Privacy-Policy
Here at Infinity Sales Group, LLC (“Infinity,” “we,” “us,” “our”), we work hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) (“Site”), and any services, transactions, or other engagements you might have with us (collectively, “Services”).
This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use.
Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Site and/or Services. If you do not agree with the Terms of Use and/or this Privacy Policy, you must refrain from using our Site and/or Services. By Accessing or using our Site and/or Services you agree to our use of your information consistent with the Terms of Use and this Privacy Policy.
This Privacy Policy does not apply to our collection, use, or disclosure of Personal Information of job applicants, employees, or independent contractors. We do not accept job applications, employees, or independent contractors from California.
PRIVACY POLICY CHANGES
This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be posted on this Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Site or Services. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change in a materially new way, we will provide you notice before using your Personal Information in the new way.
CONFLICT BETWEEN THIS POLICY AND LOCAL LAWS AND REGULATIONS
When local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. In addition, the specific requirements of this Privacy Policy apply only when local laws and regulations permit.
INFORMATION WE COLLECT
Personal Information
We collect, and have collected in the past twelve months, information that personally identifies, relates to, describes, or is capable of being associated with a person (“Personal Information”), including:
- Identifiers (e.g., name, social security number, taxpayer identification number, driver’s license number, date of birth, IP address, security questions & answers, mailing address, email address, phone number);
- Commercial Information (e.g., internal or third-party customer account numbers, product interest and purchase history, payment information such as bank account number, credit card number, expiration date, participation in surveys and sweepstakes);
- Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information (e.g., call recordings);
- Characteristics of Protected Classifications under California or federal law (e.g., age);
- Professional or Employment-related Information (e.g., job title, employer);
- Internet or Other Electronic Network Activity Information (e.g., the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site);
- Geolocation (approximate);
- Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;
- Personal information as described in Cal. Civ. Code § 1798.80(e) to the extent collected under another category of Personal Information above.
Some of the Personal Information listed above may be considered sensitive under relevant privacy laws. This includes social security number, driver’s license and other government identification card information, and your customer account login credentials. We refer to this type of Personal Information as “Sensitive Personal Information” in this Policy. Each type of Sensitive Personal Information may overlap with a category of Personal Information listed above.
The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.
Business Information
We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business. If such Business Information relates to a business contact person, we will treat it as Personal Information.
Usage Data and Site Activity
We automatically collect information in connection with the actions you take on the Site (“Usage Data”). For example, each time you use the Site, we may automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information under the category Internet or Other Electronic Network Activity Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.
Call Recordings
We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to such recording and retention of communications.
HOW WE COLLECT INFORMATION
Voluntary Disclosure
We may ask you to provide us with Personal Information when you communicate with us (online or offline), when you place an order, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as the companies whose products we market and sell.
Cookies & Other Automated Tools
We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to improve the experience of the site and Services, such as saving your preferences from visit to visit to present you with a customized version of the Site. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Site may not work if you delete or disable cookies.
We use the following types of cookies:
Strictly Necessary cookies: These cookies are essential for the Site to operate and provide you with the Services you have requested.
Functional Cookies: Functional cookies enable certain features or non-essential functionality on our Site. For example, we might use these cookies to recognize you and remember your preferences or settings when you return to our Site or to provide you a more personalized experience.
Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.
Analytics Cookies: Analytics cookies help us understand how our Site is working and who is visiting our Site. Google Analytics is one tool we use, and you can learn more about it by reviewing Google’s Privacy Policy.
We employ software technology that enables us to track certain aspects of a user’s visit to the Site. This technology helps us better manage content on the Site by informing us what content is effective, how consumers engage with the Site, and how consumers arrive at and/or depart from the Site. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.
If you arrive at the Site by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you were searching on that led you to the Site, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached the Site to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.
Targeted and Cross-Context Behavioral Advertising
We may work with third-party advertisers, search providers, ad networks, and our clients (“Advertisers”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of the Site or Services as well as other websites and services. These companies may use cookies, tracking pixels, and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users and Advertisers may collect Identifiers, Commercial Information, Characteristics of Protected Classification, and Internet or Other Electronic Network Activity information in connection with targeted and cross-context behavioral advertising activity. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Site or on third-party websites. You can visit the Network Advertising Initiative website at www.networkadvertising.org for information about Internet advertising companies and how to reduce information collection by such companies. Please also see the Additional State Consumer Rights section below regarding rights you may have under state laws to opt out of our sharing of Personal Information for targeted or cross-context behavioral advertising purposes.
Information from Advertisements
If you arrive at the Site via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).
Surveys
From time to time we may request Personal Information from consumers via surveys. Participation in these surveys is completely voluntary and you have a choice whether or not to disclose Personal Information. The requested information typically includes personal identifiers and contact information.
Sweepstakes and Contests
We may offer opportunities for consumers to participate in sweepstakes or contests. Participation in these sweepstakes or contests is completely voluntary but participation usually requires providing certain Personal Information. The requested Personal Information typically includes Identifiers and Commercial Information.
Social Media Widgets
The Site may include social media features, such as the Facebook, YouTube, LinkedIn, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them. Before you choose to interact with these features, you should review the relevant social media company’s privacy policy.
HOW WE USE AND DISCLOSE INFORMATION
Generally
We collect and use Personal Information for internal purposes, such as to:
- Provide you with the Site and Services;
- Process or complete transactions you requested;
- Improve the Site and Services, including customization and personalization;
- Notify you of products and services via mail, email, telephone, and/or text messaging;
- Communicate with you about the Site, the Services, and other matters via mail, email, telephone, and/or text messaging; and
- Compile information and analyses to enhance the customer experience and improve our business; and
- Perform day-to-day business operations such as accounting, seeking legal advice, pursuing or defending legal claims, maintaining information security and anti-fraud programs, and facilitating business transactions with our business partners and clients.
We use Sensitive Personal Information for the following purposes:
- Social Security Number – To verify your identity and/or in connection with credit determinations performed by our clients related to transactions initiated by you.
- Driver’s license and other government identification number – To verify your identity and/or in connection with credit determinations performed by our clients related to transactions initiated by you.
- Customer account login credentials – To facilitate the transactions you requested and maintain our customer relationship with you.
From time to time, we may de-identify Personal Information so that it can no longer be reasonably linked, directly or indirectly, with an identifiable person. We may use and disclose de-identified information for any purpose since it is no longer Personal Information. We will not re-identify de-identified information.
Testimonials
If you provide a testimonial, we may post it publicly on the Site or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
Service Providers
We may establish a relationship with other businesses to provide services to us (“Service Providers”), including:
- Online hosting and maintenance;
- Marketing and promotion design and management;
- Communication facilitation such as printing and mailing or telecommunication services;
- Payment processing;
- Management of access to services;
- Data storage and management;
- Data analytics; and
- Identity and contact information validation.
We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
We disclose each of the categories of Personal Information to one or more Service Providers.
Third-Party Disclosures
We may also sell or share (for targeted or cross-context behavioral advertising), and have sold or shared in the past twelve months, Personal Information with third parties who are not our Service Providers (“Third Parties”) as follows:
Category of Third Party | Sale or Sharing (for targeted or cross-context behavioral advertising) | Purpose of Sale or Sharing | Categories of Personal Information Sold of Shared |
Our clients (providers of consumer goods and services) | Sale | To enable our clients to market and provide their goods and services | Identifiers; Commercial Information; Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information; Characteristics of Protected Classifications; Internet or Other Electronic Network Activity Information; Geolocation (approximate); Personal Information Described in Cal. Civ. Code § 1798.80(e); Sensitive Personal Information. |
Our clients (providers of consumer goods and services) | Sharing | To enable our clients to market their goods and services | Identifiers; Characteristics of Protected Classifications; Internet or Other Electronic Network Activity Information; Geolocation (approximate); Personal Information Described in Cal. Civ. Code § 1798.80(e). |
Ad networks & ad technology providers | Sharing | To facilitate our advertising of goods and services | Identifiers; Characteristics of Protected Classifications; Internet or Other Electronic Network Activity Information; Geolocation (approximate); Personal Information Described in Cal. Civ. Code § 1798.80(e). |
Except as stated above, we have not disclosed Personal Information to Third Parties for a business purpose in the prior twelve months. We do not knowingly sell or share (for targeted or cross-context behavioral advertising) with Third Parties the Personal Information of individuals under 16 years of age.
Email Marketing
We may use your Personal Information to market products or services likely to be of interest to you, or to provide you with special offers and opportunities, via email. With respect to commercial email communications from us, you may opt out of these emails via a link in the footer of all commercial email messages.
Profiling
We do not engage in profiling or automated decision-making that may have legal or similarly significant effects; however, our clients may engage in such practices subject to their respective privacy policies using Personal Information that we provide to them. For example, our clients may make credit determinations using automated decision-making.
SECURITY
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100{31701b7889b6061aa6a2c6fe253835ccc7753500cad66efc77f15ada80887561} secure. As a result, while we strive to protect information transmitted on or through our Site or Services, you do so at your own risk.
OTHER WEBSITES
Please be aware that third-party websites accessible through the Site or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.
COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, our clients, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
OTHER TRANSFERS
We may disclose Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
HOW LONG WE RETAIN YOUR DATA
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. Generally, we retain Personal Information for approximately ten (10) years after our relationship with you has ended, but the term for which we retain your Personal Information may be longer or shorter. We do so in accordance with our data retention policies and applicable law.
CHILDREN’S PRIVACY
The Site and Services are not intended for children under the age of 18 and we do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.
ADDITIONAL STATE CONSUMER RIGHTS
If you are a resident of California, Connecticut, Colorado, Utah, or Virginia, you have additional rights to access and control your Personal Information as described more fully below. We will retain a record of your request for at least two years and in compliance with applicable laws.
Right to Know
You have the right to request twice per 12-month period that we provide you (i) the categories and, if requested, specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Third Parties with whom we sold or shared your Personal Information; and (v) the business or commercial purpose for which we sold or shared your Personal Information. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your information by mail or electronic delivery.
To request access to your Personal Information and the information listed above, you may submit a request through our Access Request Page .
. If you choose to call us, please review the Access Request Page first because it contains important descriptions of the process we use to verify your identity and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the Access Request Page.
Right to Deletion
You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your fulfillment by mail or electronic delivery.
To request deletion of your Personal Information, you may submit a request through our Deletion Request Page. If you choose to call us, please review the Deletion Request Page first because it contains important descriptions of the process we use to verify your identity and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the Deletion Request Page.
Right to Correction
You have the right to request that we correct any Personal Information that we have on file about you that you believe to be erroneous. When you make your request, please be sure to provide us the specific information that you believe is inaccurate and the correct information. You should also provide us with any documentation you believe supports your proposed correction, and we will take that documentation into consideration. We will only correct the information if we determine, based on the totality of the circumstances, that your correction is more likely than not accurate. We may also choose to delete the allegedly inaccurate information instead of correcting it. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your fulfillment by mail or electronic delivery.
To request correction of your Personal Information, you may submit a request through our Correction Request Page or call us . If you choose to call us, please review the Correction Request Page first because it contains important descriptions of the process we use to verify your identity and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the Correction Request Page.
Right to Opt-Out from the Sale or Sharing of Personal Information
You have the right to direct us not to sell your Personal Information to Third Parties or to share it with Third Parties for targeted or cross-context behavioral advertising purposes . You may exercise your Right to Opt-Out by calling us or submitting a request via our Do Not Sell or Share My Personal Information web page. You may also designate an authorized agent to submit a request on your behalf as described on the Do Not Sell or Share My Personal Information page.
We will recognize and process browser-based opt-out signals If we are able to reasonably associate a browser-based opt-out signal with an identifiable consumer, we will treat it as a request to opt-out of the sale or sharing of that consumer’s Personal Information as if the consumer made the request using a method above. If we are not able to reasonably associate a browser-based opt-out signal with an identifiable consumer, we will treat it as a request to opt-out of the sale or sharing of that Site visitor’s Personal Information collected while the signal is present. While the signal is present, we will also disable any cookies or other tracking tools present on the Site from a Third Party.
Right to Limit Use of Sensitive Personal Information
If you are a California resident, you have the right to request that we limit the use of your Sensitive Personal Information as defined under California law to only exempt purposes such as to provide the goods and services reasonably expected by the average consumer who requests such goods and services, to prevent fraud, and to verify or maintain the quality or safety of goods or services we provide.
If you are a Connecticut, Colorado, Utah, or Virginia resident, and you make a request to limit the user of your Sensitive Personal Information as defined under your applicable state’s law, we will treat that request as a revocation of your consent for us to collect and process your Sensitive Personal Information and will delete your Sensitive Personal Information subject to any exemptions available under applicable law.
We will process requests to Limit Use of Sensitive Personal Information within 15 business days subject to any applicable exceptions and extension permitted by law.
You may exercise your Right to Limit Use of Sensitive Personal information by calling us or submitting a request via our Limit Use of Sensitive Personal Information Request Page. You may also designate an authorized agent to act on your behalf as described on the Limit Use of Sensitive Personal Information Request Page.
Right to Appeal
If we deny your privacy request, in full or in part, you may appeal our decision. If we deny your appeal, you may also contact your state Attorney General to lodge a complaint and we will provide you with an online mechanism to do so. We will process requests to appeal within the timeframes established under applicable law, but typically within 45 days. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your fulfillment by mail or electronic delivery.
You may exercise your Right to Appeal by calling us or submitted a request via our Appeal Request Page. You may also designate an authorized agent to act on your behalf as described on the Appeal Request Page.
Non-Discrimination Notice
We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.
California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our Site and Services do not respond to “do not track” signals.
CA Privacy Policy Last Updated: 01/01/2023
Here at Infinity Sales Group, LLC (“Infinity,” “we,” “us,” “our”), we work hard to build and maintain a relationship of trust with you. This California Privacy Notice (the “Privacy Notice”) provides information to California residents about our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) (“Site”), and any services, transactions, or other engagements you might have with us (collectively, “Services”). You should also review our Privacy Policy which contains additional important information about our privacy practices. This Privacy Notice does not apply to our collection, use, or disclosure of Personal Information of job applicants, employees, or independent contractors. We do not accept job applications, employees, or independent contractors from California. PRIVACY NOTICE CHANGES This Privacy Notice is subject to change. We encourage you to review this Privacy Notice frequently for any revisions or amendments. Changes to this Privacy Notice will be posted on this Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Site or Services. If we determine that a change to this Privacy Notice will result in using your Personal Information acquired before the change in a materially new way, we will provide you notice before using your Personal Information in the new way and obtain your consent. INFORMATION WE COLLECT Personal Information We collect, and have collected in the past twelve months, information that personally identifies, relates to, describes, or is capable of being associated with a person (“Personal Information”), including:
- Identifiers (e.g., name, social security number, taxpayer identification number, driver’s license number, date of birth, IP address, security questions & answers, mailing address, email address, phone number);
- Commercial Information (e.g., internal or third-party customer account numbers, product interest and purchase history, payment information such as bank account number, credit card number, expiration date, participation in surveys and sweepstakes);
- Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information (e.g., call recordings);
- Characteristics of Protected Classifications under California or federal law (e.g., age);
- Professional or Employment-related Information (e.g., job title, employer);
- Internet or Other Electronic Network Activity Information (e.g., the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site);
- Geolocation (approximate);
- Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;
- Personal information as described in Cal. Civ. Code § 1798.80(e) to the extent collected under another category of Personal Information above.
Some of the Personal Information listed above may be considered sensitive under relevant privacy laws. This includes social security number, driver’s license and other government identification card information, and your customer account login credentials. We refer to this type of Personal Information as “Sensitive Personal Information” in this Policy. Each type of Sensitive Personal Information may overlap with a category of Personal Information listed above. The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us. Business Information We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business. If such Business Information relates to a business contact person, we will treat it as Personal Information. Usage Data and Site Activity We automatically collect information in connection with the actions you take on the Site (“Usage Data”). For example, each time you use the Site, we may automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information under the category Internet or Other Electronic Network Activity Information. If this information is not capable of being individually associated with you, we treat it as Usage Data. Call Recordings We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to such recording and retention of communications. HOW WE USE AND DISCLOSE INFORMATION (PURPOSES OF COLLECTION) Generally We collect and use Personal Information for internal purposes, such as to:
- Provide you with the Site and Services;
- Process or complete transactions you requested;
- Improve the Site and Services, including customization and personalization;
- Notify you of products and services via mail, email, telephone, and/or text messaging;
- Communicate with you about the Site, the Services, and other matters via mail, email, telephone, and/or text messaging; and
- Compile information and analyses to enhance the customer experience and improve our business; and
- Perform day-to-day business operations such as accounting, seeking legal advice, pursuing or defending legal claims, maintaining information security and anti-fraud programs, and facilitating business transactions with our business partners and clients.
We use Sensitive Personal Information for the following purposes:
- Social Security Number – To verify your identity and/or in connection with credit determinations performed by our clients related to transactions initiated by you.
- Driver’s license and other government identification number – To verify your identity and/or in connection with credit determinations performed by our clients related to transactions initiated by you.
- Customer account login credentials – To facilitate the transactions you requested and maintain our customer relationship with you.
From time to time, we may de-identify Personal Information so that it can no longer be reasonably linked, directly or indirectly, with an identifiable person. We may use and disclose de-identified information for any purpose since it is no longer Personal Information. We will not re-identify de-identified information. Testimonials If you provide a testimonial, we may post it publicly on the Site or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications. Service Providers We may establish a relationship with other businesses to provide services to us (“Service Providers”), and provide them Personal Information necessary for them to perform services for us. Third-Party Disclosures We may sell or share (for targeted or cross-context behavioral advertising), and have sold or shared in the past twelve months, Personal Information with third parties who are not our Service Providers (“Third Parties”) as follows:
Category of Third Party | Sale or Sharing (for targeted or cross-context behavioral advertising) | Purpose of Sale or Sharing | Categories of Personal Information Sold of Shared |
Our clients (providers of consumer goods and services) | Sale | To enable our clients to market and provide their goods and services | Identifiers; Commercial Information; Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information; Characteristics of Protected Classifications; Internet or Other Electronic Network Activity Information; Geolocation (approximate); Personal Information Described in Cal. Civ. Code § 1798.80(e); Sensitive Personal Information. |
Our clients (providers of consumer goods and services) | Sharing | To enable our clients to market their goods and services [this is more to enable us to market our clients goods and services] | Identifiers; Characteristics of Protected Classifications; Internet or Other Electronic Network Activity Information; Geolocation (approximate); Personal Information Described in Cal. Civ. Code § 1798.80(e). |
Ad networks & ad technology providers | Sharing | To facilitate our advertising of goods and services | Identifiers; Characteristics of Protected Classifications; Internet or Other Electronic Network Activity Information; Geolocation (approximate); Personal Information Described in Cal. Civ. Code § 1798.80(e). |
Except as stated above, we have not disclosed Personal Information to Third Parties for a business purpose in the prior twelve months. We do not knowingly sell or share (for targeted or cross-context behavioral advertising) with Third Parties the Personal Information of individuals under 16 years of age. COMPLIANCE WITH LAWS AND LAW ENFORCEMENT We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, our clients, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law. OTHER TRANSFERS We may disclose Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. HOW LONG WE RETAIN YOUR DATA We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. Generally, we retain Personal Information for approximately ten (10) years after our relationship with you has ended, but the term for which we retain your Personal Information may be longer or shorter. We do so in accordance with our data retention policies and applicable law. CALIFORNIA CONSUMER RIGHTS If you are a resident of California, you have additional rights to access and control your Personal Information as described more fully in our Privacy Policy, including the right to opt-out of the sale and sharing of your Personal Information which you may exercise by calling us or submitting a request via our Do Not Sell or Share My Personal Information web page.