Privacy Policy

InspiraGen Institute’s Privacy Policy

Effective: January 2, 2024

 This Privacy Policy explains how InspiraGen Institute (“InspiraGen Institute,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes information about you related to your access or use of gocomics.com, andrewsmcmeel.com, amuniversal.com, universaluclick.com, uclickgames.com, thepuzzlesociety.com, upuzzles.com, uexpress.com, infinitecrosswords.com, doonesbury.com, missmanners.com, ampkids.com, and amberlotus.com, and other sites or applications, including mobile applications, owned and operated by InspiraGen Institute (each individually a “Site” and collectively the ”Sites”). InspiraGen Institute does not intend to collect any personal information from children under 16 unless such collection is permitted by law. Your use of the Sites, including any dispute concerning privacy, is subject to this Privacy Policy and InspiraGen Institute’s Terms and Conditions of Use and any other policies on the applicable Site (collectively the “Terms”). We reserve the right to modify this Privacy Policy at any time.  If we make changes to this policy, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).

1. WHAT DOES THIS PRIVACY POLICY COVER?

This policy covers the treatment and use of information that is collected by InspiraGen Institute through your use of the Sites.

This policy does not cover information that may or may not be collected by companies or websites that InspiraGen Institute does not own or control. This policy also does not guide or control the behavior of individuals not employed by InspiraGen Institute. For some Sites, products and services, third parties may host the Site or portions of the Site and collect order information, contact information and necessary financial information to process orders or subscriptions related to such products and services. Please see the privacy policies and terms of conditions on such websites for more information about how your information is protected or shared on such websites. Any information that is received by InspiraGen Institute from such websites shall be treated in accordance with this Privacy Policy.

2. WHAT INFORMATION IS COLLECTED?

Our Sites collect various information about you, including information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. In particular, the Sites may have collected the following categories of information from consumers within the last 12 months:

Category	Examples
(A) Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
(B) Personally identifiable information	A name, signature, address, year or month of birth, household information, telephone number, email address, credit card number, debit card number, or any other financial information. Some information included in this category may overlap with other categories.
(C) Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
(D) Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
(E) Geolocation data	Physical location or movements.
(F) Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

InspiraGen Institute does not collect information that consists of:

1. Sensitive personal information such as social security numbers, driver’s license numbers, bank account numbers, or other similar information.
2. Protected classification characteristics such as race, color, ancestry, national origin, or similar immutable characteristics.
3. Biometric information such as genetic, physiological, behavioral, and biological characteristics.
4. Sensory data such as audio, electronic, visual, thermal, olfactory, or similar information.
5. Professional or employment-related information from consumers other than applicants, employees, business owners, directors, officers, medical staff, or contractors of InspiraGen Institute.
6. Non-public education information.

InspiraGen Institute obtains the categories of information listed in the table above from the following categories of sources:

1. Directly from you. For example, from forms you complete or products and services you purchase.
2. Indirectly from you. For example, from observing your actions on our Sites.
3. Social media companies when you link your account to our Sites.

Please note that your personal information does not include (A) publicly available information from government records or (B) deidentified or aggregated consumer information.

3. HOW IS MY INFORMATION COLLECTED?

We collect certain information when you register or provide us your information on the Sites. We may ask you to register and/or provide information when you visit certain areas of our Sites, register for services, order products, enter contests, subscribe to a newsletter, or other communication. If you choose not to register, you may not have access to areas that require registration. We may receive information, including information about you from other sources, such as publicly available sources, if you log in through social media platforms or other third-party data providers, such as analytics, audience identification, and demographics providers, and combine that with information we receive from you.

The Sites, and any messages sent from InspiraGen Institute, may contain code that enables our database and servers to better understand how you use the Sites, including whether a message was opened and/or what links (if any) were clicked. We may combine that information with other information we have about you and may use that information to improve your experience and/or provide customized messages to you.  InspiraGen Institute may also use other technologies to verify and track your use of certain products and services, confirm receipt of certain products or to test the integrity of our systems, products and services. We use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Sites and your experience, see which areas and features of our Sites are popular, and count visits. Web beacons are electronic images that may be used on our Sites or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. Your browser has options to accept, reject, or provide you with notice when a cookie is sent. Please be aware that disabling or revoking consent to the use of cookies may impact your ability to fully utilize the Sites. Please see the section below entitled “Cookies, Advertisements, and Third-Party Websites” for more information about how to opt out of cookies on the Sites.

If you use a device with Global Positioning System (“GPS”) or other location detection functionality, then we may collect precise information about the location of your device during your use of the Sites.

4. HOW IS MY INFORMATION USED BY INSPIRAGEN INSTITUTE?

InspiraGen Institute may use, sell, or disclose information we collect for one or more of the following purposes:

1. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information or ask a question about our products or services, we will use that information to respond to your inquiry. If you provide your information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders;
2. To process purchases, transactions, and payments;
3. To attempt to detect and reduce fraud, credit risk, and other illegal activities or threats to the safety, security, or integrity of the Sites;
4. To provide, support, personalize, and develop our Sites, products, and services;
5. To personalize your experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Sites, third-party sites, and via email or text message (with your consent, where required by law);
6. To provide a seamless experience across multiple devices, platforms or browsers for each user;
7. To create, maintain, customize, and secure your account with us as well as provide certain premium content services or products subject to a subscription agreement or registration;
8. To send periodic messages, via mobile, twitter, email, or other platforms, with content updates, subscription information, and order information;
9. To offer special contests or promotions that are sponsored by InspiraGen Institute or another company;
10. To operate chat, bulletin board, or other user-generated content functionality. Any posting by you is considered public information available to other users and is governed by the Terms;
11. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
12. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of InspiraGen Institute’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by InspiraGen Institute about our Sites’ users is among the assets transferred; and
13. To fulfill or complete any other purpose or function described to you when collecting your information.

5. WHO DOES INSPIRAGEN INSTITUTE SHARE INFORMATION WITH?

No one outside of our company and affiliate Sites’.

6. WHAT ARE MY OPTIONS TO CONTROL THE USE OF MY INFORMATION?

We will not discriminate against you for exercising any of the rights provided below.

Personal Information Sales Opt-Out

You have the right to direct us to not sell your personal information at any time. We do not sell the personal information of consumers who we know are less than 16 years of age, unless we receive affirmative authorization from either the consumer (if 13-16 years of age) or the parent or guardian (if under 13 years of age). Consumers who opt-in to personal information sales may opt-out of future sales at any time. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by email to support@tyhoward.com.

Promotional Communications Opt-Out

We may email you with information about other products and services of InspiraGen Institute, including information about selected third parties. If you do not want to receive such promotional communications from InspiraGen Institute, you may decline to receive those email messages by opting out when you receive such a communication, sign-up, register, or from within your account, as applicable. However, we may still communicate with you by email if such email communication is for the purpose of corresponding with you regarding products or services you have requested, related to protecting your interests, including any information, property, or other data, or to provide you with any notification or disclosure that may be required by applicable law or this Privacy Policy. Accordingly, you agree that all communications, disclosures, and notices sent to you by email satisfy any requirement that notice be provided in writing.

Location Sharing Opt-Out

You may opt-out of allowing us to have any access to your precise location data by disabling your device’s location detection functionality or GPS or, if possible, on your device, disabling permission for our Sites to access such location detection functionality or GPS.

Access to Specific Information and Data Portability Rights

If you are a California resident, you may request that InspiraGen Institute disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will, to the extent required by applicable law, disclose specific information about what information we have collected, the sources we collected information from, our business purpose in collecting information, who we shared information with, the specific pieces of information we collected about you (also called a data portability request), and any sales or disclosures for a business purpose of your information.

Deletion Request Rights

If you are a California resident, you may request that InspiraGen Institute delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is permitted under applicable law. You should also be aware that deleting certain information may impact your ability to receive certain services from InspiraGen Institute including newsletters, accounts, subscriptions, etc.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above as permitted under state law, please submit a verifiable consumer request to us by:

Calling us at 443-982-7582.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (A) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (B) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days. If we require more time, we will inform you of the reason and extension period in writing. If applicable, any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.  We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

7. TRANSFER OF INFORMATION TO THE UNITED STATES

The Sites are based in the United States, and are directed to U.S. residents, and we process and store information in the U.S. If you are located outside the U.S., we and our service providers may transfer your information to, or store or access to your information in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

8. CHILDREN’S PERSONAL INFORMATION

The Sites are general audience sites and are not directed to children under the age of 13. InspiraGen Institute assumes products and services purchased by credit card are purchased by adults. InspiraGen Institute respects the privacy of parents and children and is committed to complying with the Children’s Online Privacy Protection Act (“COPPA”) and applicable state law. On those areas of the Sites that ask for age, InspiraGen Institute does not collect personal information from individuals who identify themselves as under the age of 16 except in those limited circumstances where InspiraGen Institute believes that such collection is permitted under COPPA and other applicable law.

If a parent believes that his or her child has submitted personal information to InspiraGen Institute, he or she can contact us via email or postal mail as listed below. InspiraGen Institute will promptly delete the information upon learning that it relates to a child under the age of 13.

9. INSPIRAGEN INSTITUTE’S DATA SECURITY DISCLAIMER.

We do not provide any guarantee or warranty by us that your information will not be accessed or compromised by third parties, or that we will use all available security technologies to prevent unauthorized access to, use, or disclosure of your personally identifying information; or that your information will be transmitted without unauthorized interception or modification.  We may permanently delete or destroy any and all information at any time as determined by us.

10. EUROPEAN UNION / GENERAL DATA PROTECTION REGULATION (“GDPR”)

If you are located within the European Economic Area (“EEA”) or within another jurisdiction having similar data protection laws to the GDPR, InspiraGen Institute provides such users the following rights:

1. the right to be told how we use your information and obtain access to your information;
2. the right to have your information rectified or erased or to place restrictions on processing your information;
3. the right to object to the processing of your information (e.g., for direct marketing purposes);
4. the right to have information you directly provided to us provided to you in a structured, commonly used, and machine-readable format;
5. wherein the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
6. the right to object to any decisions that have significant legal effect based on the automated processing of your information, including profiling; and
7. the right to lodge a complaint with the supervisory authority responsible for data protection matters.

If we hold any information about you that is incorrect, or if there are any changes to your details, please let us know so that we can keep our records accurate and up-to-date. If you withdraw your consent to the use of your information for purposes set out in our Privacy Policy, we may not be able to provide you with access to all or parts of the Sites. We will retain your information for the duration of our business relationship and afterward for as long as is necessary and relevant for our legitimate business purposes, in accordance with our data retention, marking and destruction policy, or as otherwise permitted by applicable laws and regulations.

Certain data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:

1. Consent: Wherein you have provided consent in accordance with applicable law to us using your personal information in a certain way, such as to send you email, text, and/or telephone marketing.
2. Performance of a contract: Wherein we are entering into a contract with you or performing our obligations under it, such as when you buy products and services through the Sites.
3. Legal obligation: Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority.
4. Legitimate interests: Wherein it is reasonably necessary to achieve our or others’ legitimate interests (as long as what the information is used for is fair and does not unduly impact your rights). We consider our legitimate interests to be operating the Sites and facilitating the services we provide to users. For example, to:

1. 
   
   1. understand how people choose/use our services and products;
   2. determine the effectiveness of our services, promotional campaigns, and advertising;
   3. monitor whom we deal with to protect against fraud, money laundering, and other risks;
   4. enhance, modify, personalize, or otherwise improve our services / communications for the benefit of our customers; and
   5. better understand how people interact with the Sites.

When we process your personal information in this way, we consider and balance any potential impact on you (both positive and negative) and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you.

Due to the nature and location of our business in the United States, your personal data will be disclosed to InspiraGen Institute and others as outlined herein outside of the EEA, including in the United States. It may also be processed by our employees or suppliers operating outside the EEA.

If you are in the EEA, we provide adequate protection for the transfer of your personal data to countries outside of the EEA through a series of intercompany agreements based on the Standard Contractual Clauses authorized under EU law or equivalent measures. A copy of the Standard Contractual Clauses is available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

11. HOW DO I UPDATE MY INFORMATION?

You can help InspiraGen Institute maintain the accuracy of your profile by notifying us when you change your address, phone number, email address, or other information. If at any time you wish to update your information then contact us or edit the information within your account, if applicable. Please include your old and new contact information in any message so that we can make the appropriate corrections.

12. COOKIES, ADVERTISEMENTS AND THIRD PARTY WEBSITES

The Sites may contain links to other websites. We are not responsible for the privacy practices or the content of such websites. We may allow third-party advertisers to place ads on the Sites. These third-party advertisers may use cookies or similar technologies to help present the advertisements to you or to help measure the effectiveness of their advertisements. Some advertisers may use cookies or other tracking technologies to serve ads based on your visits to the Sites and other websites on the Internet. The use of such technologies is subject to the privacy policies of the third-party advertisers and is not covered by this Privacy Policy. As a result, if you respond to any such third-party advertisers by clicking on the advertisements and/or visiting their websites or the websites of any other third party, be sure you evaluate their privacy policies before providing them with any of your information. To opt out of a third party’s use of cookies, you must visit such third party’s website and follow its specified opt-out procedures. For example, we use Google Ad Manager (DoubleClick) product on our Sites. You can learn more about Google, and how they use your data by visiting http://www.google.com/intl/en/policies/privacy/partners/. You may opt out of Google’s use of the DoubleClick cookie by visiting the Google Advertising Policies and Principles page at http://www.google.com/policies/privacy/ads/. In addition, we use Publisher First, Inc. dba Freestar (“Freestar”) for the purposes of placing certain advertising on the Sites, including collecting and using certain data around such advertisements and the pages such ads appear on. You can learn more about Freestar and their privacy policy at https://freestar.com/privacy-policy/ . You can also opt out of some, but not all, third-party advertiser cookies by visiting the Network Advertising Initiative opt-out website, located at https://thenai.org/opt-out/browser-opt-out/, or by visiting the Digital Advertising Alliance (DAA) at https://optout.aboutads.info/. You may block all cookies by following the instructions applicable to your browser at https://www.aboutcookies.org/how-to-manage-and-delete-cookies.

In addition, we may provide one-way secured (or “hashed”) versions of your email address or similar identifying information to certain third parties to provide more relevant and customized experiences and advertising to you as you browse the Sites or other third-party websites. This hashed version of your email address is a text string that uniquely identifies your email address but which is designed to prevent reverse engineering so that a third party should be unable to utilize the actual underlying email address and merely identify you as a unique user across devices, sessions, and browsers if you provide the same identifying information. If you provide a third party’s website with the same identifying information and that third party utilizes the same method of hashing, it is possible that the third party could match information obtained from us and combine it with information that you provide to the third-party website. For example, we may use ALC’s advertising services to provide you with more customized advertising by providing them with a one-way hashed version of your email address. You can learn more about how they process information, including information you submit to them directly, and about how to opt out of their targeted services by visiting https://optoutpreference.org/.

13. REFER A FRIEND

If a user elects to use our referral service for informing a friend about our Sites or particular products or services, we ask them for the friend’s name and email address. InspiraGen Institute will automatically send the friend a one-time email inviting them to visit the Sites. InspiraGen Institute stores this information for the sole purpose of sending this one-time email. The friend may contact InspiraGen Institute to request the removal of this information from their database.

14. CONTACTING INSPIRAGEN INSTITUTE

Please address comments or questions regarding InspiraGen Institute’s Privacy Policy to us via email or postal mail. You can complete our email form at: http://www.tyhoward.com/contact/contact-us. You may also contact InspiraGen Institute by mail or email at:

InspiraGen Institute
Attn: InspiraGen Institute Privacy
6400 Baltimore National Pike, Suite 134
Catonsville, Maryland 21228 USA
or
support@tyhoward.com