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. Please see our Provisions for California Residents below for a more complete description of your rights as a California State resident.
- Information We Collect
- No Information Collected from Minors
- How We Use Information Collected
- Information Security and Retention
- Deleting, Modifying and Updating Your Information
- Contact Us
1. Information We Collect
[Please see our Provisions for California Residents below for additional details regarding the categories of Personal Information collected. 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) 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.
“Third party collected information” is information about you that we acquire from a third party which may include personal, demographic, behavioral and indirect information. This collection may include, but not limited to, first party cookies, third party cookies, anonymous cookies, persistent identifiers, email opt in, and search engine keywords. We have no access or control over these cookies and other tracking devices used by data aggregators or advertisers.We have no responsibility or liability for the policies and practices of these parties.
2. No Information Collected from Minors
We will never knowingly collect any Personal Information from individuals under eighteen (18) years of age. If we obtain actual knowledge that we have collected Personal Information about an individual under eighteen (18) years of age, that information will be immediately deleted from our database. Because we do not collect such information.
Generally, we use technologies such as cookies, web beacons and java scripts to collect information automatically from Website visitors. 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.
Proprietary Auto-Fill Tracking. At times, we use third-party vendors who have technology that collects information held in your browser’s auto-fill functionality This collection allows them to notify you of an error in the registration or a failure to submit the registration. You can stop this functionality by turning it off in your browser. There is no loss of use of our Website or services should this browser function be turned off.
4. How We Use Information Collected
[Please see our Provisions for California Residents below for additional details regarding our uses of Personal Information]
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 from us. After you visit one of our client’s websites, we use the information we have collected during your visit to our Website 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.
Targeted Advertising. We may customize and target advertising to an individual. In our discretion, we may combine information to target advertising to an individual on our Website, in email and/or through direct mail. Such advertising may be different than the products or services offered or promoted on our Website.
Commercial Email. We may use your email address to promote our goods and services that we think may be of interest to you and these may be different than the products or services offered or promoted on our Website.
Direct Mail. We may use Personal Information to advertise our goods and services to individuals using postal mail.
Telemarketing. By submitting your Personal Information by and through the Website, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.
5. 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. Where our registration/application process prompts users to enter sensitive information (such as medical information, driver’s license/ID card number, health insurance information, data collected from an automated license plate recognition system, Social Security Number and credit card information), and when we store and transmit such sensitive information, that information is encrypted with advanced TLS (Transport Layer Security). 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. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your Personal Information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
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.
[Please see our Provisions for California Residents below.To opt-out of receiving e-mail and other forms of communication from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; (b) follow the instructions on our unsubscribe page; or (c) e-mail us at: firstname.lastname@example.org.
Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for our offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving messages from us relating to your request for our offerings and/or inquiries, you must cease requesting and/or utilizing our offerings and/or cease submitting inquiries to us, as applicable.
8. Deleting, Modifying and Updating Your Information
[Please see our Provisions for California Residents below for instructions on how California Residents can access and/or delete Personal Information that we have collected] At your request, we will: (a) inform you of what Personal Information we have on file for you; (b) amend the Personal Information that we have on file for you; and/or (c) remove Personal Information that you have provided to us, or that we have otherwise collected. You may do so by emailing us at: email@example.com. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
Please be advised that deleting your Personal Information may terminate your access to certain of our offerings. If you wish to continue using the full complement of our offerings, you may not be able to delete all of the Personal Information that we have on file for you.
Please be further advised that, after you delete your Personal Information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
Transfer of Personal Information Internationally
GDPR and CASL Compliance.
Unfortunately, we are not in a position to accept clients who are not U.S. Citizens. Canada’s Anti-Spam Legislation (“CASL”) and the EU General Data Protection Regulation (“GDPR”) regulations, in particular, provide certain rights to their respective citizens which are not the same as those granted to citizens of the United States. For this reason, we do not accept referrals from any citizens outside of the United States. Our services are specifically designed for United States citizens. We have expunged all European Union Member State resident data and Canadian Citizen data from our database to the extent we have been made aware of same. If you are a resident of a European Union Member, a Canadian citizen or a citizen of any country outside of the United States, please notify us at firstname.lastname@example.org and we will remove and destroy your Personal Information.
9. CONTACT US
Privacy Provisions 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 CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA 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|
|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|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated CA 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 (as indicated in parenthesis) from the following categories of sources:
- Directly from our CA Users. For example, from online registration forms that our CA Users submit to us related to the products and/or services that weoffer by and through the Website. (Category A, B, C and I)
- Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Category A, B, C, F and I)
- Directly and indirectly from activity on the Website. 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 Website usage details and analytics as same are collected automatically by us. (Category F)
- From publicly availably sources, such as Internet search engines. (Finance, Housing Services, Health, Employment Services, Auto, Travel, Contests, Politics and others)
Use of Personal Information
We may use or disclose the personal information that we collect (including; Name, last name, address, zip code, phone number, email, gender, health conditions, debt, financial information, vehicle information, private insurance, housing information, declared personal interests, political affiliation, behavioral information and others) 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 Website, we will use that personal information to better provide you with the requested information. (Category A, B, C, F and I)
- To provide you with information, products or services that you request from us. (Category A, B, C, F and I)
- To create, maintain, customize and secure your account with us. (Category A, B, C, F and I)
- To provide you with e-mail, direct mail and telemarketing messages concerning certain Company products and/or services that we believe may be of interest to you. (Category A, B, C, F and I)
- To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Category A, B, C, F and I)
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Website’s Terms and Conditions. (Category A, B, C, F and I)
- To improve the Website and better present its contents to you. (Category A, B, C, F and I)
- For customer service purposes and to respond to inquiries from you. (Category A and BI)
- For testing, research, analysis and product development. (Category A, B, C, F and I)
- As necessary or appropriate to protect our rights, property or safety, and that of our clients or others. (Category A, B, C, F and I)
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Category A, B, C, F and I)
- As described to you when collecting your personal information or as otherwise set forth in the CCPA. (Category A, B, C, F and I)
- 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. (Category A, B, C, F and I)
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.
Your Rights and Choices
The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to opt-out of our communications.
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 CA User request, we will disclose 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 specific pieces of personal information we collected about you (also called a data portability request).
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 CA 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 CA 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 CA 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 CA User request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.
You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA 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 CA User request does not require you to create an account with us. We will only use personal information provided in a verifiable CA 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 CA 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 CA 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 these Privacy Provisions
We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Website’s homepage.
Revised Posting Date: June 28th, 2022