number and/or an international phone number (just some of the many interpretations we know of), and there are no validity-checking algorithms anywhere that can be used automatically to guarantee a distinct and therefore correct interpretation of it. For example, if you search for the number 594-91-8104 which exists on our site, the various validity-checking algorithms say it is equally valid as a possible CUSIP Issue Number (for an equity security), US IRS EIN (assigned in Brookhaven, NY), US IRS SSN (assigned randomly), Canadian CRA SIN (assigned in Ontario) and US UCC-1 Loan Number. Our site contains more than 60 million numbers that individually pass multiple validity checks like that, and over 1.2 million numbers that pass all interpretations we check for. Further complicating things, a sole proprietor with employees could disclose an SSN as an EIN. So, it is impossible for us or anyone to know if any nine-digit number is an SSN.

Data security
IncJournal uses reasonable measures to safeguard personally identifiable information from loss, theft, misuse, alteration and unauthorized access or destruction. In addition, we maintain appropriate physical, electronic, and procedural safeguards to protect your personal data, including:
• Restricting access to personal data to our service providers on a “need to know” basis;
• Enforcing policies and procedures for handling of personal data;
• Using technologies designed to safeguard data during its transmission, such as SSL encryption, and using appropriate security to safeguard the data that we have received.
IncJournal also employs industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our systems.
However, as effective as these measures are, no security system is impenetrable. There is no method of transmission over the Internet, or method of electronic storage that can be 100% secure. Therefore, IncJournal cannot guarantee the absolute security of your information, nor can we guarantee that your information will not be intercepted while being transmitted to us over the Internet. The Internet by its nature is a public forum, and we encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your username and password from third party access, and for selecting passwords that are secure.

Changes to our Privacy Policy
We may modify this Privacy Policy from time to time. We will notify you of changes by posting changes here. Any changes to the Privacy Policy will become effective when the updated policy is posted here. Your use of IncJournal.com following such changes indicates your acceptance of the revised Privacy Policy.

If you require more information or have any questions about our privacy policy, please feel free to contact us by email at [email protected].




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