- Information we collect
- How We Use Information Collected
- Information Security and Retention
- California Resident Rights
- GDPR and CASL Compliance
- Contact Us
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.
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 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.
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. After visiting one of our 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.
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.
WE DO NOT SELL YOUR DATA TO ANY THIRD PARTY. We DO NOT Share, Disclose, or Transfer Your Information- EXCEPT FOR LIMITED PURPOSES AS STATED BELOW.
We will share, disclose or transfer your personal information with third parties for limited purposes only in the following ways:
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.
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 Resident Rights.
Your California Privacy Rights
If you are a resident of the State of California certain additional privacy-related rights may apply to you, including the right to opt-out of our sale of your Personal Information, as well as the right to know what Personal Information about you we have collected, whether your Personal Information was shared with third-parties in the preceding year and, if so, what categories of Personal Information were shared, as well as the categories of third-parties with whom we shared that information. Please see our Provisions for California Residents below for a more complete description of your rights as a California State resident.
GDPR and CASL Compliance.
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 firstname.lastname@example.org and we will remove and destroy your Personal Information.
Revised Posting Date: FEBRUARY 1, 2020
Privacy Notice for California Residents
Categories of Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or device ("personal information"). In particular, we have collected the following categories of personal information from Users within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, postal 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 number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics 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 or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a CA User's interaction with a website, application or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Personal information does not include:
Publicly available information from government records.
De-identified or aggregated User information.
Information excluded from the CCPA's scope, such as:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from our Users. For example, from online registration forms that our Users submit to us related to the products and/or services that we (and our third party service providers) offer by and through the Site.
Indirectly from our Users. For example, through information we collect from our Users in the course of providing our products and/or services to them.
Directly and indirectly from activity on the Site. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third party partners.
From third-parties that interact with us in connection with the products and/or services that we offer to our Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from User lists, analyzing data and providing marketing analysis.
From third-party data brokers or aggregators.
From publicly availably sources, such as Internet search engines.
Use of Personal Information
We may use or disclose the personal information that we collect for one or more of the following business purposes:
To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your request for information regarding your eligibility for Section 8 housing benefits, as well as information regarding the other products and/or services featured on the Site, we will use that personal information to better provide you with the requested information.
To provide you with information, products or services that you request from us.
To create, maintain, customize and secure your account with us.
To provide you with e-mail, direct mail and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you.
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site's Terms and Conditions.
To improve the Site and better present its contents to you.
For customer service purposes and to respond to inquiries from you.
For testing, research, analysis and product development.
As necessary or appropriate to protect our rights, property or safety, and that of our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
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.
Third parties who provide the products and/or services featured on the Site.
Third parties who purchase and/or license your personal information for marketing purposes, including: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. If a third party purchaser of your personal information wants to resell it, that purchaser is required by law to provide you with explicit notice and an opportunity to opt-out of further sales.
Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you.
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 have shared that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.
Sharing Personal Information
Subject to your right to opt-out of such sharing/sale, we may share, rent and/or sell your personal information with/to third parties for marketing purposes, as well as other business purposes. When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have sold the following categories of personal information to third parties:
In the preceding twelve (12) months, we have sold the above referenced categories of personal information to the third parties who purchase and/or license your personal information for marketing purposes, as well as the third parties who provide the products and/or services featured on the Site.
Your Rights and Choices
The CCPA provides Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Opt-Out from the Sale of Your Personal Information
You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable User request by mailing us at: email@example.com.
We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable User request, we will disclose to you:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech rights, ensure the right of another User to exercise their free speech rights or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with User expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability and Deletion Rights
To exercise your access, data portability and/or deletion rights described above, please submit a verifiable User request emailing us at: firstname.lastname@example.org.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable User request related to your personal information.
You may only make a verifiable User request for access or data portability twice within a 12-month period. The verifiable User request must:
Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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 that the personal information relates to you. Making a verifiable User request does not require you to create an account with us. We will only use personal information provided in a verifiable User request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to all verifiable User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (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 receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; and/or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to this Privacy Notice
We reserve the right to amend this Privacy Notice in our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on the Site's homepage.