Effective Date: February 25, 2021
- INFORMATION WE COLLECT.
We collect various types of information about you when you visit and use our Website or one of our powered registration applications. Examples of the type of information we collect includes personal information, behavioral information, third-party information and technology driven information. Sometimes we collect combinations of these types of information:
- Personal Information. Is information that can be used to identify you or any other individual to whom the information may relate. The CCPA refers to this type of information as an “Identifier.” This is information which you are prompted to provide to us. Such information may include your name, address, telephone number(s), mobile numbers and email address, credit card number(s), bank account(s), other unique information about you which you provide to us during the registration process, or through the course of communicating with us. We may collect this same information about all other persons when you provide it to us.
- Behavioral Information. Is information which is automatically collected when you use our Website. This information includes the areas of our Website that you visit, what services you access or ordered, information about your computer hardware and software, including your IP address, geographic location, browser preference, operating system type, domain names, times that you access the internet, and other websites you have visited. When we can identify you personally, through the use of this information, it becomes Personal Information.
- Third-Party Information. Is information about you that we acquire from a client which may include personal as well as behavioral and technology information. This collection may also include information from cookies, persistent identifiers, and email opt-in records. We may also receive information third-parties derived from government entities which publicly post your information, such as your DMV records. We have no access or control over the cookies and other tracking devices used by third-parties, including our clients. We have no responsibility or liability for the policies and practices of these parties. When we can identify you personally, through the use of this information, it becomes Personal Information.
We use technologies such as cookies, web beacons, and java scripts. These technologies collect internet protocol (“IP”) addresses, browser type, internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This information is used to verify your identity, analyze uses, administer our Website, track users’ movements through our Website and share the information with our Clients, in order to honor your requests. We may receive reports based on these technologies on an individual or aggregated basis. California residents have the right to know if we respond to do not track signals or cookies. We do not respond to such signals or cookies.
- Web Beacons. We use electronic images known as Web Beacons (sometimes called single-pixel gifs, clear gifs or action tags) which allow us to collect information about your visit to our Website, measure and improve the effectiveness of services and track delivery of responses to you. Web Beacons collect only a limited set of information including a cookie number, time and date of page view, as well as a description of the page on which the Web Beacon resides. We may also use Web Beacons in email messages sent to you. This allows us to determine if you opened or acted upon the email message. Because Web Beacons are the same as any other content request, you cannot opt-out or refuse them. However, they can be rendered ineffective by either opting-out of cookies or changing the cookie setup in your browser.
- HOW WE USE INFORMATION COLLECTED.
- Providing Services. We use the information we gather to provide our clients with our services and to perform your request. This may include passing your information on to our client or a third-party to provide responses to your requests in furtherance of our services to our clients. Although our contractual arrangement limits how this party can use your information, we do not control the privacy practices of third-parties. We also use the information to manage our clients’ use of the Services, respond to inquiries and comments and provide customer service and support.
- Improving Our Website and Services. We use the information we gather to respond to any inquiries you make, operate and improve the functionality of our Website, and deliver the services to our clients. We use the same for testing, research, analysis and product or marketing development. This includes maintaining and improving the safety, security and integrity of our Website, database(s) and technology assets.
- DISCLOSURE OF INFORMATION TO OTHERS.
- Product and Service Delivery. We share all categories of information set out in this policy with third-parties who help us in the delivery of the services you have requested.
- Website Functionality. We share all categories of information set out in this policy with third-parties we employ to perform technical functions on our behalf. Examples include third-parties who host our Website, analyze data, provide compliance assistance, and provide customer and client services.
- Anonymized information. We share aggregated anonymous information about you, combined with other persons using our Website with third-parties, so that they can understand the kinds of consumers that come to our Website, how those consumers use our Website and promotion of our marketing.
- Legal Process. We disclose your information if legally required to do so, or at our discretion, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to: (i) conform to legal requirements or comply with legal process; (ii) protect our rights or property, or our clients; (iii) prevent a crime or protect national security; or (iv) protect the personal safety of users or the public.
- THIRD-PARTY COLLECTION AND USE OF INFORMATION.
Third-parties collect and use information about you on or through our Website in the following way:
- Clients. Advertising agencies, advertising networks, and other companies who retain our services are provided the information and may collect additional information about you using their own cookies, web beacons, and other technology. We do not control the use of such technology and have no responsibility for the use of such technology to gather information about you.
- Analytics. As described above, we use third-parties to monitor, analyze and report on the traffic to, from and within our Website and email messages.
We endeavor to safeguard and protect your information. When you submit information on our Website, such information is protected both online and offline. We have security measures in place to protect against the loss, misuse, and alteration of personal information under our control. The servers in which we store your information are kept in a secure physical environment. The servers have industry standard firewalls. Access to such servers is password protected and access by our employees is limited. Currently, we use Secure Socket Layer software (“SSL”) to protect data and to secure any transactions. SSL encrypts information including credit card number(s), and names and addresses, as they are transmitted over the Internet. Please be advised that, although we take commercially reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure; therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of data at or through our Website is at your own risk.
- CALIFORNIA RESIDENTS RIGHTS (CCPA).
The California Consumer Privacy Act (“CCPA’”), provides California residents with certain rights regarding the personal information that businesses have about them. This includes the rights to request access or deletion of your personal information, as well as the right to direct a business to stop selling your personal information.
- Collection and Use of Personal Information. We collect consumers and clients name, address, email, phone number, job title, and transactional information (“identifiers”) from you directly. We also collect records of services purchased, services undertaken and the like (“commercial information”), and as described above technological information automatically such as usage information, IP address, and cookies (“Internet or other electronic network activity information”).
- Use of Personal Information. We use identifiers to provide the services requested by either our clients or a consumer. This includes collecting California consumers requests for deletion, information or not to sell personal information. It also includes record keeping, troubleshooting, data analysis, and testing. We use identifiers, commercial information, and Internet or other electronic network activity for monitoring, marketing, and advertising, as well as website and database security.
- Sharing and/or Selling Your Personal Information. We share personal information identifiers, commercial information and internet or other electronic network activity with providers as necessary for certain “business purposes,” as defined by the CCPA (Cal. Civ. Code 1798.140(d)). This includes processing, consumer and client relationship management, consulting, email, product feedback and legal compliance. We do not sell personal information collected through this Website in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). This includes sharing identifiers, commercial information and internet or other electronic network activity with clients, independent consultants, advertising networks, and website analytics companies.
- The Right to Opt-out of Sale. For California consumers using our website or powered application, we do not sell your personal information, but will provide it to honor your requests as submitted by you. We retain this information to provide proof of your request and our client’s honoring of such request. Because it is a requirement of CCPA that such proof be retained for a period of three years, you may not opt-out of the sharing of this information between us and our clients. Your personal information is retained in an encrypted form when stored. Otherwise, we do not sell your information in any form. For California businesses who have retained our services, our relationship is governed by our written agreement. We may still use aggregated and de-identified personal information that does not identify you or any individual; we may also retain information as needed, in order to comply with legal obligations, enforce agreements, and resolve disputes.
- Right to Request Disclosure. You have the right to request identification of the personal information We have collected, shared or disclosed for a business purpose: The categories of sources from which We collected the personal information; The business or commercial purpose for Our collecting or selling the personal information; The categories of third-parties with whom We shared personal information; The specific personal information We collected about you; The categories of personal information that We disclosed about you for a business purpose; The categories of personal information We sold about you; The categories of third-parties to whom We sold the information;
If you would like to exercise your right to request disclosure, please fill out our California Consumer Request Portal or email us at [email protected]. Our privacy team will examine your request and respond to you as quickly as possible.
- Right to Request Deletion. Consumers have the right to request that We delete your personal information from our systems. We will honor that request unless We are required to retain such information to prove legal compliance by our clients or Us. Clients may requests are governed by our written agreement with the client.
If you would like to exercise your right to request deletion, please fill out our California Consumer Request Portal or email us at [email protected]. Our privacy team will examine your request and respond to you as quickly as possible.
- Right to Non-Discrimination. We do not discriminate against you for exercising any of your rights under the CCPA.
- CALIFORNIA’S SHINE THE LIGHT LAW.
California residents have the right to receive, once a year, information about third-parties by category with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. California residents also have the right to know if we respond to do not track signals or cookies. We do not respond to such signals or cookies. California customers may request further information about our compliance with this law by sending us an email at [email protected]. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.
- CONTACT US.