Effective Date: 12/26/2019
1. Information We Collect.
1.1 We collect general types of information about you when you visit and use our Website; examples include personal information, demographic information, behavioral information, and indirect information. Sometimes we collect combinations of these types of information:
1.1.1. 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, credit card number(s), bank account(s), employment status or self-employment 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. We may collect this same information about all other persons when you provide it to us.
1.1.2. 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, marital status, occupation, military service, industry of employment, personal and online interests. When we can identify you personally through the use of this information, it becomes Personal Information.
1.1.3. 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.
1.1.4. Third-Party Information. Is information about you that we acquire from a third-party which may include personal, demographic, behavioral and indirect information. This collection may also include, but not limited to, first party cookies, third-party cookies, anonymous cookies, persistent identifiers, email opt-in records and search engine keywords. We may also receive information third-parties derive from government entities which publicly post your information, such as your DMV records. We have no access or control over these cookies and other tracking devices used by third-parties including advertisers and networks, internet service providers, data analytics providers or social networks and platforms. 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.
1.1.6. No Information Collected from Children. We will never knowingly collect any Personal Information from children under the age of 16. If we obtain actual knowledge that we have collected Personal Information about a child under the age of 16, that information will be immediately deleted from its database. Because it does not collect such information, we have no such information to use or to disclose to third-parties.
1.1.7. No Sensitive Health Information is Collected. We do not collect information about past, present or potential future medical conditions or treatments. Nor do we collect any biometric information.
1.1.8. Credit Card Information and Bank Account Information. We may, in certain instances, collect credit card number(s), bank account information and related information, when you place an order on our Website. When the credit card or bank account information is submitted to us, such information is encrypted and is protected with SSL encryption software. We will use the credit card information or bank account information for purposes of processing and completing the transaction you requested through a third-party processor. As such, information will be disclosed to third-parties as necessary to complete the requested purchase transaction.
2.1 Generally, we as well as third-party vendors, networks, ISP(s) and supporting advertisers 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 analyze trends, administer our Website, track users’ 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. 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.
2.2 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 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.
3. How We Use Information Collected.
3.1 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. 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.
3.2 Improving Our Website. We use the information we gather to respond to any inquiries you make, operate and improve the functionality of our Website, and deliver the products and services advertised on our Website. We use the same for testing, research, analysis and product or marketing development. Our services include the display of personalized products, content, and advertising, relating to your experience and interests. This includes maintaining and improving the safety, security and integrity of our Website, databases and technology assets.
3.3 Promotions and Communications with You. We also use the information we gather to promote our and third-party services and products to you that might be of interest to you. We also use the information we have gathered to respond to your inquiries, concerns or requests. If your request is made through a third-party, we may use the information to respond to their requests.
4. Disclosure of Information to Others.
4.1.1. 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 products and services you have requested.
4.1.2. 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 our data, provide marketing assistance, process credit card payments, and provide customer service as set forth above.
4.1.3. Third-Party Products and Services. We share all categories of information set out in this policy with third parties including affiliated entities, service providers, and data aggregators with your information with third parties who will provide you with their opportunities, products or services. Again, 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.
4.1.4. 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 visitors that come to our Website, and how those visitors use our Website and promotion of our marketing. This includes demographic information and behavioral information.
4.1.5. 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: (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.
4.1.6. 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.
5. Third-Party Collection and Use of Information.
5.1 Third-parties collect and use information about you on or through our Website in the following way:
5.1.1. Advertisers. 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.
5.1.2. 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.
5.1.3. 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.
6.1 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. However, access to your information is strictly limited and not accessible to the public.
8. California Residents Rights.
8.1 Right to Know About Personal Information Collected, Disclosed, or Sold
8.1.1. You have the right to request that we advise you what Personal Information we collect, use, disclose, and sell that belongs to you. Personal Information does not include: (a) Publicly available information from government records; (b) De-identified or aggregated consumer information; (c) Information excluded from the CCPA’s scope, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”); (d) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”), California Financial Information Privacy Act (“FIPA”), or the Driver’s Privacy Protection Act of 1994 (“DPPA”).
8.1.2. You may submit a verifiable consumer request to obtain the specific Personal Information we have collected about you either through our California Resident Portal form or you may email us at [email protected].
8.1.3. Upon receiving your information, we are required to verify that you are the same consumer with whom we have the information in our systems. To verify your identify, we will require that you fill out the portal form in its entirety which includes your name, address, email address and may include the last four digits of your social security number, your bank account number and other Personal Information we have collected.
8.1.4. As set forth in our primary
8.1.5. Personal Information has been collected from the following categories of sources:
a. Information collected directly and indirectly from your activity on our website and your interactions or communications with us. This includes your Personal Information provided by you in connection with obtaining a certain product or service offered by us or one our network providers or advertisers.
b. Information you provide us when you enter promotions or sweepstakes offered by us or our clients including networks and advertisers.
c. Information you provide us through telephone and web-based surveys, customer service correspondence, and general feedback.
d. Information we received directly or indirectly from our clients or their agents in the course of providing services to you and others.
e. Analytics companies who provide demographic information such as gender, zip code, or any information that is not tied to your Personal Information. In addition, we may receive information about you from other online or offline sources, including third parties from whom we validate consumer self-reported information, and verify information we already have about you. This helps us to update, expand and analyze our records and provide products and services that may be of interest to you.
8.1.6. We have disclosed, shared and/or received compensation for our disclosure of Personal Information for the following commercial/business purposes in the preceding 12 months:
a. To obtain the services or products you have registered for on our Website.
b. To allow a third-party to market their products or services to you
c. To provide you with information, products or services that you request from us or resolve consumer concerns or request to opt-out of marketing.
d. To provide you with notices concerning our products or services, or events or news, that may be of interest to you.
e. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
f. To improve our website, products and services, and present its contents to you including testing, research, analysis and product development.
g. To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
h. To maintain the safety, security, and integrity of our Website, platforms as well as products and services, databases and other technology assets, and business.
i. To respond to government or law enforcement requests and as required by applicable law, court order, or governmental regulations.
j. To evaluate or conduct a merger, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our business or assets.
k. As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
8.1.7. We have disclosed Personal Information to our Service Providers and the following categories of third parties:
a. Our affiliated entities.
b. Data aggregators.
d. Ad Networks.
e. Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we and/or third parties provide to you.
8.1.8. We do not collect, distribute, share or sell the Personal Information of anyone under the age of 16.
8.2 Right to Request Deletion of Personal Information
8.2.1. You have a right to request the deletion of your Personal Information if we have collected or maintained it in the past 12 months.
8.2.2. You may submit a verifiable consumer request to delete your information using our California Consumer Portal and fully fill out the request form or contact us by email at [email protected]
8.2.3. Once we receive and confirm your verifiable consumer request, we will disclose to you the following:
a. The categories of Personal Information we collected about you.
b. The categories of sources for the Personal Information we collected about you.
8.2.4. This policy has disclosed our business or commercial purpose for collecting or selling that Personal Information and the categories of third parties with whom we shared that Personal Information.
8.3 Right to Opt-Out of the Sale of Personal Information. You have the right to opt-out of any sale of your Personal Information by us. If you are requesting a product or service, this is an exemption from this right, and we will process your request. However, you have the right to cease all further sale of your Personal Information.
8.4 Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights. You have a right not to receive discriminatory treatment by us for the exercise of these privacy rights conferred by the CCPA. As such, we will not deny you goods or services, charge you different prices or rates for goods or services, or deny you discounts or other benefits; nor will we provide you a different level or quality of goods or services or recommend a different level or quality of goods or services.
8.5 Authorized Agent. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.
8.6 Contact Us. Contact us for more information or with any questions either through our California Consumer Portal or by email at [email protected]
8.7 Limitations on Requests. You may only make a verifiable consumer request for access twice within a twelve (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 your authorized agent; (b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to you; (c) 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; (d) Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
8.8 Response Time and Response Format. We make every effort to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons why we cannot comply with a request, if applicable. We will provide our response in a manner that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance to you.
8.9 Changes to California Resident Privacy Notice. We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will enforce the terms of the new policy going forward. You will receive no other notice than an updated posting on this page. Please check back each time you use or visit our Website.
9. GDPR and CASL Compliance.
10.1. Unfortunately, we are not in a position to accept clients 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 referrals 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 [email protected] and we will remove and destroy your Personal Information. We apologize for the inconvenience.
If you have any questions or comments about this Privacy Statement, please do not hesitate to contact us at: [email protected]