Last Updated: December 31, 2019
Personal, Business and Financial Data
The Company collects personal information when you visit the Website. Much of this information is collected during the registration and/or application process and, while some items are optional, some are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Website; in some cases, this additional information will be required by us as a condition of your availing yourself of the Company’s goods or services, or your continued use of the Services.
Generally, the type of information we collect includes, but is not limited to:
• Data required to verify your identity;
• Personal and financial data necessary to assess your eligibility to utilize the Services on the Website; and
• Non-identifiable and aggregated personal data pertaining to your Website visits that help the Company evaluate and maintain quality control with respect to the features, functionality and user experience of the Website.
Registration pages and forms will require you to provide basic personal and/or business data. This typically includes your name, email address, home/business address and phone number. The Company uses this data to: (i) enable you to register with, log in and return to the Website; (ii) establish your eligibility to utilize the Company’s goods and services; (iii) verify your age; (iv) guard against potential fraud; and, (v) contact you if we would like to reach you; and (vi) maintain regular and reliable communications with you regarding interest in Company activities and related matters.
We also gather the names and email addresses of users and visitors who contact us through the Website with questions about the Company, the Website or the Services. We collect this information for the sole purpose of responding to such inquiries and improving the Website and the Services; we generally do not store the contact information unless requested to do so, as in the case of job applicants who submit resumes.
Other Personal Data
The Company and its service providers may also collect web surfing data related to your use of the Website. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Website. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. We may use this aggregated information in the administration of the Website to improve its usability and to evaluate the success of particular marketing and advertising campaigns. We also use it to help optimize the Website based on the needs of our users.
Sharing of Personal Information
We do not sell or rent personal information about our users for marketing purposes. We do, however, work with a number of trusted partners who perform vital functions as part of our operations.
In submitting an inquiry relating to our Services, Website and/or Company, you agree that we may share your information with other third parties such as our clients (including, for example, cable companies, telecommunication companies, energy companies and other affiliates), the Company’s affiliates, consultants and subcontractors in order to respond to inquiries, investigations or requests for Services. Please note that the clients with which your information is shared may retain or use your information whether or not you use their services. You should contact these clients directly concerning their privacy and information sharing practices.
Additional Sharing of Information
We also may work with (among others) providers of hosting services for the Website, electronic signature providers, and electronic payment service providers. We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Website or our services, or to protect the rights, property or personal safety of the Company, its users, issuers, or others.
Notifications and Communications from Our Website
The Company will send you email notifications from time to time. Some notifications are required elements of your transactions on our Website, such as confirmations of particular actions you have taken.
We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your account without your knowledge. In other cases, these notifications may involve changes to various legal agreements or Website policies about which we would like to inform you. Generally, you may not opt out of such service-related emails.
When you apply for Company goods and services, you will receive emails that confirm specific actions you requested. These may include emails to which you must respond to complete your registration and notifications confirming your application and, perhaps, requesting additional or supporting information.
We may also send you responses to emails you send us, if appropriate. From time to time, we will also send user surveys, requests for user feedback regarding user experience and Website operations, or marketing offers from us or from us on behalf of our marketing partners. Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary. If you do not wish to receive these surveys, user feedback emails, and/or marketing offers, please opt out in any offer email you receive from us.
Questions on Your Information
Links to Other Sites
Information We Collect
Real names, aliases, postal addresses, email addresses, phone numbers, unique personal identifier, online identifier, Internet Protocol address, account information, or other similar identifiers
(2) Commercial Information
Products or services purchased, obtained or considered, or other purchasing or consuming history or tendencies
(3) Internet or other similar network activity
Information on your interaction with the Company and Website, including, but not limited to, browsing history and search history
(4) Geolocation data
Physical location, generally
(5) Inferences drawn from other personal information
Profiles reflecting a persons’ preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes
(6) Professional or employment-related information.
Current or past job history or performance evaluations.
We may obtain the categories of personal information listed above from the following categories of sources:
- Directly from you: For example, from forms/surveys you complete, information you input into the Website, and any other communications between you and the Company.
- May apply to the following categories: (1), (2), (4) and (6)
- Indirectly from you: For example, from observing your actions on the Website.
- May apply to the following categories: (1), (3), (4) and (5)
- Publicly available databases.
- May apply to the following categories: (1) and (6)
Use of Personal Information
- Performing Services. For example, we will use the personal information you submit through our website to help us provide you with information, products or services that you request from us; in addition, we will use your information to customize our Services for you, including building campaigns, hosting our Website, managing databases, performing analyses, and marketing services.
- Providing you email alerts and other notices concerning our Services and job positions that may be of interest to you.
- Auditing interactions with users. For example: monitoring traffic to our Website, counting ad impressions, investigating feedback related to our Services, and auditing legal and regulatory compliance.
- Security. For example, maintaining the safety, security, and integrity of our Website and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations.
- Debugging/Repair. For example, identifying and repairing errors in our Website's functionality.
- Certain Short-term Uses. For example, ad customization that does not involve or contribute to profiling.
- Internal Research for Tech Development. For example, testing, research, analysis, and product development, including to develop and improve our Website and Services.
- Quality and Safety Maintenance and Verification. For example, improving, upgrading or enhancing our Services or Website, verifying the quality or safety of our Website or Services, and conducting investigations into the quality of our Services.
- Other Commercial Purposes. For example, as described to you when collecting your personal information resulting in a commercial transaction with our clients and/or 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.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose described above. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for performing the contract.
We may disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- May apply to the following categories: (1), (2), (3), (4), (5) and (6)
- Our clients.
- May apply to the following categories: (1), (2) and (4)
- Our subcontractors.
- May apply to the following categories: (1) and (2)
- Our Service Providers (as defined under the CCPA) that help us perform the Services offered by the Website.
- May apply to the following categories: (1), (2), (3), (4), (5) and (6)
We do not, and will not, sell any personal information. As a result, in the preceding twelve (12) months, we have not sold any personal information. Your Rights and Choices
The CCPA provides California residents with the additional rights listed below:
- Right to Know. You have the right to know and see what data we have collected, used, disclosed, and sold about you over the past 12 months, including:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting your personal information;
- The categories of third parties with whom we have shared your personal information; and
- The specific pieces of personal information we have collected about you.
- Right to Delete. You have the right to request that we delete the personal information we have collected from you. There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
- Complete your transaction;
- Provide you a good or service;
- Perform a contract between us and you;
- Protect your security and prosecute those responsible for breaching it;
- Fix our system in the case of a bug;
- Protect the free speech rights of you or other users;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
- Comply with a legal obligation; or
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
- Other Rights. You also have the right not to be discriminated against for exercising any of the rights listed above.
Exercising Your California Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under California law, or to discuss any questions or comments you have about our privacy policies and practices, please contact us by email at [email protected] You may write to us to exercise rights. Please include your full name, email address, and phone number, along with why you are writing, so that we can verify your identity and process your request in an efficient manner. If we are not able to verify your identity based on the information you have provided, we may ask you for additional information. 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. 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. If you choose to submit a request using an authorized agent, we may require that you provide your authorized agent with written permission to make a request on your behalf, and that you verify your identify directly with us. We may deny a request from an agent that does not submit proper proof of authorization.
The Website may be accessed by users located outside the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States, and that by providing your personal information on or through the Website then you consent to that transfer.
We limit access to the personal information we have about you to those employees who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. The Website is built upon a secure infrastructure with multiple layers of protection, and we use industry-standard encryption technologies to safeguard your information.
Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Website. Generally, identification and authentication take place through the use of your username and a password and/or while logging in with one of our technical support staff.
Notifications of Security Systems Breach
If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Website in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Take Precautionary Measures
You can take several precautions to protect the security of your computer and personal information. For instance, you can use a strong password and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on the Website, be sure that you log out and close the browser window.
You should also be aware of fraudulent attempts to gain access to your account information through "phishing," whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake site, scammers will ask for login information to gain access to people's accounts and withdraw their money.
We will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go the website directly from your browser’s home page.
ATTENTION KIDS: No information should be submitted to the Company by children under 18 years of age without their parent's or guardian's consent. The Company does not monitor the age of its user audience.
The Company reserves the right to change this policy at any time by posting notice of the existence of a new privacy statement. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any party.