Last Updated: August 14th, 2020
Personal, Business and Financial Data
The Company collects personal information when you visit the Website. Much of this information is collected during the registration and/or application process and, while some items are optional, some are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Website; in some cases, this additional information will be required by us as a condition of your availing yourself of the Company’s and/or Clients’ goods or services, or your continued use of the Services.
Generally, the type of information we collect includes, but is not limited to:
- Data required to verify your identity and any consents necessary for receipt of the Services;
- Personal, business and financial data necessary to assess your eligibility to utilize the Services on the Website; and
- Non-identifiable and aggregated personal/business data pertaining to your Website visits that help the Company evaluate and maintain quality control with respect to the features, functionality and user experience of the Website.
Registration pages and forms will require you to provide basic personal data. This typically includes your name, email address, home or business address/zip code and phone number. The Company uses this data to: (i) enable you to register with, log in and/or return to the Website; (ii) establish your eligibility to utilize the Company’s or the Clients’ goods and services; (iii) verify your age (if applicable); (iv) guard against potential fraud; (v) contact you if we would like to reach you; and (vi) maintain regular and reliable communications with you regarding interest in Company or Client activities and related matters.
We also gather the names and email addresses of users and visitors who contact us through the Website with questions about the Company, the Website or the Services. We collect this information for the sole purpose of responding to such inquiries and improving the Website and the Services.
Other Personal Data
When you enter sensitive information on our online forms (including when we collect geolocation information), we encrypt the transmission of that information using Transport Layer Security (TLS). We utilize industry standard physical, technical, and administrative controls and procedures to safeguard the information we collect, to prevent unauthorized access or disclosure, to maintain data accuracy, and to allow only the appropriate use of your personal data. As no method of transmission over the Internet or method of electronic storage is completely secure, we cannot guarantee its absolute security.
The Company and its service providers may also collect web surfing data related to your use of the Website. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Website. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. We may use this aggregated information in the administration of the Website to improve its usability and to evaluate the success of particular marketing and advertising campaigns. We also use it to help optimize the Website based on the needs of our users.
Sharing of Personal Information
We may work with (among others) providers of hosting services for the Website, electronic signature providers, and electronic payment service providers. We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing or data storage. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Website or our services, or to protect the rights, property or personal safety of the Company, its users, issuers, or others.
Notifications and Communications from Our Website
The Company will send you email notifications from time to time. Some notifications are required elements of your transactions on our Website, such as confirmations of particular actions you have taken.
We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your information without your knowledge. In other cases, these notifications may involve changes to various legal agreements or Website policies about which we would like to inform you. Generally, you may not opt out of such service-related emails.
When you apply for Company’s or Clients’ goods and services, you will receive emails that confirm specific actions you requested. These may include emails to which you must respond to complete your registration and notifications confirming your application and, perhaps, requesting additional or supporting information.
We may also send you responses to emails you send us, if appropriate. From time to time, we will also send user surveys, requests for user feedback regarding user experience and Website operations, or marketing offers from us or from us on behalf of our marketing partners. Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary. If you do not wish to receive these surveys, user feedback emails, and/or marketing offers, please opt out in any offer email you receive from us.
Questions on Your Information
Links to Other Sites
Information We Collect
|(1) Identifiers||Real names, aliases, postal addresses, email addresses, phone numbers, unique personal identifier, online identifier, Internet Protocol address, account information, or other similar identifiers|
|(2) Commercial Information||Products or services purchased, obtained or considered, or other purchasing or consuming history or tendencies|
|(3) Internet or other similar network activity||Information on your interaction with the Company and Website, including, but not limited to, browsing history and search history|
|(4) Geolocation data||Physical location, generally|
|(5) Inferences drawn from other personal information||Profiles reflecting a persons’ preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes|
We may obtain the categories of personal information listed above from the following categories of sources:
- Directly from you: For example, from forms/surveys you complete, information you input into the Website, and any other communications between you and the Company, including information relating to products and services you purchase from our Clients.
- May apply to the following categories: (1), (2), and (4)
- Indirectly from you: For example, from observing your actions on the Website.
- May apply to the following categories: (1), (3), (4) and (5)
Use of Personal Information
- Performing Services. For example, we will use the personal information you submit through our website to help us provide you with information, products or services that you request from us; in addition, we will use your information to customize our Services for you, including facilitating your transactions with Clients, hosting our Website, managing databases, performing analyses, and marketing services.
- Providing you email alerts and other notices concerning our Services and our Client’s products/services that may be of interest to you.
- Auditing interactions with users. For example: monitoring traffic to our Website, counting ad impressions, and auditing legal and regulatory compliance.
- For example, maintaining the safety, security, and integrity of our business, services to our clients, Website and its services, databases and other technology assets, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations.
- Debugging/Repair. For example, identifying and repairing errors in our Website’s functionality.
- Certain Short-term Uses. For example, ad customization that does not involve or contribute to profiling.
- Internal Research for Tech Development. For example, testing, research, analysis, and product development, including to develop and improve our Website and Services.
- Quality and Safety Maintenance and Verification. For example, improving, upgrading or enhancing our Services or Website, and verifying the quality or safety of our Website or Services.
- Other Commercial Purposes. For example, as described to you when collecting your personal information resulting in a commercial transaction with our Clients and/or to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose described above. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for performing the contract.
We may disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- May apply to the following categories: (1), (2), (3), (4) and (5)
- Our Clients.
- May apply to the following categories: (1) and (2)
- Our Service Providers (as defined under the CCPA) that help us perform the Services offered by the Website.
- May apply to the following categories: (1), (2), (3), (4) and (5)
We do not, and will not, sell any personal information. As a result, in the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides California residents with the additional rights listed below:
- Right to Know. You have the right to know and see what data we have collected, used, disclosed, and sold about you over the past 12 months, including:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting your personal information;
- The categories of third parties with whom we have shared your personal information; and
- The specific pieces of personal information we have collected about you.
- Right to Delete. You have the right to request that we delete the personal information we have collected from you. There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
- Complete your transaction;
- Provide you a good or service;
- Perform a contract between us and you;
- Protect your security and prosecute those responsible for breaching it;
- Fix our system in the case of a bug;
- Protect the free speech rights of you or other users;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
- Comply with a legal obligation; or
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
- Authorized Agent. You have the right to appoint another person or entity registered with the Secretary of State (“Authorized Agent”) to make a request for you. If you appoint an Authorized Agent, you must provide us with legal authorization indicating your consent to have an Authorized Agent act on your behalf. Examples of acceptable forms of legal authorization include, but are not limited to, a fully executed Power of Attorney or a notarized affidavit. If you choose to submit a request using an Authorized Agent, we may require that you provide your Authorized Agent with written permission to make a request on your behalf, and that you verify your identify directly with us. We may deny a request from an Authorized Agent that does not submit proper proof of authorization.
- Other Rights.
- Disclosure of Personal Information to Third Parties for Direct Marketing. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. To make such a request, please contact us at firstname.lastname@example.org.
- You have the right not to be discriminated against for exercising any of the rights listed above.
- Exercising Your California Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under California law, or to discuss any questions or comments you have about our privacy policies and practices, please contact us by using the following methods:
- Email: You may write to us to exercise rights. Please include your full name, residential address, email address, and phone number, along with why you are writing, so that we can verify your identity and process your request in an efficient manner. Please email us at email@example.com.
- Toll-Free Telephone Number: You may call us at (888) 808-1787 to exercise your rights. Please include your full name, residential address, e-mail address, and phone number, along with why you are calling, so that we can verify and process your request in an efficient manner.
- Response Timing. After submitting your request for access or deletion, you will receive a confirmation receipt within 10 business days that includes additional information. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing. If we are not able to verify your identity based on the information you have provided, we may ask you for additional information. 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.
The Website may be accessed by users located outside the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States, and that by providing your personal information on or through the Website then you consent to that transfer.
We limit access to the personal information we have about you to those employees who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. The Website is built upon a secure infrastructure with multiple layers of protection, and we use industry-standard encryption technologies to safeguard your information.
Notifications of Security Systems Breach
If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Website in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Take Precautionary Measures
You can take several precautions to protect the security of your computer and personal information. For instance, you can use a strong password and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on the Website, be sure that you log out and close the browser window.
You should also be aware of fraudulent attempts to gain access to your account information through “phishing,” whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake site, scammers will ask for login information to gain access to people’s accounts and withdraw their money.
We will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go the website directly from your browser’s home page.
ATTENTION KIDS: No information should be submitted to the Company by children under 18 years of age without their parent’s or guardian’s consent. The Company does not monitor the age of its user audience.
The Company reserves the right to change this policy at any time by posting notice of the existence of a new privacy statement. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any party.