Privacy Policy

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect the following categories of personal information from consumers:

• Category A – Identifiers: Your Name and Email Address.
• Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Your Name and Your Telephone Number.
• Category I – Professional or employment-related information: Your Employer and Company Information.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, through information we ask from You when You or Your agents use our Services.
• Directly and indirectly from You when visiting our website. For example, usage details collected automatically in the course of Your interaction with our platform or website or provided by You through a website intake portal.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, to enjoy services offered by our organization.
• To provide You with email alerts and other notices concerning our Services, or updates to the Services.
• To improve our Services to You.
• To market our Services to You.
• For testing, research, analysis and product/service development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing You notice.

Sharing Personal Information

We will not disclose Your personal information to a third party for a business purpose.
We will not sell Your personal information to a third party.

Your Data Rights and Choices

Choices. You have certain choices available to You when it comes to Your information that is stored with us. Below is a summary of those choices, how to exercise them and any limitations.

(i) You have the right to request a copy of Your information in electronic format or object to our use of Your information (including for marketing purposes) or request removal of Your account and all associated data. Below we describe the processes and tools which You can use to do so, where Your account is managed by Your employer or an administrator, You may need to contact Your administrator to assist You in Your request.

(ii) Should You request to receive a copy of Your information, we will provide You an electronic file that contains Your basic account information and the information that You created which are under Your sole control that we maintain.

(iii) Your choices or requests may be limited in certain cases, for example, deletion of Your information which we or Your administrator or Your employer are permitted by Applicable Law to keep or have compelling legitimate interest to keep; or when Your data is shared with third-parties, then You will be required to contact those third-party service providers to delete or restrict Your information.

(iv) You may opt-out from receiving promotional email communications from us while signing up or using the ‘unsubscribe’ link from the emails received from us.

(v) You may be able to opt out of receiving personalized advertisements from other companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand Your options, please visit: http://www.aboutads.info, http://optout.networkadvertising.org/ and http://www.youronlinechoices.eu.

(vi) You can request for removal of Your account and associated data (excluding the information which we are required and/or permitted by Applicable Law to retain).  The invoices or previous payment information will not be removed, as we need to retain such information for accounting purpose.

(vii) In some circumstances, You have the right to request for erasure of Your information without undue delay after providing notice of such request to us, i.e.

(1) when Your Personal Information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(2) when You intend to withdraw Your consent to consent-based processing;

(3) when You object to processing of Your Personal Information under certain provisions of Applicable Law;

(4) when the processing of Your Personal Information is for direct marketing purposes; and

(5) when Your Personal Information has been unlawfully processed.

(viii) Data Portability is the ability to obtain some of Your information in a format that You can move from one service provider to another. In the industry where we operate, there is no particular standard for data-portability yet, hence this applies to some of Your information, but not to all of Your information.

(ix) There may be certain exceptions to Your rights as contemplated herein, including but not limited to where processing of Personal Information is necessary for compliance with any legal obligation or for the establishment, exercise or defense of legal claims.

(x) Furthermore, we may acquire such deleted/ erased/ removed data from various legitimate sources and such contact details may be purchased and added back into its database which may, therefore, mean that You could be contacted in a future marketing campaign.

Your Rights and Choices – California Residents

The CCPA provides California residents with specific rights regarding their personal information. This section describes for residents of California those CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to You about our collection and use of Your personal information over the past 12 months. Once we receive and confirm Your verifiable consumer request, we will disclose to You:

• The categories of personal information we collected about You.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about You (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of Your personal information we collected from You and retained, subject to certain exceptions. Once we receive and confirm Your verifiable consumer request, we will delete (and direct our service providers to delete) Your personal information from our records, unless an exception applies.

We may deny Your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or perform a contract with You.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

 

1. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
2. Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us.
3. Comply with a legal obligation.
4. Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us.

Only You or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable consumer request related to Your personal information. You may also make a verifiable consumer request on behalf of Your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify You are the person about whom we collected personal information or an authorized representative.
• Describe Your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to Your request or provide You with personal information if we cannot verify Your identity or authority to make the request and confirm the personal information relates to You.  Making a verifiable consumer request does not require You to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform You of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at Your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide Your personal information that is reasonably useable and should allow You to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell You why we made that decision and provide You with a cost estimate before completing Your request.

Non-Discrimination

We will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny You use of our Services.
• Provide You a different level or quality of Services.

Changes to Our Privacy Notice

We reserve the right to amend this Notice of Privacy Policy at our discretion and at any time. The date this policy was last updated is identified at the bottom of this page. You are responsible for periodically visiting the website and this Privacy Notice to check for any changes.

Policy Toward Minors

We do not knowingly collect or solicit personal information from anyone under the age of 18. No one under age 18 may provide any personal information to us or on the Services. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us.

Contact Information

If You have any questions or comments about our Privacy Policy, the ways in which we collect and use Your personal information, Your choices and rights regarding such use, or wish to exercise Your rights, please contact us.

Updated April 2, 2024