Information We Collect
We collect the following types of information about you when you visit and use our Website “Personal information” is information that can be used to identify you or any other individual to whom the information may relate. 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, or other unique information about you which you provide to us during the registration process, or through the course of communicating with us about the products and services provided on our Website.
“Demographic information” is information that may or may not be unique to you in the sense that it refers to selected population characteristics. Such information may include, but is not limited to, zip code, mobile phone carrier, age, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests.
“Behavioral information” is information which is automatically collected pertaining to how you use our Website, the areas of our Website that you visit, what services you access, and 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.
“Third party collected information” is information about you that we acquire from a third party which may include personal, demographic, behavioral and indirect information. This collection may include, but not limited to, first party cookies, third party cookies, anonymous cookies, persistent identifiers, email opt in, and search engine keywords. We have no access or control over these cookies and other tracking devices used by data aggregators, third party advertisers and third party networks. We have no responsibility or liability for the policies and practices of these parties.
No Information Collected from Children. We will never knowingly collect any Personal Information from children under the age of 13. If we obtain actual knowledge that we have collected Personal Information about a child under the age of 13, that information will be immediately deleted from our database. Because we do not collect such information, we have no such information to use or to disclose to third parties.
Generally, we as well as third party vendors and supporting advertisers use technologies such as cookies, web beacons, and java scripts to collect information. 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 analyze trends, administer our Website, track user's movements through our Website and gather demographic information about our user base as a whole. We may receive reports based on these technologies on an individual or aggregated basis.
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 advertisements and track delivery of advertising. 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 messages. 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.
Proprietary Auto-Fill Tracking. At times, we use third party vendors who have technology which collects information held in your browser’s auto-fill functionality This collection allows them to notify you of an error in the registration or a failure to submit the registration. You can stop this functionality by turning it off in your browser. There is no loss of use of our Website or services should this browser function be turned off.
How We Use Information Collected.
Providing Services and Products. We use the information we gather on our Website to provide you with the services and or products you have requested. After visiting one of our client’s websites, we use the information we have collected during your visit to send you an email to complete your registration or provide you with additional offers that may be of interest to you. This may include passing your information on to a third party to provide such services or products. Although our contractual arrangement limits how this party can use your information, we do not control the privacy practices of third parties. If you have any questions or wish to remove your information from the third party databases, you will need to contact that party directly.
Improving Our Website. We use the information we gather to respond to any inquires you make, operate and improve the functionality of our Website, and deliver the products and services advertised on our Website. Our services include the display of personalized products, content, and advertising, relating to your experience and interests.
Targeted Advertising. Based on User Information, we may customize and target advertising to an individual. In our discretion, we may combine information to target advertising to an individual on the Site, in email and/or through direct mail. Such advertising may be different to the products or services offered or promoted on our Website.
Commercial Email. We may use your email address to promote goods and services of third parties that may be of interest to you and these may be different than the products or services offered or promoted on the Site.
Direct Mail. We may use User Information to advertise, directly or indirectly to individuals using postal mail.
We Share Your Information.
We will share your personal information with third parties in the following ways:
Product and Service Delivery We share your personal information with third parties who help us in the delivery of the products and services you have requested.
Website Functionality. We share your Personal and Non-Personal information with companies and individuals we employ to perform technical functions on our behalf. Examples include third parties who host our Website, analyze our data, provide marketing assistance, process credit card payments, and provide customer service.
Third Party Products and Services. We share your Personal and Non Personal Information with third parties who will provide you with their opportunities, products or services. This includes your personal and non-personal information, and includes your interests and preferences, so they may determine whether you might be interested in their products or services.
Anonymous 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 visitors that come to our Website, and how those visitors use our Website. This includes demographic information and behavioral information.
Legal Process. We disclose and share 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 (a) conform to legal requirements or comply with legal process; (b) protect our rights or property, or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
Acquisition or Merger. We may disclose and transfer your information to a third party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.
Third Party Collection and Use of Information.
Third Parties collect and use information about you on or through our Website in the following ways:
Service Providers and Advertisers. Service Providers of the service or product you have requested, Advertising agencies, advertising networks, and other companies who place ads on our Website, may use their own cookies, Web beacons, and other technology, to collect information about you. We do not control the use of such technology and have no responsibility for the use of such technology to gather information about you.
Hyperlinks. Our Website and email messages sometimes contain hypertext links to Websites owned by third parties. We are not responsible for the privacy practices or the content of such other Websites. These links are provided for your convenience and reference only. We do not operate or control any information, software, products or services, available on these third party Websites. The inclusion of a link on our Website does not imply any endorsement of the services, products or website, or its sponsoring organization.
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.
Disclaimer. We do not control the collection and use of any information collected by Third Parties. Please review their policies and terms before providing any information.
Information Security and Retention
We use industry standard precautions to safeguard your personal Information from loss, theft and misuse including unauthorized access, disclosure, alteration and destruction. These precautions are technical, physical and managerial. 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 from improper actions of third parties not under our control; therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of information through our Website or through email communications is at your own risk.
We retain Personal Information for the time necessary to fulfill the purpose for which you provided the information and retain it thereafter for a period permitted by law. We retain Non-Personal Information indefinitely as the same is used by us for any proper purpose, including but not limited to analysis, development and improvement of our Website, services and products.
California residents have the right to receive, once a year, information about third parties 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. In addition, 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.
As stated in this Policy, you have agreed to allow us to share information with third parties for their direct marketing purposes until you remove your information; and thus, you have agreed to this disclosure. California customers may request further information about our compliance with this law by sending us an email at email@example.com. 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.
GDPR and CASL Compliance
Unfortunately, we are not in a position to accept registrants who are not U.S. Citizens. The CASL and GDPR regulations, in particular, provide certain rights to their citizens which are not the same as the United States. For this reason, we do not accept registrations from any citizen outside the United States. Our services are specifically designed for United States citizens. We have expunged all European Union Member and Canadian Citizens data to the extent we have been made aware of the same. If you are a European Union Member, Canadian or any country outside of the United States citizen, please notify us at firstname.lastname@example.org.
California Consumers’ Privacy Rights
Personal Information Collected
We collect Personal Information provided by Consumers through the Site. In the past 12 months, we have collected the following Personal Information from Consumers:
|Category of Information||Examples||Information Collected|
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||Yes|
|Categories of personal information described in subdivision (e) of Section 1798.80.||A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card, or any other financial information, or health insurance information.||Yes|
|Characteristics of protected classifications under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran military status, genetic information (including familial genetic information).||No|
|Commerical Information||Records of perosnal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|Biometric information||An individual's physiological, or biological or behavioral characteristics, including an individual's deoxyribonucleic acid (DNA), that can be use, singly or in combination with each other or with other identifying data, to establish individual identity, including but not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, helath, or exercise data taht contain identifying information.||No|
|Internet or other electronic netowrk activity information||Browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, advertisement.||No|
|Geolocation||Physical location, position, and movement data.||No|
|Sensory information||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|Professional or employment-related information||Present and past employment data.||No|
|Education information||Education records maintained by educational institutions or third parties on behalf of these institutions.||No|
|Inferences drawn from any other information||Data reflecting a consumer's preferences, characteristics, habits, attitudes, predispositions, intelligences, and abilities.||No|
The categories of Personal Information described above are collected from the following categories of sources:
- Directly from Consumers or their agents, such as through Consumers’ responses to our web forms.
- Directly and indirectly from activity on our Website, such as through Consumers’ interaction with our Website.
- From third parties that work with us to provide services to Consumers, such as third parties that we connect Consumers with to fulfill their requests.
Uses of Personal Information
The information we collect is used to:
- Fulfill the purpose for which the information was provided by the Consumer.
- Perform the activities described to Consumers when collecting their Personal Information or as set forth in the CCPA.
- Provide the Consumer with information, products, or services that have been requested.
- Perform internal and external marketing.
- Carry out obligations and enforce contractual rights.
- Improve the services provided through the Website, such as through testing, research, analysis, and development.
- Respond to requests from law enforcement and government organizations as required by law, court order, or government regulation.
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets whether on an ongoing basis or as part of a discrete transaction in which collected Personal Information is among the assets transferred.
Personal information will not be used for materially different purposes without first providing the Consumer with notice.
Sharing and Sale of Personal Information
We may sell or disclose Personal Information provided to us by Consumers for a business purpose. In the past 12 months, the following categories of Personal Information have been sold or disclosed for a business purpose:
- Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80
- Characteristics of protected classifications under California or federal law
- Commercial information
Consumers’ Personal Information is sold or disclosed for business purposes to the following categories of third parties:
- Mortgage companies
- Home improvement companies
- Contact centers
- Email affiliates
- Media buyers
- Compliance vendors
Personal information for minors under 16 years of age is not collected, disclosed for a business purpose or sold.
Consumers have several rights under the CCPA. These include:
- The right to know what categories and specific pieces of Personal Information are collected, disclosed for a business purpose, or sold by requesting this information from us.
- The right to request deletion of Personal Information collected or maintained by us.
- The right to opt-out of the sale of Personal Information.
- The right not to receive discriminatory treatment from us for choosing to exercise privacy rights under the CCPA.
- The right to designate an authorized agent for making requests under the CCPA on the Consumer’s behalf.
Even after fulfilling a request for deletion, we are required to maintain records for statutory compliance.
To submit a request to know or delete Personal Information, please either call our toll-free telephone number (877) 623-0003 or complete the form provided here. Once we have received a request, we work with Consumers to verify their identities. As part of the verification process, we work with OneTrust. Depending on the type of request submitted, OneTrust may request information from the Consumer, such as an email address, phone number, or government issued identification card. More information about OneTrust’s identification process is found here. If a Consumer has asked an agent to exercise rights on the Consumer’s behalf, the agent’s identity will need to be verified by providing a writing from the Consumer designating the agent in addition to any information requested through OneTrust.
To opt-out of the sale of Personal Information, please complete the form located here.
Revised Posting Date: January 3, 2020