PRIVACY & ADVERTISING POLICY
Revision: January 2023 Introduction
What personal data do we collect?
When ordering or registering on our site or app, emailing us, or talking to us over the phone, as appropriate, you may be asked to enter your name, email address, payment information, or other details to help you with your experience or to complete a transaction with us.
TRAFFIC DATA COLLECTED. We automatically track and collect the following categories of information, either through the Site or through third parties: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; (4) types of web browsers used to access the Site; and (5) other usage data (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Site. We also use “cookies” to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly, and to store your password so you do not have to re-enter it each time you visit the Site.
PERSONAL INFORMATION COLLECTED. In order for you to access certain premium services and to purchase products and services that we offer via the Site, we require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information: (1) Contact Data (such as your name, mailing address, and e-mail address); (2) Financial Data (such as your account or credit card number); and (3) Demographic Data (such as your zip code, age, and income). If you communicate with us by e-mail, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms, surveys, or contest entries, any information provided in such communication may be collected as Personal Information. You assume responsibility for the Personal Data of third parties published or shared though the Site and declare that you have the right to communicate or broadcast them, thus relieving the Company of all responsibility.
How long do we keep personal data?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
At any time, however, you may contact us to request that we delete all of your personal data.
Do you have to provide personal data to us?
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
When do we collect information?
We collect information (including personal data) from you when you fill out a form on our site, enter information on our site, communicate with us over the phone, email us, or otherwise enter into a transaction with us.
How do we use your personal data?
We may use the personal data we collect from you when you register, make a purchase, respond to a survey or marketing communication, browse the website, or use certain other site features in the following ways:
To provide our services to you and fulfill your requests of us.
To complete the transactions, you requested that we complete.
To send periodic emails regarding your order or other products and services.
To run ads or promotional materials.
To verify your qualifications for certain products or services and to bill you for products and services.
What is our legal basis for processing?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where you have provided consent for us to use your personal data.
Where we need to perform the contract, we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
How can you control our use of your personal data?
You may decline to provide us with personal data and/or decline to enter into transactions with us. You may also contact us at any time to request: to access your personal data, rectify your personal data, erase your personal data, or to opt-out of future communications from us.
In addition, you also have the right to lodge a complaint with data protection supervisory authorities, the identity of which may depend on your location.
How do we protect and store personal data?
Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the personal data confidential.
We implement a variety of security measures when a user enters, submits, or accesses their personal data to maintain the safety of your personal data.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
USER ABILITY TO ACCESS, UPDATE, AND CORRECT PERSONAL INFORMATION.
We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. At any time, you may email at email@example.com and: (a) review and update your Personal Information that we have already collected; (b) choose whether or not you wish for us to send you information about our Company, or promotional material from some of our partners; and/or (c) choose whether or not you wish for us to share your Personal Information with third parties.
Do we use ‘cookies’?
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If you disable cookies, some features will be disabled that make your site experience more efficient and some of our services will not function properly.
We may share your personal data with third parties in the following situations:
We may provide your personal data to our business partners, suppliers and subcontractors who provide services to us or where necessary to perform a service that you have requested (i.e. to process payment information that you provide to us).
We may provide data about your visit to analytics and search engine providers to help us improve and optimize our services. We generally only share this information in a form that does not directly identify you.
We may provide your personal data to our professional advisors (like lawyers, accountants, and financial advisors) if needed for our own professional advice.
We may provide your personal data to law enforcement or regulatory authorities if required under law.
We do not include or offer third-party products or services on our website.
We do use third-party services to provide part of our services such as a client dashboard and to run ads. We regularly review each third-party service provider’s privacy and advertising policy to ensure that they are up to date on all regulatory policies and procedures including audiences for credit, employment, or housing campaigns. You have an option to opt-out from any of the following third-party advertising
platforms. From time to time, we will add new third-party services to run ads only after a thorough examination of their advertising policies. See third-party vendor list here.
We provide audience targeting to a broad base not to discriminate the “protected classes” segment based on a person’s race, ethnicity, religion, beliefs, age, sexual orientation or practices, gender identity, disability, physical or mental health (including medical condition), parental status, marital status, zip
code, vulnerable financial status, voting status, membership in a trade union, criminal record, or name.
We, along with our third-party services, designate financial campaigns as “Special Ad Category.” Special Ad Category campaigns for credit, employment or housing opportunity ads have limited or unavailable targeting options. See third party disclosure here.
Consumer Financial Protection Bureau – digital marketing service provider
We are a digital marketing service provider that delivers advertisements to consumers on behalf of our clients across various platforms following the laws and regulations set forth by the Consumer Financial Protection Bureau (CFPB), strictly adhering to the Consumer Financial Protection Act (CFPA) including UDAAP prohibition. Our designation by the CFPB is a “service provider” and we will continue to monitor and examine our delivery channels to be fully compliant. We perform all duties pertaining to our designation as a service provider in full regulatory compliance with all strategies and final creatives clearly communicated and approved by our client. We do not perform any service provider duties without prior written consent and/or approval by our client.
California Consumer Privacy Act (CCPA) created an array of consumer privacy rights and business obligations with regard to the collection and sale of personal information which was amended and expanded by California Privacy Rights Act (CPRA). We regularly review our third-party vendors to ensure compliance: See CCPA/CPRA regulation here.
The right to know about the personal information a business collects about them and how it is used and shared;
The right to delete personal information collected from them (with some exceptions);
The right to opt-out of the sale or sharing of their personal information;
The right to non-discrimination for exercising their CCPA rights;
The right to correct inaccurate personal information that a business has about them; and
The right to limit the use and disclosure of sensitive personal information collected about them.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email.
Within 1 business day
We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute noncompliance by data processors.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
Send information, respond to inquiries, and/or other requests or questions.
Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with the CAN-SPAM Act we agree to the following:
NOT use false or misleading subjects or email addresses.
Identify the message as an advertisement in some reasonable way.
Include the physical address of our business or site headquarters.
Monitor third-party email marketing services for compliance, if one is used.
Honor opt-out/unsubscribe requests quickly.
Allow users to unsubscribe by using the link at the bottom of each email.
Information collected or received may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, we may transfer your information to the United States and process it there (or any other country in which we operate).
You may request from the Company, at any time, specific information regarding whether your personal data has been stored and can consult the Company to learn about the information stored and its origins, to verify its accuracy, or to ask that your personal data be supplemented, cancelled, updated or corrected. You may request that your personal data be transformed into an anonymous format or to black any data held in violation of the law, as well as to oppose its treatment for any and all legitimate reasons. Requests should be sent to the Company at the contact information set out above.
If at any time you would like to unsubscribe from receiving future emails, you can email us at firstname.lastname@example.org
If there are any questions regarding this privacy and advertising policy, you may contact us using the information below:
10866 Wilshire Boulevard, Suite 400, Los Angeles, CA 90024