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Privacy Policy

Last updated: July 7, 2021

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Website and tells You about Your privacy rights and how the law protects You. If You are a California resident, You can learn about your rights under California law in the section of this Privacy Policy below called “CCPA Privacy”.
We use Your Personal data to provide and improve the Website. By using the Website, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation

 

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

 

Definitions

For the purposes of this Privacy Policy:

 

  • ACCOUNTS means a unique account created for You to access our Website or parts of our Website.

 

  • BUSINESS, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

 

  • COMPANY (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to COMPEO, 225 E Dania Beach Blvd, Suite 120, Dania Beach, FL 33004. This Policy applies to all of Our operating divisions, subsidiaries, affiliates, and branches, and any additional subsidiary, affiliate, or branch of the Company that we may subsequently form.

 

  • CONSUMER, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

 

  • COOKIES are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

 

  • COUNTRY refers to: United States of America

 

  • DEVICE means any device that can access the Website such as a computer, a cellphone or a digital tablet.

 

  • DO NOT TRACK (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

 

  • PERSONAL DATA is any information that relates to an identified or identifiable individual.
    For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

 

  • SALE, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.

 

  • WEBSITE refers to the Website.

 

  • WEBSITE PROVIDER means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Website, to provide the Website on behalf of the Company, to perform services related to the Website or to assist the Company in analyzing how the Website is used.

 

  • USAGE DATA refers to data collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).

 

 

  • YOU means the individual accessing or using the Website, or the company, or other legal entity on behalf of which such individual is accessing or using the Website, as applicable.

Types of Data Collected

 

Personal Data

 

While using Our Website, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

 

– Email address

 

– First name and last name

 

– Phone number

 

– Address, State, Province, ZIP/Postal code, City

 

– Usage Data

 

Usage Data

 

Usage Data is collected automatically when using the Website.

 

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

 

When You access the Website by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

 

We may also collect information that Your browser sends whenever You visit our Website or when You access the Website by or through a mobile device.

 

Cookies

 

Cookies are small files that a website may transfer to a user’s computer that reside there for either the duration of the browsing session (session cookies) or on a permanent (until deleted) basis (persistent cookies) that may be used to identify a user, a user’s machine, or a user’s behavior. We make use of cookies under the following circumstances and for the following reasons

  •  
  • – Provide you with services available through the website and to enable you to use some of its features.
  •  
  • – Authenticate users and prevent fraudulent use of user accounts.
  •  
  • – Identify if users have accepted the use of cookies on the website
  •  
  • – Compile data about website traffic and how users use the website to offer a better website experience.
  •  
  • – Understand and save visitor preferences for future visits, such as remembering your login details or language preference, to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the website.
  •  
  • – Track your browsing habits to enable us to show advertising which is more likely to be of interest to you, including advertising by third parties on our website.

 

Use of Your Personal Data

 

The Company may use Personal Data for the following purposes:

  •  
  • –  TO PROVIDE AND MAINTAIN OUR WEBSITE, including to monitor the usage of our Website. This includes managing Individual information and accounts; respond to questions, comments, and other requests; provide access to certain areas, functionalities, and features of our Websites; and answer requests for customer or technical support.
  •  
  • –  TO ADMINISTER OUR WEBSITE, including measure interest and engagement in our Website and Websites; conduct research and development; improve our products and Websites; develop new products and Websites; ensure internal quality control; and verify Individual identity. We will communicate with you about your account, activities on our Website and Websites and policy changes. Process your financial information and other payment methods for products or Websites purchased; process applications and transactions; prevent potentially prohibited or illegal activities; and enforce our terms and agreements.
  •  
  • –  FOR THE PERFORMANCE OF A CONTRACT: the development, compliance and undertaking of the client service agreement for the products, items or services You have purchased or of any other contract with Us through the Website.
  •  
  • –  TO CONTACT YOU: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  •  
  • –  TO PROVIDE YOU with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  •  
  • –  TO MANAGE YOUR REQUESTS: To attend and manage Your requests to Us
  •  
  • –  TO DELIVER TARGETED ADVERTISING TO YOU: We may use Your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.
  •  
  • –  TO MARKET OUR PRODUCTS AND WEBSITES: To provide you with materials about offers, products, and Websites that may be of interest, including new content or Websites. We may provide you with these materials as permitted by applicable law. Such uses include: to tailor content, advertisements, and offers; to notify you about offers, products, and services that may be of interest to you; to provide Websites to you and our sponsors; and other purposes you consent to or are disclosed when you provide Personal Data You may contact us at any time to opt out of the use of your Personal Data for marketing purposes as described below.
  •  
  • –  FOR BUSINESS TRANSFERS: We may use Your information 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 Data held by Us about our Website users is among the assets transferred.
  •  
  • –  TO OBTAIN SURVEYS AND REVIEWS: To participate in surveys and reviews. If you decide to participate, you may be asked to provide certain information which may include Personal Data.
  •  
  • –  TO POST: We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
  •  
  • –  CHAT/MESSAGING: If you participate in chats with or message COMPEO, COMPEO customer service representatives, or other COMPEO representatives through our Websites, any Personal Data disclosed in those chats or messages may be collected.

 

By providing your phone number, you are agreeing to receive text messages from COMPEO and its affiliates.

 

By providing the phone number of your employees to us, you hereby explicitly agree that you have obtained all prior approval from and grant us explicit permission to text message your employees.

 

You and your employees may receive text messages about our services, including but not limited to onboarding, program reminder, updates and notifications, and marketing material. We may send text messages relating to the services up to three times per day.

 

You can opt out of receiving text messages at any time by texting [STOP] to [(855) 516 – 2133].

 

By providing your phone number, you agree to the terms of this disclosure, and you agree to indemnify COMPEO and its affiliates from any and all claims and litigation, including the TCPA, arising as a result.

 

You agree to indemnify and hold harmless COMPEO and its officers, directors, employees, agents and affiliates (collectively, “COMPEO”), from and against any and all claims, losses, damages, liabilities, costs, and expenses (including reasonable attorneys’ fees and costs) arising out of or in connection with any text messages sent by COMPEO to you or your employees, including but not limited to claims of TCPA violations, claims of violations of other state or federal laws or regulations, claims of defamation, invasion of privacy, or other common law torts.

 

You shall defend COMPEO at your expense against any such claims and shall pay any damages or costs awarded against COMPEO in connection with such claims.This indemnity clause shall survive the termination of this Agreement and shall remain in full force and effect.

 

  • –  REGISTRATION FOR SWEEPSTAKES OR CONTESTS: We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
  •  
  • –  DE-IDENTIFIED AND AGGREGATED INFORMATION USE: We may use Personal Data and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Website and Websites, or other analyses we create. De-identified or aggregated information is not Personal Data, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
  •  
  • –  DIRECT MAIL, EMAIL AND OUTBOUND TELEMARKETING: Individuals who provide us with Personal Data, or whose Personal Data we obtain from Third Parties, may, as permitted by law, receive periodic emails, newsletters, mailings or phone calls from us with information on COMPEO’s products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in the Section “Exercising Your CCPA Data Protection Rights”.
  •  
  • –  SHARING CONTENT WITH FRIENDS OR COLLEAGUES. COMPEO’s Website and Websites may offer various tools and functionalities. For example, COMPEO allows you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Websites. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by COMPEO or any other third parties for any other purpose.
  •  
  • –  FOR OTHER PURPOSES: COMPEO may use Personal Data to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, and fraud prevention, or any other purpose disclosed to you at the time you provide Personal Data or with your consent. We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, services, marketing and your experience. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Websites.

 

We may share Your Personal Data in the following situations:

  •  
  • –  WITH WEBSITE PROVIDERS: We may share Your Personal Data with Website Providers to monitor and analyze the use of our Website, to show advertisements to You to help support and maintain Our Website, to advertise on third party websites to You after You visited our Website, for payment processing, to contact You.
  •  
  • –  FOR BUSINESS TRANSFERS: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  •  
  • –  WITH AFFILIATES: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  •  
  • –  WITH BUSINESS PARTNERS: We may share Your information with Our business partners to offer You certain products, services or promotions.
  •  
  • –  WITH OTHER USERS: when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  •  
  • –  WITH YOUR CONSENT: We may disclose Your Personal Data for any other purpose with Your consent
  •  

Retention of Your Personal Data

 

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Website, or We are legally obligated to retain this data for longer time periods.

 

Transfer of Your Personal Data

 

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

 

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

 

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal Data.

 

Disclosure of Your Personal Data

 

Business Transactions

 

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

 

Law enforcement

 

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

Other legal requirements

 

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  •  
  • –  Comply with a legal obligation
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  • –  Protect and defend the rights or property of the Company
  •  
  • –  Prevent or investigate possible wrongdoing in connection with the Website
  •  
  • –  Protect the personal safety of Users of the Website or the public
  •  
  • –  Protect against legal liability

 

Security of Your Personal Data

 

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

The Website Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Website in accordance with their Privacy Policies.

 

Analytics

We may use third-party Website providers to monitor and analyze the use of our Website.

 

  • – GOOGLE ANALYTICS, GA AUDIENCE, GOOGLE TAG MANAGER, LIVECHAT
    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

    You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

    For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
    Information: https://policies.google.com/technologies/partner-sites
    Opt-Out: http://tools.google.com/dlpage/gaoptout

 

Advertising

We may use Website Providers to show advertisements to You to help support and maintain Our Website.

 

  • – GOOGLE ADSENSE & DOUBLECLICK COOKIE
    Google, as a third party vendor, uses cookies to serve ads on our Website. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Website or other websites on the Internet.

    You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

 

 

 

 

 

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

 

We may use Email Marketing Website Providers to manage and send emails to You.

 

 

Payments

We may provide paid products and/or services within the Website. In that case, we may use third-party services for payment processing (e.g. payment processors).

 

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your Personal Data is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

 

 

 

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or visited our Website. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Website so that We can improve our Website to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

 

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Website in accordance with their Privacy Policies and to enable Us to:

 

  • – Measure and analyze traffic and browsing activity on Our Website

 

  • – Show advertisements for our products and/or services to You on third-party websites or apps

 

  • – Measure and analyze the performance of Our advertising campaign

 

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

 

 

 

 

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information

 

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Website with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

 

The third-party vendors We use are:

 

  • – GOOGLE ADS (ADWORDS)
    Google Ads (AdWords) remarketing service is provided by Google Inc.

    You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

    Google also recommends installing the Google Analytics Opt-out Browser Add-on – http://www.google.com/settings/ads – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

    For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

 

 

 

 

 

 

Operationally Necessary

This includes Technologies that allow you access to our Website, Websites, applications and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as saved search or similar functions.

 

Performance Related

We may use Technologies to assess the performance of our Websites, including as part of our analytic practices to help us understand how our visitors use the Websites.

 

Functionality Related

We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Website and Websites. This may include identifying you when you sign into our Website or Websites or keeping track of your specified preferences, interests, or past items viewed

 

Advertising or Targeting Related

We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Website and Websites or on third party sites.

 

Third Party Websites/Applications, Social Media Platforms and Software Development Kits

Websites may contain links to other websites/applications and other websites/applications may reference or link to our Website or other Websites. These other websites and applications are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

 

We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Websites. APIs and SDKs may allow third parties including advertising partners to collect your Personal Data to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Data Collected

The following is a list of categories of Personal Data which we may collect or may have been collected from California residents within the last twelve (12) months.

  • – CATEGORY A: IDENTIFIERS.
    Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
    Collected: Yes.
  • – CATEGORY B: PERSONAL INFORMATION CATEGORIES LISTED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE (CAL. CIV. CODE § 1798.80(E)).
    Examples: A name, signature, Social Security number, physical characteristics or description, 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.
    Collected: Yes.
  • – CATEGORY C: COMMERCIAL INFORMATION.
    Examples: Records and history of products or services purchased or considered.
    Collected: Yes.
  • – CATEGORY D: INTERNET OR OTHER SIMILAR NETWORK ACTIVITY.
    Examples: Interaction with our Website or advertisement.
    Collected: Yes.
  • – CATEGORY E: NON-PUBLIC EDUCATION INFORMATION (PER THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (20 U.S.C. SECTION 1232G, 34 C.F.R. PART 99)).
    Examples: 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.
    Collected: No
  • – CATEGORY F: INFERENCES DRAWN FROM OTHER PERSONAL DATA.
    Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
    Collected: No.

Sources of Personal Data

We obtain the categories of Personal Data listed above from the following categories of sources:

  • – DIRECTLY FROM YOU. For example, from the forms You complete on our Website, preferences You express or provide through our Website on our Website.
  • – INDIRECTLY FROM YOU. For example, from observing Your activity on our Website.
  • – AUTOMATICALLY FROM YOU. For example, through cookies We or our Website Providers set on Your Device as You navigate through our Website.
  • FROM WEBSITE PROVIDERS . For example, third-party vendors to monitor and analyze the use of our Website, third-party vendors to provide advertising on our Website, third-party vendors to deliver targeted advertising to You, third-party vendors for payment processing, or other third-party vendors that We use to provide the Website to You.

Share of Personal Data

We may share Your Personal Data identified in the above categories with the following categories of third parties

  • – Our affiliates
  • – Our business partners
  • – Third party vendors to whom You or Your agents authorize Us to disclose Your Personal Data in connection with products or services We provide to You
  • – Government agencies

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their Personal Data. If You are a resident of California, You have the following rights:

  • – RIGHT TO KNOW. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months;
  • – RIGHT TO ACCESS. The right to request, up to 2 times in a 12-month period, that we provide you access to or disclose to you, free of charge, the specific pieces of personal information we have collected about you in the last 12 months;
  • – RIGHT TO DELETE. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
  • – RIGHT TO OPT-OUT. The right to opt-out of the sale of your personal information to third parties;
  • – The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and
  • The right to not be discriminated against in receiving different or less favorable pricing, service or financial incentive for exercising any of the above rights.

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

  • – Call our privacy toll-free line at (855) 271-2664

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your Personal Data.

Your request to Us must:

  • – Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Data 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 the required information if we cannot:

  • – Verify Your identity or authority to make the request.
  • – And confirm that the Personal Data relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Data

You have the right to opt-out of the sale of Your Personal Data. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your Personal Data. To exercise Your right to opt-out, please contact Us.

The Website Providers we partner with (for example, our analytics or advertising partners) may use technology on the Website that sells Personal Data as defined by the CCPA law. If you wish to opt out of the use of Your Personal Data for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Website Providers by following our instructions presented on the Website:

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

  • – “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
  • – “Limit Ad Tracking” on iOS devices
  •  

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Data Collected

The following is a list of categories of Personal Data which we may collect or may have been collected from California residents within the last twelve (12) months.

  • – CATEGORY A: IDENTIFIERS.
    Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
    Collected: Yes.
  • – CATEGORY B: PERSONAL INFORMATION CATEGORIES LISTED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE (CAL. CIV. CODE § 1798.80(E)).
    Examples: A name, signature, Social Security number, physical characteristics or description, 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.
    Collected: Yes.
  • – CATEGORY C: COMMERCIAL INFORMATION.
    Examples: Records and history of products or services purchased or considered.
    Collected: Yes.
  • – CATEGORY D: INTERNET OR OTHER SIMILAR NETWORK ACTIVITY.
    Examples: Interaction with our Website or advertisement.
    Collected: Yes.
  • – CATEGORY E: NON-PUBLIC EDUCATION INFORMATION (PER THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (20 U.S.C. SECTION 1232G, 34 C.F.R. PART 99)).
    Examples: 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.
    Collected: No
  • – CATEGORY F: INFERENCES DRAWN FROM OTHER PERSONAL DATA.
    Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
    Collected: No.

Sources of Personal Data

We obtain the categories of Personal Data listed above from the following categories of sources:

  • – DIRECTLY FROM YOU. For example, from the forms You complete on our Website, preferences You express or provide through our Website on our Website.
  • – INDIRECTLY FROM YOU. For example, from observing Your activity on our Website.
  • – AUTOMATICALLY FROM YOU. For example, through cookies We or our Website Providers set on Your Device as You navigate through our Website.
  • FROM WEBSITE PROVIDERS . For example, third-party vendors to monitor and analyze the use of our Website, third-party vendors to provide advertising on our Website, third-party vendors to deliver targeted advertising to You, third-party vendors for payment processing, or other third-party vendors that We use to provide the Website to You.

Share of Personal Data

We may share Your Personal Data identified in the above categories with the following categories of third parties

  • – Our affiliates
  • – Our business partners
  • – Third party vendors to whom You or Your agents authorize Us to disclose Your Personal Data in connection with products or services We provide to You
  • – Government agencies

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their Personal Data. If You are a resident of California, You have the following rights:

  • – RIGHT TO KNOW. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months;
  • – RIGHT TO ACCESS. The right to request, up to 2 times in a 12-month period, that we provide you access to or disclose to you, free of charge, the specific pieces of personal information we have collected about you in the last 12 months;
  • – RIGHT TO DELETE. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
  • – RIGHT TO OPT-OUT. The right to opt-out of the sale of your personal information to third parties;
  • – The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and
  • The right to not be discriminated against in receiving different or less favorable pricing, service or financial incentive for exercising any of the above rights.

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

  • – Call our privacy toll-free line at (855) 271-2664

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your Personal Data.

Your request to Us must:

  • – Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Data 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 the required information if we cannot:

  • – Verify Your identity or authority to make the request.
  • – And confirm that the Personal Data relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Data

You have the right to opt-out of the sale of Your Personal Data. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your Personal Data. To exercise Your right to opt-out, please contact Us.

The Website Providers we partner with (for example, our analytics or advertising partners) may use technology on the Website that sells Personal Data as defined by the CCPA law. If you wish to opt out of the use of Your Personal Data for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Website Providers by following our instructions presented on the Website:

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

  • – “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
  • – “Limit Ad Tracking” on iOS devices
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You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Our Website does not respond to Do Not Track signals.

 

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Our Website does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

 

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

 

If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request.

 

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

 

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Our Website may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

 

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

 

We will let You know via email and/or a prominent notice on Our Website, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

 

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.