Privacy Policy

Updated: December 14, 2022

Ginni Rometty (“Ginni Rometty,” “we,” “us,” or “our”) recognizes the importance of protecting the privacy of the information we may receive from anyone who accesses our website (“Users,” “you,” or “your”) located at (the “Site”). This privacy policy (this “Privacy Policy”) describes the information we collect from Users, how we may use and with whom we may share that information, the safeguards we use to protect such information and the choices you may make with respect to your information. Your access to and use of the Site is subject to this Privacy Policy and our Terms.

1. Information We Collect

You may visit the Site without revealing your identity or volunteering any personally identifiable information (“PII”). Please be aware that we may automatically collect certain information about Users, including the IP address of your computer, browser type, date and time of your visit, how long you visited certain pages on the Site, the page, service or product you are requesting, and other aggregate or de-identified data (“Aggregate Information”). If you choose to contact us, request information, inquire about a service or product or subscribe to any promotional materials, we may collect PII from you, such as your email address, and this information may be combined to provide you with information and services you request. In order to receive information from the Site, you may be required to provide us with certain information, including, for example, your email address. Failure to provide such data may make it impossible for us to provide you with information.

2. Cookies

The Site may deploy cookies in order to collect certain aggregate data about our users and to customize certain aspects of your specific user experience. A cookie is a small data text file which is stored on your computer that uniquely identifies your browser. Cookies may also include more personalized information, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and your first name to welcome you back to our Site. We may use cookies to perform tasks such as: monitoring aggregate site usage metrics, storing and remembering your passwords (if you allow us to do so), storing account and advertising preferences that you have set, and personalizing the services we make available to you. We may use first-party cookies and allow third parties to use our cookies for their own purposes. Some cookies may be placed on your device by a third party and provide information to us and third parties about your browsing habits. We do not control third-party cookies. Most web browsers allow control of cookies through the browser settings, which will enable you to accept or reject a cookie. If you do not accept cookies, certain elements of the Site may not function correctly or completely.

3. Use of Information We Collect

We may use PII and Aggregate Information (collectively, “User Data”) for various purposes, including the following (collectively, “Our Purposes”):

  • administering and enabling use of the Site, including, but not limited to, communications with Users at the email, physical addresses or phone number provided by such Users;
  • ensuring all Users follow our Terms and other rules and policies, and investigating cases of suspected abuse or fraud;
  • banning a User temporarily or permanently for failure to follow our Terms, rules or policies, or for other misconduct or inappropriate behavior;
  • enabling Users to receive newsletters, updates, and other materials related to us;
  • tracking and analyzing User behavior, monitoring, analyzing and performing the technical administration of the Site, and improving the functionality, design and quality of the Site; and
  • any other purpose that we determine at our discretion is related to the use, advertising, marketing, promotion or other of our, or the Site’s legitimate purposes.

By accessing the Site, you expressly consent and agree that we may use your User Data for Our Purposes in accordance with this Privacy Policy. We may retain User Data for the period necessary to fulfill Our Purposes, or longer if necessary to comply with our legal obligations, resolve disputes, or as is otherwise permitted or required by applicable law, rule or regulation.

4. Do Not Track Disclosure

You can set your browser to a Do Not Track (“DNT”) setting, to notify websites you browse that you do not want them to collect and/or track your personal information. Please be advised that in some cases the Site does not respond to the DNT browser setting. If you do not want us to track your PII and other personal data, please do not share your PII with us. Please also be advised that third-party websites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

5. Disclosure of Personal Information

We may share your User Data with our vendors, third-party service providers and agents in connection with Our Purposes. These third parties include web analytics service providers such as Google Analytics. We will provide these companies only with the information they need to deliver the services we have requested, and they are prohibited from using that information for any other purpose. We may also share PII when we believe it is necessary to maintain the security of the Site or our products and services, or to otherwise protect us, our business or our Users, for example to enforce our Terms, prevent spam or other unwanted communications and investigate or protect against fraud.

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may, without providing notice to you, disclose any User Data to government or law enforcement officials or private parties (i) where we are required to do so by law, including, but not limited to, in response to a court order or subpoena, or (ii) in response to a request by a government or law enforcement agency or if we believe such disclosure may prevent or mitigate the threat of crime or harm to Users or others, facilitate an investigation related to a User’s safety or public safety, protect the security or integrity of the Site, or enable us to take precautions against liability.

We may also share User Data with third parties when you give us consent to do so. Processing of the data collected through the Site is conducted following organizational procedures related to Our Purposes. We may employ third parties to facilitate the operation of the Site and to perform services related to administration of the Site, including, but not limited to, maintenance, hosting, security and database management services, web analytics and administration and legal services. These third parties may have access to User Data to perform these tasks on our behalf. We may share Aggregate Information, and reports based on Aggregate Information, with third parties for industry analysis, demographic profiling, other commercial purposes, or to deliver targeted advertising about other products and services.

In connection with a sale of all or part of our operations, or sale or transfer of assets, or a merger, reorganization, or in the event of bankruptcy, we may transfer User Data to a third party as part of the transaction, to the extent permitted by applicable law.

6. Notice to California Residents – Your California Privacy Rights

If you are a California resident, you have the right to request one Notice of Information-Sharing Disclosure per year which will identify the third parties with whom we or any of our affiliates has shared the personal information we have collected from you. You may request the Notice of Information-Sharing Disclosure by writing to us by email or mail as set forth in Section 12, and we will respond to your request within 60 days.

7. Your Privacy Choices; Opt Out

If a User becomes aware that personal information we maintain about them is inaccurate, incomplete, misleading, irrelevant or out of date, or if an individual would like to access, update or review their information, the individual is solely responsible for updating such information, and may do so by contacting us using the contact information below. We will attempt to provide the requested information or make requested changes to the extent allowable by applicable privacy laws. You may request the removal of previously provided personal information at any time. The deletion of such data, however, may affect our ability to provide you with our services or products. We reserve the right to verify the identity of any person making an opt-out or correct/update request but shall have no liability whatsoever resulting from false or erroneous requests. You may update your personal information, communications preferences, or opt out from receiving promotional materials at any time by contacting us. Please note that it may take time to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make a request.

8. Security

Please note that any information you share with us via email or the internet is not completely secure. We take reasonable steps to protect personal information provided via the Site from loss, misuse and unauthorized access or disclosure, however, no internet or email transmission is ever fully secure or error-free. Due to the nature of the internet, there is a possibility that unsecured email or internet transmissions may be intercepted and read by third parties. We assume no responsibility for interception of confidential or personal information that you send in any unsecured email message or other internet transmission to or from the Site. Therefore, you should take special care in deciding what information you send to us via the Site, email or other internet transmission. YOU ACKNOWLEDGE AND AGREE THAT DESPITE OUR EFFORTS, THERE MAY BE TIMES OR SITUATIONS WHEN YOUR PII IS INADVERTENTLY DISCLOSED BY US OR BY A THIRD PARTY TO WHOM WE HAVE DISCLOSED YOUR PII. YOU HEREBY ACCEPT THAT RISK AND WAIVE ANY AND ALL CLAIMS, CAUSES OF ACTION, DAMAGES AND LIABILITY AGAINST US IN THE EVENT OF SUCH INADVERTENT OR NEGLIGENT DISCLOSURE OF PII.

9. Links to Third-Party Sites

This Privacy Policy applies only to the Site. The Site may at times link to websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy policies of such other websites or how these websites operate or treat your User Data. In no event shall we be responsible for the information contained in such links or websites, their practices or for your use of, or inability to use, such links or websites or their services, or transmissions received from such websites. By using the Site, you expressly release and discharge us from any and all liability arising from your use of any third-party website. We encourage you to read the privacy policies and terms of use associated with any third-party websites that may collect User Data.

10. Cross-Border Transfers

The Site is intended for use by persons located in the United States. If you visit the Site from a country other than the United States, your communications may result in the transfer of your PII across national borders. Our servers or offices may be located in countries other than the country from which you access the Site, also resulting in the transfer of your PII across international borders. If you provide PII when visiting the Site from outside of the United States, you acknowledge and agree that this data may be transferred from your then-current location to our offices and servers and to those of our affiliates, agents, and service providers located in the United States and in other countries. The United States and such other countries may not have the same level of data protection as those that apply in the jurisdiction where you live.

11. Updates to this Privacy Policy

Ginni Rometty shall have the right, in its sole discretion, to revise this Privacy Policy at any time and without additional notice to you. Such revised Privacy Policy shall be effective when posted on the Site. You should revisit this Privacy Policy on a regular basis, as revised versions will be binding upon you. You understand and agree that your continued access to or use of the Site after the effective date of changes to this Privacy Policy indicates your acceptance of such revisions.

12. Contact Us

If you have any questions about this Privacy Policy or require assistance in managing your privacy choices, please contact us at: [email protected]