Privacy Policy

Effective Date: 06-19-2023

This Privacy Policy has been designed to set out our consumer information collection and processing practices related to personal information in the course of our business. This policy does not apply to our employees or business associates. Please review fully as this policy effects your rights and our use of your Personal Information and advises you how to access or delete your personal information. We may change this policy at any time by posting changes on this page with no further notice to you.

Personal Information We Collect

Information You Provide to Us

Customer Service and Support. If you contact us directly for any reason, we may collect the information you provide to our representatives.

Direct Registration or Surveys. If you directly register for our services or participate in a survey, we are running or providing for a third party we will collect the information you provide.

Information We Collect Through Your Use of the Services

Collection during use of our Services. We may collect certain information automatically when you interact with our services and emails. This information may include your Internet protocol (IP) address, cookie identifiers, mobile carrier, and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, the device you used to access our emails or website including information about the links you click, information about how you interact with the marketing, including the frequency and duration of your activities and this information may be associated with accounts and other devices.

Cookies, Pixel Tags/Web Beacons, and Analytics collection. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. These technologies are small data files placed on your device by us and third parties that allow us and our clients or service providers to record certain pieces of information whenever you visit or interact with our services.

• Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. We use the following cookie types:
  • Operationally Necessary. This includes Technologies run our services and take note of or correct irregular behavior to prevent fraudulent activity and improve security;
  • Performance Related. We may use Technologies to assess the performance of our services, including as part of our analytic practices to help us understand how our visitors use the services or to be paid for our services. We may use Technologies that allow us to enhanced functionality. This may include identifying you when you open or click through our email keeping track of your actions after you arrive at one of client’s websites.
  • Advertising or Targeting Related. We may use Technologies to develop and deliver content, including ads relevant to your interests, through our services or on third party sites.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our emails or on our website that collects information about your engagement with our services or emails. A pixel will allow us to record your interaction including opening, clicking through an advertisement to the website and may also allow us to track your movements after you leave our services or our clients website. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
• Google Analytics. We use various ad services provided by Google that connects the activity on our Website with their advertising network and they may use cookies that collects information regarding certain patterns in your browsing history. To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google’s Analytics Advertising. This includes: (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) Google controlled Campaign Manager integration; and (iv) Google Analytics Demographics and Interest Reporting. Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis service. Google utilizes the data collected through its cookies to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-on here https://tools.google.com/dlpage/gaoptout/.

Information Collected From Other Sources

Our Clients. Our clients may provide us with your personal information in order to promote their services or third parties services through internet marketing. This may include an analysis of general characteristics you have shown through your interaction with tour client which allows us to undertake targeted behavior marketing.

Third Parties. We may obtain information about you from third parties who have placed your information with us including the site you registered at, the IP you used, the date and time of registration and any other information you may have provided to them. We use this information for legal compliance as well as our services to promote third party products and services.

How We Use Your Information

We use Personal Information to:

• Provide services to our clients;
• Provide services to and from third party vendors and service providers;
• Manage your information;

• Process payments to and from us;
• Respond to questions, comments, and other requests;
• Retain for records of legal compliance.

• Pursue legitimate interests, such as direct marketing, research, and development (including marketing research), network and information security, and fraud prevention;
• Measure interest and engagement in our services and our clients advertising;
• Develop of new products and services;
• Improve our products and Services;
• Verify individual identity;
• Secure our technology and database systems;
• Prevent and prosecute potentially prohibited or illegal activities;
• Enforce our agreements; and
• Comply with our legal obligations.

Targeted Behavioral Marketing

We may use personal information to build profiles of databases to tailor and provide content and advertisements which of are interest to a certain base of consumers; we may adjust our delivery schedule to a time when you are more likely to review; and we may use in the aggregate to promote our services.

De-identified and Aggregated Information Use

We may use personal information and other information about you to create de-identified and/or aggregated information, such as demographic information, location information, aggregated trends, reports, or statistics, or other analyses of our databases and services. De-identified and aggregated information is not personal information though it may be derived from personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

How We Disclose, Share, or Sell Your Information

Our Company and our Affiliates

We share information with our company’s employees, agents and service providers who may: (i) access your personal information and the contents of the communications and files associated with your account; and (ii) control and administer our client’s accounts. We may share personal information with our affiliated entities.

Service Providers

We may share any personal information we collect about you with our third party service providers. The types of service providers to whom we share personal information include service providers who: (i) provide support to the services such as suppression companies, hygiene companies, (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment processing; (v) customer service activities; and (vi) the provision IT and related services.

Business Clients

We may disclose, sell or share personal information to business clients and associates to provide advertising services to you or with whom we jointly offer services and products.

Interest-Based or Personalized Advertising. We and our clients also have access to Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These clients may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

Disclosures to Enforce Legal Rights

We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to collect amounts owed to us; (iv) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

How to Access and Control Your Personal Information.

Email Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email, and we will place your email address on a do not mail list which prevents further email communications from us or the advertiser that is in the body of the email.

Technologies and Personalized Advertising

If you would like to opt-out of the Technologies we utilize, you may do so by blocking, disabling, or deleting them as your browser or device permits. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.aboutads.info/choices/. Please note you must separately opt out in each browser and on each device.

“Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

CALIFORNIA RESIDENT’S RIGHTS

This Privacy Notice for California Residents supplements the information contained in our primary privacy policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and as amended and effective January 1, 2023, the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and CPRA have the same meaning when used in this Notice. The CCPA and CPRA are collectively referred to as the “CCPA” for purposes of this Notice.

California Privacy Choices

If you are a resident of California, and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

• RIGHT TO KNOW. The right to confirm whether we are processing Personal Information about you and to obtain certain personalized details about the Personal Information we collected about you, including:
  • The categories of Personal Information collected;
  • The categories of sources of the Personal Information;
  • The purposes for which we collected the Personal Information;
  • The categories of Personal Information disclosed to third parties, and the categories of recipients to whom we disclosed the Personal Information;
  • The categories of Personal Information shared for cross-context behavioral or targeted advertising purposes, and the categories of recipients to whom we disclosed the Personal Information for those purposes; and
  • The categories of Personal Information sold, and the categories of third parties to whom we sold the Personal Information.
• RIGHT TO CORRECT. The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information, and the purposes of processing the Personal Information.
• RIGHT TO DELETE. The right to have us delete the Personal Information we maintain about you, subject to additional exemptions.
• RIGHT TO CONTROL SENSITIVE PERSONAL INFORMATION. The right to exercise control over our collection and processing of Sensitive Personal Information.
• RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION. The right to direct us not to “sell” your Personal Information to third parties for monetary or other valuable consideration. You also have the right to direct us not to use your Personal Information for automated decision-making or profiling for certain purposes. The exception to this Right is our ability to disclose, share and sell your Personal Information to the third parties who provide to you the services and products you requested at registration.
• RIGHT TO PORTABILITY. The right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• RIGHT AGAINST DISCRIMINATION OR RETALIATION. You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.
• HOW TO EXERCISE YOUR RIGHTS. Submit your request to exercise one of the privacy rights identified above, as follows:
  • Submit your request using our web portal; or
  • Email us at: [email protected]

Before processing your request, we will need to verify your identity and confirm you are a resident of California. In order to verify your identity, we will generally either require the successful authentication of your email, or the matching of sufficient information you provide us to the information we maintain about you in our system. As a result, we require requests to include first and last name, phone number, email, street address, city, state, and zip code.

We will process requests to opt-out of sales within 10 business days, subject to any applicable exceptions and extensions permitted by law. We will process all other privacy requests within 45 days, subject to any applicable exceptions and extensions permitted by law.

In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of California, or where we are unable to verify your identity.

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either: (i) a valid power of attorney; or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you or the California Resident to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Retention of Personal Information

We retain Personal Information as long as is reasonably necessary to fulfill the purpose for which it was collected, as required by an applicable law, rule, regulation, or contractual provision. We will retain your Personal Information for the purposes of commercial marketing to you until you request, we cease further efforts to provide you such offers or in the event you request deletion of your Personal Information. To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

As such, we retain Personal Information for as long as you continue to use our Websites and/or Services for the purposes explained in our Privacy Policy. When you discontinue the use of our Websites or Services, we will retain your Personal Information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices you have made, such as to receive marketing communications. In particular, we will retain Personal Information provided, including complaints, claims, and any other Personal Information provided during the duration of your agreement with us for the Services until the statutory limitation periods have expired and the necessary for the establishment, exercise, or defense of legal claims.

Once retention of the Personal Information is no longer necessary for the purposes outlined above, we will either delete or de-identify the Personal Information or, if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from further processing until deletion or de-identification is possible.

Changes to Our Privacy Policy

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will post a notice of the update on our Site, or as otherwise required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.