Effective Date: January 1, 2020
1. Information We Collect.
- 1.1 User Direct Information. Each time you provide or transmit information to our Company, we obtain and collect personal information about you, including, but not limited to, your name, email address, mailing address, social security number, credit card information, bank account information and telephone or mobile phone number(s) (collectively "personally identifiable information" or "PII").
- 1.2 Survey Information. Company may collect PII when you voluntarily complete a Company survey, order form, or a registration page, either online (by using the Internet) or offline (by providing this information through the mail, in person or using a telephone).
- 1.3 Third Party Information. Company may collect PII from you when you provide information to a third party, and Company subsequently acquires or uses the information provided by that third party. Such information may include, but is not limited to, your name, email address, street address, zip code, telephone number(s) (including mobile phone number(s) and carriers), birth date, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests, and such other information as you may have provided to the third party. When acquiring this information, Company seeks assurances from the third party that you agreed to provide such information and to such information subsequently being acquired by Company. If you did not give your express permission, or you would like to remove your permission, you may suppress all your information by sending to us at [email protected], or you may change your PII using your log in password.
- 1.4 Cookies, Web Beacons, and Other Information Collected Using Technology. Company currently uses cookie and Web beacon technology to associate certain Internet-related information about you with information held in its database. Additionally, Company may use other new and evolving sources of information in the future. Company does not acknowledge do not track cookies.
- Web Beacons. A Web beacon is a programming code that can be used to display an image on a Web page but can also be used to transfer your unique user identification to a database and associate you with previously acquired information in that database. They are also known as "clear gifs," "one-pixel gifs," "Web bugs," "Internet tags," or "pixel tags." This allows Company to track certain websites that you visit. Web beacons are used to track online behavioral habits for marketing purposes in order to determine which products or services you may be interested in. In addition to using Web beacons on Web pages, Company also uses Web beacons in email messages sent to individuals listed in Company's database.
- IP Addresses. Company automatically tracks certain information based upon your behavior on our websites. We may use this information to do internal research on our users' demographics, interests, and behavior, to better understand, protect and serve you and our community. This information may include the URL that you just came from (whether this URL is on our website or not), which URL you next go to (whether this URL is on our website or not), your computer browser information, and your IP address. Your Internet Protocol ("IP") is a unique Internet "address" which is assigned to you by your Internet Service Provider ("ISP"). For Local Area Network ("LAN"), Dedicated Server Line ("DSL"), or cable modem users, an IP address may be permanently assigned to a computer. IP addresses are automatically logged by Web servers collecting information about a user's traffic patterns. While the IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual using the Web. Your IP address can, however, reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages.
- Data Analysis. Data analysis technology may be employed from time to time if used by a Business Client of Company.
2. How Information is Used and Shared.
- 2.1 Disclosure of Information to Service Providers and Third-Party Vendors. Although much of our disclosures are governed by our contracts with our Business Clients, Company may disclose your PII to third party service providers and vendors in order to carry out any transaction that you have requested from us, or as necessary to complete our contractual obligations with you. This includes email service providers, providers of direct marketing services and applications, including lookup and reference, data hygiene providers, data enhancement providers, suppression services and validation services. We contractually prohibit the sale or transfer of PII by such service providers and vendors. We may share PII with affiliated companies that are directly or indirectly controlled by, or under common control, of Company.
- 2.2 Disclosure of Web Technology Related PII. Company uses and discloses information collected by cookies and Web technology to third party vendors to enhance your online experience by allowing Company to save your preferences for your next visit. Cookies may also measure the general activity on the website, which allows Company to determine which areas and features are most popular in order to make improvements to the website. Web beacons, also known as "clear gifs," "one-pixel gifs," "Web bugs," "Internet tags," or "pixel tags," are used by Company and third parties to monitor the activity on our website or to make cookies more effective. We use log files to store the data that is collected through Web beacons.
- 2.3 Complying with Legal Process. Company will use or disclose your PII in response to subpoenas, court orders, warrants, or legal process, or to otherwise establish or exercise Company's legal rights, or defend against legal claims, or in the event of a breach in an agreement with Company. Company will use and disclose your PII if Company believes that a user of this website, or a Business Client, will harm the property or rights of Company, its owners, or Company's other customers. Finally, Company will use or disclose PII if it believes that it is necessary to investigate, prevent, or take action, regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of Company's acceptable use policy.
3. Choices Regarding PII Use and Sharing.
As the only information we collect through our Corporate website is information we use to connect with Business Clients and prospective clients, we do not provide an opt-out for information collected. If you would like to correct or be removed from our client database, please contact us at [email protected]. If you wish to review the PII related to you which has been collected by Company on our websites, please provide the request in writing to [email protected]. Company reserves the right to confirm the identity and association of the person requesting such information prior to any disclosure.
We endeavor to safeguard and protect your information. We use redundant and robust servers to host internal data, which are also protected by high performance firewalls housed in one of the premium collocation services in California. Our Web frontend and application systems are user and password protected to prevent access from unauthorized users. Access restriction rules and policies by IP address and domain are also implemented on our high-performance firewalls. Thus, when you submit information via the website, such information is protected both online and offline. The servers in which we store PII are kept in a secure physical environment. Company has security measures in place to protect against the loss, misuse, and alteration of personal information under our control. In addition, Company currently uses Secure Socket Layer software ("SSL") to protect data and to secure any transactions. SSL encrypts information including credit card numbers, and names and addresses, as they are transmitted over the Internet. Please be advised that, although Company takes reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure; therefore, Company cannot and does not warrant that your information will be absolutely secure. Any transmission of data at or through our websites is at your own risk.
5. Do Not Call Waiver
By registering via our websites, or otherwise, for our services, you agree that such act constitutes an inquiry and/or application for the purposes of the Amended Telemarketing Sales Rule (16 CFR 310, et seq.), as amended from time to time, and other telemarketing laws such as the FCC rules. Notwithstanding that your telephone number(s) may be listed on the Federal Trade Commission's Do-Not-Call List, we reserve the right to contact you via telemarketing in accordance with the Amended Telemarketing Sales Rule.
6. No Information Collected from Children
Company will never knowingly collect any PII about children under the age of 13. If Company obtains actual knowledge that it has collected PII about a child under the age of 13, that information will be immediately deleted from its database. Because it does not collect such information, Company has no such information to use or to disclose to third parties.
8. California Consumer Rights
California Resident Privacy Rights
(1) Right to Know About Personal Information Collected, Disclosed, or Sold
- 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: (i) Publicly available information from government records; (ii) De-identified or aggregated consumer information; (iii) Information excluded from the CCPA's scope, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"); (iv) 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").
- 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]
- 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.
- Personal Information has been collected from the following categories of sources:
- 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.
- Information you provide us when you enter promotions or sweepstakes offered by us or our clients including networks and advertisers.
- Information you provide us through telephone and web-based surveys, customer service correspondence, and general feedback.
- Information we received directly or indirectly from our clients or their agents in the course of providing services to you and others.
- 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.
- We have disclosed, shared and/or received compensation for our disclosure of Personal Information for the following commercial purposes in the preceding 12 months:
- To obtain the services or products you have registered for on our Website.
- To allow a third-party to market their products or services to you.
- To provide you with information, products or services that you request from us or resolve consumer concerns or request to opt-out of marketing.
- To provide you with notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website, products and services, and present its contents to you including testing, research, analysis and product development.
- 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).
- To maintain the safety, security, and integrity of our Website, platforms as well as products and services, databases and other technology assets, and business.
- To respond to government or law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, restructuring, reorganization, dissolution, or other sale or transfer of some or all our business or assets.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- We have disclosed Personal Information to the following categories of third-parties:
- Our affiliated entities.
- Our Service Providers.
- Data aggregators.
- Ad Networks.
- 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.
- We do not collect, distribute, share or sell the Personal Information of anyone under the age of 16.
(2) Right to Request Deletion of Personal Information.
- You have a right to request the deletion of your Personal Information if we have collected or maintained it in the past 12 months.
- 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]
- Once we receive and confirm your verifiable consumer request, we will disclose to you the following:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third-parties with whom we shared that Personal Information.
(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 a business. 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 sharing of information.
(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.
(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.
(6) Contact Us
(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) 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.
(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 enter our Website.
(10) Contact Information
If you have any questions or comments about this Privacy Statement, please do not hesitate to contact us at:
Postal Address: 30401 Agoura Road, Suite 100, Agoura Hills, CA 91301