Effective: January 01, 2020

This Privacy Policy applies to your use of https://www.symplerdigital.com/ or any other URL (the “Site” or “Website(s)”) owned by Sympler Digital, LLC its subsidiaries, affiliates and partners (collectively the “Company.”)

Your privacy is very important to us. We want to make your experience on the Internet as enjoyable and rewarding as possible, and we want you to use the Internet’s vast array of information, tools, and opportunities with complete confidence.

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how our company collects information from all end users of our products and services (collectively the “Services”) – those who access some of our Services but do not have accounts (“Visitors”) as well as those who may purchase Products and/or pay a monthly service fee to subscribe to the Service (“Members”) – what we do with the information we collect, and the choices Visitors and Members have concerning the collection and use of such information. We request that you read this Privacy Policy carefully. By visiting our Site, you are consenting to our policy of collecting and using your data.

Personal Information Our Company Collects and How It Is Used

Introduction:

Our company collects information in different ways from Visitors and Members who access the various parts of our Services and the network of Websites accessible through our Service. We do not specifically target customers in the EU, however, we have updated our Privacy Policy and will continue to remain compliant and up to date on all policies and requirements. Our commitment is to your privacy and protection of your data.

Registration:

Members may be asked to provide certain personal information when they sign up for our Products or Services including name, address, telephone number, billing information (such as a credit card number), and the type of personal computer being used to access the Services. The personal information collected from Members during the registration process is used to manage each Member’s account (such as for billing purposes). This information may be shared with third parties, as stated herein, or in special circumstances.

However, in instances where our company and a partner jointly promote our Services, we may provide the partner certain personal information, such as the name, address, phone number of persons who subscribed to the Services as a result of the joint promotion for the purpose of offering you other products and services. We may also generate non-identifying and aggregate profiles from personal information Members provide during registration (such as the total number, but not the names, of Members). As explained in more detail below, we may use this aggregated and non-identifying information to sell advertisements that appear on the Services.

Our Company collects personal information through forms you complete on the site, as well as but not limited to contests, sweepstakes, text messages, Facebook messages, e-mails, faxes, telephone calls, postal mail or other communications with the user, as well as from outside sources such as credit card processors and database vendors. For example, when you fill out a form subscribing to our emails, we are sent data information from our autoresponder company such as your name, email, the website you signed up from, geographical data such as your city, state, Postal code, country, Latitude, Longitude, Timestamp, Subscription method and IP address. Also, with purchases, we supply our member’s contact information, to our business partners, who then may contact the member by telephone after the member purchase. Sales proceeds are collected by the business partner company. We also may supply other companies with contact information, for mail or email offers we believe would be of interest to our members, with or without compensation from those companies. At times we may send an advertisement for a third-party product, where we collect the sales proceeds, and forward the purchaser’s information to that third party.

Our Company Partners and Sponsors:

Some products and services may be offered to Visitors and Members in conjunction with an affiliate, independent contractor seller or non-affiliated partner. To provide Visitors and Members some of these products and services, the partner may need to collect and maintain personal information.

Online Shopping:

You can purchase products and services or register to receive materials, such as a newsletter, catalog or new product and service updates from our Site. In many cases, you may be asked to provide contact information, such as your name, address, email address, phone number, and credit/debit card information. If you complete an order for someone else, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient’s name, address, and phone number. Our Company has no control over the third parties’ use of any personal information you provide when placing such an order. Please exercise care when doing so. If you order services or products directly from our company, we use the personal information you provide to process that order. We do share this information with outside parties that we do business with.

Online Advertisements:

Our Company may display online advertisements. In those cases we share information about our Visitors and Members collected through the registration process as well as through online surveys and promotions with these advertisers. Additionally, in some instances, we use this information to deliver tailored advertisements or joint ventures. For instance, an advertiser or joint venture company tells us the audience they want to reach and provides us an advertisement tailored to the audience. Based upon the information we have collected, we may then display or send the advertisement to the intended audience. Our company does share personal information about its Visitors or Members with these advertisers or joint venture companies.

By visiting our Company Website, you are consenting to our policy of collecting and using your data. If you do not want to consent to our policy of collecting and using your data you can “opt out” of our Re-Targeting, Social Network and Facebook.com Website Custom Audience Ads advertising policy by notifying Company in the following manner:

Re-Targeting & Behavioral Targeting:

Our company partners with a 3rd party ad network to display our advertising on other websites. Our ad network partner uses cookies and web beacons to collect non-personally identifiable information about your activities on this website as well as others. This information is used to provide you targeted advertising across the Internet, based on your interests. Our Company may utilize categories of information, including names and email addresses, collected from users on our sites and services, as well as third party sites and services, in connection with the ads that are served. This advertising may include, but not limited to, contextual advertising, cookies, anonymous cookies, pixels, persistent identifiers, geo-location information, email opt in, search engine terms, behavioral advertising and/or retargeting advertising. This type of advertising is a form of targeted advertising, to the specific individual who is visiting the Web site. These advertisements appear on websites or other media, including display ads, pop up ads and ads displayed in mobile browsers.

Our Company does not conduct inquiries into the information collection practices of third parties that may collect information from users that leave our Web site. Our Company may share customer information with third parties to process orders, for third party analytics and for marketing and advertising purposes.

If you would like to have this information not used for the purpose of showing you targeted ads, you may opt-out by going to this website (http://preferences-mgr.truste.com/). If you are located in the European Union you may change your preferences by going to this website (http://www.youronlinechoices.eu/). This does not opt you out of being served advertising it only ensures your information will not be used by us to serve targeted ads. You will still receive generic advertising across the Internet, which has nothing to do with our company.

Social Network and Facebook.com Website Custom Audience Ads (WCA):

A Custom Audience on Facebook.com is a list of people our company would like to show our ads to on Facebook.com, who have shown interest in our products and services, with ads we believe would be of interest to them. This audience consists of people, whose information and email addresses our Company already has, because they have already subscribed to receiving Company emails. If you no longer have an interest in our products and services, you can opt-out of seeing Company’s Facebook.com Website Custom Audience Ads. Unsubscribing from our Company’s email list will remove you from Company’s internal email database list and stop future emails from our Company, but not from being shown Facebook.com Website Custom Audience Ads. The Facebook.com Website Custom Audience Ads external database, is different from our Company’s internal database and requires the following Opting-out request.

Opting-out of Facebook.com Website Custom Audience Ads: To opt out of our Company’s Facebook.com Custom Audience Ads, send an email, from the email address you are opting out, to Company using our email address provided in Company’s contact information. Put “Opting Out of Facebook.com Website Custom Audience Ads” in the subject line of the email. In the body of the email include your name and email address. Our Company staff will forward your name and email address to Facebook.com with a request to delete you from all of Company’s Facebook.com Website Custom Audience Ads.

Google.com Analytics:

Our Company may use Analytics tracking code to support Display Advertising, and enable Google Analytics to collect data about your traffic via the DoubleClick cookie in addition to data collected through the standard Google Analytics implementation. Display Advertising lets us enable features in Analytics that aren’t available through standard implementations, like Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting.

Our Company may use Remarketing with Google Analytics to advertise online: This allows third-party vendors, including Google, to show your ads on sites across the Internet. Our Company and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to our website.

Our Company may implement Google Display Network Impression Reporting or the DoubleClick Campaign Manager: Our Company and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services that are related to visits to your site.

Our Company may implement Google Analytics Demographics and Interest Reporting: The data from Google’s Interest-based advertising or 3rd-party audience data (such as age, gender, and interests) with Google Analytics allows us to serve ads to you based on this data.

Opting-out of Google Analytics’ For The Web and Google Analytics for Display Advertising: Users can opt-out of Google Analytics’ currently available opt-outs for the web at https://tools.google.com/dlpage/gaoptout/

Using the Ads Settings, users can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads at https://www.google.com/settings/personalinfo

Responses to Email Inquiries:

When Visitors or Members send email inquiries to our company, the return email address is used to answer the email inquiry we receive.

Voluntary Customer Surveys:

We may periodically conduct both business and individual customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of products and services we offer and how we provide them to you.

We may take the information we receive from individuals responding to our Customer Surveys and combine (or aggregate) it with the responses of other customers we may have, to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our services to you, and to develop new services and products. This aggregated; non-personally identifying information may be shared with third parties.

Special Cases:

It is our company’s policy to use or share the personal information about Visitors or Members in ways described herein without additional notice or means to opt-out except as noted herein, or otherwise prohibit such unrelated uses. Also, we may disclose personal information about Visitors or Members, or information regarding your use of the Services or Web sites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including: credit agencies, collection agencies, merchant database agencies, law enforcement, or to satisfy laws, such as the Electronic Communications Privacy Act, the Child Online Privacy Act, regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Acceptable Use Policy or Terms Of Service, or other user policies; to operate the Services properly; or to protect our company and our Members.

An Understanding of How We Use Your Information

Information we collect may be used in the following ways:

  • To notify you of updates to our Site or any Products and Services we offer.
  • To respond to your request or inquires.
  • To share offers from other companies with you.
  • To conduct market research and analysis.
  • To validate your identity.
  • To keep records of our interactions with you if you place an order or deal with a customer support representative.
  • To carry out our obligations and enforce our rights.
  • To provide you with newsletters, articles or products, Products or Services.
  • To provide you with alerts and announcements.
  • To process and complete your transactions for orders, customer service, billing and otherwise to fulfill our contractual obligation to you as a customer.
  • To analyze purchase history and transactions to improve our products, services and programs.
  • To prevent, investigate or provide notice of fraud, unlawful or criminal activity, or unauthorized access to or us of personally identifiable information.
  • To fulfill any other purpose for which you provided your personally identifiable information us.

Legal Bases for Processing (for EEA users):

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:

  • We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  • You give us consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

“Cookies” and How Our Company Uses Them.

A “cookie” is a small data file that can be placed on your hard drive when you visit certain Web sites. Our company may use cookies to collect, store, and sometimes track information for purposes stated herein as well as for statistical purposes to improve the products and services we provide and to manage our telecommunications networks.

Your Consent:

By continuing to use and navigate our Sites and use our Services you are agreeing to our use of cookies, web beacons and similar technologies as described herein.

Cookies, In General:

Cookies are essentially small data files placed on your computer, tablet, mobile phone or other device (“collectively, a “device”) that allows us to record information when you visit or interact with our websites, service, applications, messaging, and other tools. Though often these technologies are generically referred to as “Cookies,” each functions slightly differently. These small text files (typically made up of letters and numbers) are placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:

  • Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
  • Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
  • First-party cookies are those set by a website that is being visited by the user at the time in order to preserve your settings (e.g., while on our site).
  • Third-party cookies are placed in your browser by a website, or domain, that is not the website or domain that you are currently visiting. If a user visits a website and another entity sets a cookie through that website this would be a third-party cookie.

When you enter a website using cookies, you may be asked to fill out a form providing personal information; like your name, e-mail address, and interests. This information is packaged into a cookie and sent to your browser (Chrome, Firefox, etc.), which then stores the information for later use. The next time you go to the same website, your browser will send the cookie to the server. The message is sent back to the server each time the browser requests a page from the server.

Web Beacons —

Web Beacons are small files (also called “pixels”, “image tags”, or “script tags”) that may be loaded on our Sites that may work in concert with cookies to identify our users and provide anonymized data on their behavior.

Similar Technologies —

Technologies that store information in your browser or device utilizing local shared objects or local storage, such as flash cookies, HTML 5 cookies, and other web application software methods. These technologies can operate across all of your browsers, and in some instances may not be fully managed by your browser and may require management directly through your installed applications or device. We do not use these technologies for storing information to target advertising to you on or off our sites.

What Types of Cookies, Web Beacons and Similar Technologies Do We Use and Why –

Our cookies, web beacons and similar technologies serve various purposes, but are generally either necessary or essential to the functioning of our sites, services, applications, tools or messaging, help us improve the performance of or provide you extra functionality of the same, or help us to serve relevant and targeted advertisements.

Strictly Necessary or Essential – ‘Strictly necessary’ or ‘essential’ cookies, web beacons and similar technologies let you move around Site and use our Services. Without these technologies, Services you have asked for cannot be provided. Please note that these technologies do not gather any information about you that could be used for marketing or remembering where you’ve been on the internet. Accepting these technologies is a condition of using our sites, services, applications, tools or messaging, so if you prevent these from loading we can’t guarantee your use or how the security therein will perform during your visit.

Performance – ‘Performance’ cookies, web beacons and similar technologies collect information about how you use our website e.g. which pages you visit, and if you experience any errors. These cookies do not collect any information that could identify you and is only used to help us improve how Site, understand what interests our users and measure how effective our content is by providing anonymous statistics and data regarding how our website is used. Accepting these technologies is a condition of using our Sites and Services, so if you prevent these from loading we can’t guarantee your use or how the security therein will perform during your visit.

Functionality –  These cookies, web beacons or similar technologies are used to provide Services or to remember settings to improve your visit.

Advertising: First or third-party cookies and web beacons may be placed by our Sites or Services in order to deliver content, including product related advertisements, relevant to your specific interests on our sites or third-party sites. These technologies allow us to understand how useful our advertisements are, and improve the relevancy of the content delivered to our users.

We also utilize 3rd party service providers to assist us in delivering on the same functions, which means that our authorized service providers may also place cookies, web beacons and similar technologies on your device via our services (third party cookies). They may also collect information that helps them identify your device, such as IP-address, or other unique or device identifiers.

How To Manage, Control and Delete Cookies, Web Beacons and Similar Technologies:

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) it may limit your use of certain features or functions on our Sites or Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Site.

Internet browsers allow you to change your cookie settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the ‘Help’ option in your internet browser for more details.

  • Cookie settings in Internet Explorer
  • Cookie settings in Firefox
  • Cookie settings in Chrome
  • Cookie settings in Safari

If you wish to withdraw your consent at any time, you will need to delete your cookies using your internet browser settings.

Do Not Track Signals:

We track our customers over time and across third-party websites to provide targeted advertising. As such, our Website, ads and emails do not respond to Do Not Track signals.

More Information About Cookies:

  • Useful information about cookies, including information about deleting or blocking cookies, can be found at: http://www.allaboutcookies.org
  • A guide to behavioral advertising and online privacy has been produced by the internet advertising industry which can be found at: http://www.youronlinechoices.eu
  • Information on the ICC (UK) UK cookie guide can be found on the ICC website section:
  • http://www.international-chamber.co.uk/our-expertise/digitaleconomy

Deleting Cookies:

If you don’t want our Company’s cookies on your computer, to be used for the purposes stated herein, they are easy to delete. Simply go to http://wiht.link/cookiesguide for instructions.

Advertisers and partners may also use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for information collected through them.

Public Forums

Please remember that any information you may disclose in any Member Directory, or other public areas of our Websites or the Internet, becomes public information. You should exercise caution when deciding to disclose personal information in these public areas.

Our Company’s Commitment to Data Security

Services and Sites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. We follow generally accepted industry standards to protect any and all personal identifiable information given to us by our customers.

While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information.

When you make a purchase from our company any sensitive information is entered on pages using orders forms that have encrypted information using SSL.

Transfer of Personal Data Abroad:

If you utilize our Services from a country other than the country where our servers are located, your communications with us may result in transferring your personal data across international borders. Also, when you call us or initiate a chat, we may provide you with support from one of our global locations outside your country of origin. In these cases, your personal data is handled according to this Privacy Policy. You understand that we may transfer information about in in the United States and other countries, which may have different data protection laws than those in the country you reside.

Rights of EEA Users:

You have the right to request any personally identifiable information we have on file about you.

If you would like a copy of this information you can contact us at [email protected] to request it. We will require proof of your identity before sharing this information. If you find that our information is out of date you may ask us to update that information.

In the event that your information is within one of our 3rd party Email Marketing programs listed above you can always change or update that information as well as your settings by following the links at the bottom of any emails sent to you by our company.

You may ask us to delete all of your information. It may not be possible for us to delete all of the information we hold about you where we are fulfilling a transaction or have a legal basis to retain the information, however, feel free to contact us and we can assist you with your request.

If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements. If you make a request to obtain a copy of or port your personal data, to the extent we have any, we will respond within a reasonable time frame.

Email Marketing —

If you are receiving emails from us and no longer wish to have them to sent to you all you need to do is click the ‘manage subscription’ or ‘unsubscribe’ buttons at the bottom of any and all emails. This does not apply to transactional based emails where are required to send you proof of purchase and fulfillment of our contractual obligations to deliver purchased products to you.

With respect to personal data that we do not maintain or control, you may also may also make your request to access, view, update, delete or port your personal data (where available), or to update your subscription preferences, by following the links at the bottom of any email communication you receive by clicking the “unsubscribe” link or the “manage subscription” link.

We utilize 5 different email-marketing platforms due to the fact that each one has features and functionality that the other does not. We use each platform for a specific type of correspondence with you; however, you are able to opt-out at the bottom of any and all emails that we send to you. If you’d like us to remove you from every platform at once you can send that request to [email protected] with the subject line “Opt Out Of Email Marketing” and we will take care of that request immediately.

For other requests, contacting us at [email protected] with the subject line “Opt Out Of Email Marketing” and we will take care of that request immediately.

To our knowledge all of our data controllers have sent out updates that they are now GDRP compliant. We will continue to monitor and make sure that we only utilize companies who are in compliance with all regulatory requirements.

Notice to California Residents – Your California Privacy Rights:

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

Under California Law SB 27, California residents have the right to receive, up to twice a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to Company, to the email address provided in our contact information and please include the phrase “California Privacy Request” in the subject line, the domain name of the Web site you are inquiring about, along with your name, address and email address. We will respond to you within forty-five days of receiving such a request. More information about your rights is below:

Privacy Notice for California Residents —

Effective Date: January 1, 2020
Last Reviewed on: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended, (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Website collects 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, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:

CategoryExamplesCollected
A. Identifiers.A real name, Internet Protocol address, email address, or other similar identifiers.YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, 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.NO
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).NO
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YES
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NO
F. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.YES
G. Geolocation data.Physical location or movements.YES
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.YES
I. Professional or employment-related information.Current or past job history or performance evaluations.NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).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.NO
K. Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.YES

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

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

  • Directly from you. For example, from forms you complete on our website.
  • Indirectly from you. For example, from observing your actions on our Website or interactions with our ads, promotions, emails, forums, web browsers and third-party advertisers.
  • We may receive personal information from other third-party sources such as social media platforms with which you choose to interact.  For example, if you connect your social media account(s) to your customer account, the social media company may share information with us about your use of their services, including information about your profile, contacts, and viewed or liked content.  We encourage you to read the applicable privacy policies of social media platforms with whom you choose to interact. We have no responsibility for the data collection and use practices of the social media companies.

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 you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • 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.
  • To customize, tailor and present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To complete a transaction.
  • To offer similar products and services to you in the future.
  • To contact you by automatic means, which may include the use of an automatic telephone dialing or SMS text system and/or autodialer.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may share your personal information with the following categories of third parties:

  • Vendors who provide SMS marketing, opt-in/out, outbound automated messaging;
  • Vendors who provide email marketing campaign and promotions technology;
  • Vendors who provide sales tax compliance services;
  • Vendors who provide metrics, trends data and analytics reports;
  • Vendors who provide sales conversion and guided user experience technology;
  • Vendors who provide technology that helps customize your user experience;
  • Vendors who provide fraud protection technology;
  • Vendors who provide live streaming training platforms;
  • Vendors who provide technology to process, track and fulfill orders; and
  • Vendors who provide customer service and support via email and telephone.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed personal information for the following business purposes:

  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Short-term, transient use, provided the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
  • Undertaking internal research for technological development and demonstration; and
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your 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.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The 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).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable 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 provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please send a message to [email protected]. 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.

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 forty-five (45) days of its receipt. If we require more time (up to [45/90] 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 readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

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 goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us at [email protected].

IF YOU ARE UNDER EIGHTEEN YEARS OF AGE, YOU ARE NOT PERMITTED TO ACCESS THIS WEB SITE FOR ANY REASON. DUE TO THE AGE RESTRICTIONS FOR USE OF THIS WEB SITE, NO INFORMATION OBTAINED BY THIS WEB SITE, FALLS WITHIN THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) AND IS NOT MONITORED AS DOING SO.

Where to Direct Questions About Our Privacy Policy.

If you have any questions about this Privacy Policy or the practices described herein, you may contact us through the contact information provided on this Web site.

We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

To easily access, view, update, delete or port your personal data (where available), or to update your subscription preferences, please sign into your Account and visit “User Profile.” Please Contact us [email protected] for additional information and guidance for accessing, updating or deleting data.

Revisions to This Policy

Our company reserves the right to revise, amend, or modify this policy, our Terms of Service agreement, and our other policies and agreements at any time and in any manner, by updating this posting. Your use of this site after such changes are implemented constitutes your acknowledgement and acceptance of these changes. Please consult this privacy statement prior to every use for any changes.

Contact Information

If you have any questions or comments about this notice, the ways in which We collect and uses your information as described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows

Effective: January 01, 2020

This Privacy Policy applies to your use of https://www.symplerdigital.com/ or any other URL (the “Site” or “Website(s)”) owned by Sympler Digital, LLC its subsidiaries, affiliates and partners (collectively the “Company.”)

Your privacy is very important to us. We want to make your experience on the Internet as enjoyable and rewarding as possible, and we want you to use the Internet’s vast array of information, tools, and opportunities with complete confidence.

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how our company collects information from all end users of our products and services (collectively the “Services”) – those who access some of our Services but do not have accounts (“Visitors”) as well as those who may purchase Products and/or pay a monthly service fee to subscribe to the Service (“Members”) – what we do with the information we collect, and the choices Visitors and Members have concerning the collection and use of such information. We request that you read this Privacy Policy carefully. By visiting our Site, you are consenting to our policy of collecting and using your data.

Personal Information Our Company Collects and How It Is Used

Introduction:

Our company collects information in different ways from Visitors and Members who access the various parts of our Services and the network of Websites accessible through our Service. We do not specifically target customers in the EU, however, we have updated our Privacy Policy and will continue to remain compliant and up to date on all policies and requirements. Our commitment is to your privacy and protection of your data.

Registration:

Members may be asked to provide certain personal information when they sign up for our Products or Services including name, address, telephone number, billing information (such as a credit card number), and the type of personal computer being used to access the Services. The personal information collected from Members during the registration process is used to manage each Member’s account (such as for billing purposes). This information may be shared with third parties, as stated herein, or in special circumstances.

However, in instances where our company and a partner jointly promote our Services, we may provide the partner certain personal information, such as the name, address, phone number of persons who subscribed to the Services as a result of the joint promotion for the purpose of offering you other products and services. We may also generate non-identifying and aggregate profiles from personal information Members provide during registration (such as the total number, but not the names, of Members). As explained in more detail below, we may use this aggregated and non-identifying information to sell advertisements that appear on the Services.

Our Company collects personal information through forms you complete on the site, as well as but not limited to contests, sweepstakes, text messages, Facebook messages, e-mails, faxes, telephone calls, postal mail or other communications with the user, as well as from outside sources such as credit card processors and database vendors. For example, when you fill out a form subscribing to our emails, we are sent data information from our autoresponder company such as your name, email, the website you signed up from, geographical data such as your city, state, Postal code, country, Latitude, Longitude, Timestamp, Subscription method and IP address. Also, with purchases, we supply our member’s contact information, to our business partners, who then may contact the member by telephone after the member purchase. Sales proceeds are collected by the business partner company. We also may supply other companies with contact information, for mail or email offers we believe would be of interest to our members, with or without compensation from those companies. At times we may send an advertisement for a third-party product, where we collect the sales proceeds, and forward the purchaser’s information to that third party.

Our Company Partners and Sponsors:

Some products and services may be offered to Visitors and Members in conjunction with an affiliate, independent contractor seller or non-affiliated partner. To provide Visitors and Members some of these products and services, the partner may need to collect and maintain personal information.

Online Shopping:

You can purchase products and services or register to receive materials, such as a newsletter, catalog or new product and service updates from our Site. In many cases, you may be asked to provide contact information, such as your name, address, email address, phone number, and credit/debit card information. If you complete an order for someone else, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient’s name, address, and phone number. Our Company has no control over the third parties’ use of any personal information you provide when placing such an order. Please exercise care when doing so. If you order services or products directly from our company, we use the personal information you provide to process that order. We do share this information with outside parties that we do business with.

Online Advertisements:

Our Company may display online advertisements. In those cases we share information about our Visitors and Members collected through the registration process as well as through online surveys and promotions with these advertisers. Additionally, in some instances, we use this information to deliver tailored advertisements or joint ventures. For instance, an advertiser or joint venture company tells us the audience they want to reach and provides us an advertisement tailored to the audience. Based upon the information we have collected, we may then display or send the advertisement to the intended audience. Our company does share personal information about its Visitors or Members with these advertisers or joint venture companies.

By visiting our Company Website, you are consenting to our policy of collecting and using your data. If you do not want to consent to our policy of collecting and using your data you can “opt out” of our Re-Targeting, Social Network and Facebook.com Website Custom Audience Ads advertising policy by notifying Company in the following manner:

Re-Targeting & Behavioral Targeting:

Our company partners with a 3rd party ad network to display our advertising on other websites. Our ad network partner uses cookies and web beacons to collect non-personally identifiable information about your activities on this website as well as others. This information is used to provide you targeted advertising across the Internet, based on your interests. Our Company may utilize categories of information, including names and email addresses, collected from users on our sites and services, as well as third party sites and services, in connection with the ads that are served. This advertising may include, but not limited to, contextual advertising, cookies, anonymous cookies, pixels, persistent identifiers, geo-location information, email opt in, search engine terms, behavioral advertising and/or retargeting advertising. This type of advertising is a form of targeted advertising, to the specific individual who is visiting the Web site. These advertisements appear on websites or other media, including display ads, pop up ads and ads displayed in mobile browsers.

Our Company does not conduct inquiries into the information collection practices of third parties that may collect information from users that leave our Web site. Our Company may share customer information with third parties to process orders, for third party analytics and for marketing and advertising purposes.

If you would like to have this information not used for the purpose of showing you targeted ads, you may opt-out by going to this website (http://preferences-mgr.truste.com/). If you are located in the European Union you may change your preferences by going to this website (http://www.youronlinechoices.eu/). This does not opt you out of being served advertising it only ensures your information will not be used by us to serve targeted ads. You will still receive generic advertising across the Internet, which has nothing to do with our company.

Social Network and Facebook.com Website Custom Audience Ads (WCA):

A Custom Audience on Facebook.com is a list of people our company would like to show our ads to on Facebook.com, who have shown interest in our products and services, with ads we believe would be of interest to them. This audience consists of people, whose information and email addresses our Company already has, because they have already subscribed to receiving Company emails. If you no longer have an interest in our products and services, you can opt-out of seeing Company’s Facebook.com Website Custom Audience Ads. Unsubscribing from our Company’s email list will remove you from Company’s internal email database list and stop future emails from our Company, but not from being shown Facebook.com Website Custom Audience Ads. The Facebook.com Website Custom Audience Ads external database, is different from our Company’s internal database and requires the following Opting-out request.

Opting-out of Facebook.com Website Custom Audience Ads: To opt out of our Company’s Facebook.com Custom Audience Ads, send an email, from the email address you are opting out, to Company using our email address provided in Company’s contact information. Put “Opting Out of Facebook.com Website Custom Audience Ads” in the subject line of the email. In the body of the email include your name and email address. Our Company staff will forward your name and email address to Facebook.com with a request to delete you from all of Company’s Facebook.com Website Custom Audience Ads.

Google.com Analytics:

Our Company may use Analytics tracking code to support Display Advertising, and enable Google Analytics to collect data about your traffic via the DoubleClick cookie in addition to data collected through the standard Google Analytics implementation. Display Advertising lets us enable features in Analytics that aren’t available through standard implementations, like Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting.

Our Company may use Remarketing with Google Analytics to advertise online: This allows third-party vendors, including Google, to show your ads on sites across the Internet. Our Company and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to our website.

Our Company may implement Google Display Network Impression Reporting or the DoubleClick Campaign Manager: Our Company and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services that are related to visits to your site.

Our Company may implement Google Analytics Demographics and Interest Reporting: The data from Google’s Interest-based advertising or 3rd-party audience data (such as age, gender, and interests) with Google Analytics allows us to serve ads to you based on this data.

Opting-out of Google Analytics’ For The Web and Google Analytics for Display Advertising: Users can opt-out of Google Analytics’ currently available opt-outs for the web at https://tools.google.com/dlpage/gaoptout/

Using the Ads Settings, users can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads at https://www.google.com/settings/personalinfo

Responses to Email Inquiries:

When Visitors or Members send email inquiries to our company, the return email address is used to answer the email inquiry we receive.

Voluntary Customer Surveys:

We may periodically conduct both business and individual customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of products and services we offer and how we provide them to you.

We may take the information we receive from individuals responding to our Customer Surveys and combine (or aggregate) it with the responses of other customers we may have, to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our services to you, and to develop new services and products. This aggregated; non-personally identifying information may be shared with third parties.

Special Cases:

It is our company’s policy to use or share the personal information about Visitors or Members in ways described herein without additional notice or means to opt-out except as noted herein, or otherwise prohibit such unrelated uses. Also, we may disclose personal information about Visitors or Members, or information regarding your use of the Services or Web sites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including: credit agencies, collection agencies, merchant database agencies, law enforcement, or to satisfy laws, such as the Electronic Communications Privacy Act, the Child Online Privacy Act, regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Acceptable Use Policy or Terms Of Service, or other user policies; to operate the Services properly; or to protect our company and our Members.

An Understanding of How We Use Your Information

Information we collect may be used in the following ways:

  • To notify you of updates to our Site or any Products and Services we offer.
  • To respond to your request or inquires.
  • To share offers from other companies with you.
  • To conduct market research and analysis.
  • To validate your identity.
  • To keep records of our interactions with you if you place an order or deal with a customer support representative.
  • To carry out our obligations and enforce our rights.
  • To provide you with newsletters, articles or products, Products or Services.
  • To provide you with alerts and announcements.
  • To process and complete your transactions for orders, customer service, billing and otherwise to fulfill our contractual obligation to you as a customer.
  • To analyze purchase history and transactions to improve our products, services and programs.
  • To prevent, investigate or provide notice of fraud, unlawful or criminal activity, or unauthorized access to or us of personally identifiable information.
  • To fulfill any other purpose for which you provided your personally identifiable information us.

Legal Bases for Processing (for EEA users):

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:

  • We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  • You give us consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

“Cookies” and How Our Company Uses Them.

A “cookie” is a small data file that can be placed on your hard drive when you visit certain Web sites. Our company may use cookies to collect, store, and sometimes track information for purposes stated herein as well as for statistical purposes to improve the products and services we provide and to manage our telecommunications networks.

Your Consent:

By continuing to use and navigate our Sites and use our Services you are agreeing to our use of cookies, web beacons and similar technologies as described herein.

Cookies, In General:

Cookies are essentially small data files placed on your computer, tablet, mobile phone or other device (“collectively, a “device”) that allows us to record information when you visit or interact with our websites, service, applications, messaging, and other tools. Though often these technologies are generically referred to as “Cookies,” each functions slightly differently. These small text files (typically made up of letters and numbers) are placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:

  • Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
  • Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
  • First-party cookies are those set by a website that is being visited by the user at the time in order to preserve your settings (e.g., while on our site).
  • Third-party cookies are placed in your browser by a website, or domain, that is not the website or domain that you are currently visiting. If a user visits a website and another entity sets a cookie through that website this would be a third-party cookie.

When you enter a website using cookies, you may be asked to fill out a form providing personal information; like your name, e-mail address, and interests. This information is packaged into a cookie and sent to your browser (Chrome, Firefox, etc.), which then stores the information for later use. The next time you go to the same website, your browser will send the cookie to the server. The message is sent back to the server each time the browser requests a page from the server.

Web Beacons —

Web Beacons are small files (also called “pixels”, “image tags”, or “script tags”) that may be loaded on our Sites that may work in concert with cookies to identify our users and provide anonymized data on their behavior.

Similar Technologies —

Technologies that store information in your browser or device utilizing local shared objects or local storage, such as flash cookies, HTML 5 cookies, and other web application software methods. These technologies can operate across all of your browsers, and in some instances may not be fully managed by your browser and may require management directly through your installed applications or device. We do not use these technologies for storing information to target advertising to you on or off our sites.

What Types of Cookies, Web Beacons and Similar Technologies Do We Use and Why –

Our cookies, web beacons and similar technologies serve various purposes, but are generally either necessary or essential to the functioning of our sites, services, applications, tools or messaging, help us improve the performance of or provide you extra functionality of the same, or help us to serve relevant and targeted advertisements.

Strictly Necessary or Essential – ‘Strictly necessary’ or ‘essential’ cookies, web beacons and similar technologies let you move around Site and use our Services. Without these technologies, Services you have asked for cannot be provided. Please note that these technologies do not gather any information about you that could be used for marketing or remembering where you’ve been on the internet. Accepting these technologies is a condition of using our sites, services, applications, tools or messaging, so if you prevent these from loading we can’t guarantee your use or how the security therein will perform during your visit.

Performance – ‘Performance’ cookies, web beacons and similar technologies collect information about how you use our website e.g. which pages you visit, and if you experience any errors. These cookies do not collect any information that could identify you and is only used to help us improve how Site, understand what interests our users and measure how effective our content is by providing anonymous statistics and data regarding how our website is used. Accepting these technologies is a condition of using our Sites and Services, so if you prevent these from loading we can’t guarantee your use or how the security therein will perform during your visit.

Functionality –  These cookies, web beacons or similar technologies are used to provide Services or to remember settings to improve your visit.

Advertising: First or third-party cookies and web beacons may be placed by our Sites or Services in order to deliver content, including product related advertisements, relevant to your specific interests on our sites or third-party sites. These technologies allow us to understand how useful our advertisements are, and improve the relevancy of the content delivered to our users.

We also utilize 3rd party service providers to assist us in delivering on the same functions, which means that our authorized service providers may also place cookies, web beacons and similar technologies on your device via our services (third party cookies). They may also collect information that helps them identify your device, such as IP-address, or other unique or device identifiers.

How To Manage, Control and Delete Cookies, Web Beacons and Similar Technologies:

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) it may limit your use of certain features or functions on our Sites or Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Site.

Internet browsers allow you to change your cookie settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the ‘Help’ option in your internet browser for more details.

  • Cookie settings in Internet Explorer
  • Cookie settings in Firefox
  • Cookie settings in Chrome
  • Cookie settings in Safari

If you wish to withdraw your consent at any time, you will need to delete your cookies using your internet browser settings.

Do Not Track Signals:

We track our customers over time and across third-party websites to provide targeted advertising. As such, our Website, ads and emails do not respond to Do Not Track signals.

More Information About Cookies:

  • Useful information about cookies, including information about deleting or blocking cookies, can be found at: http://www.allaboutcookies.org
  • A guide to behavioral advertising and online privacy has been produced by the internet advertising industry which can be found at: http://www.youronlinechoices.eu
  • Information on the ICC (UK) UK cookie guide can be found on the ICC website section:
  • http://www.international-chamber.co.uk/our-expertise/digitaleconomy

Deleting Cookies:

If you don’t want our Company’s cookies on your computer, to be used for the purposes stated herein, they are easy to delete. Simply go to http://wiht.link/cookiesguide for instructions.

Advertisers and partners may also use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for information collected through them.

Public Forums

Please remember that any information you may disclose in any Member Directory, or other public areas of our Websites or the Internet, becomes public information. You should exercise caution when deciding to disclose personal information in these public areas.

Our Company’s Commitment to Data Security

Services and Sites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. We follow generally accepted industry standards to protect any and all personal identifiable information given to us by our customers.

While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information.

When you make a purchase from our company any sensitive information is entered on pages using orders forms that have encrypted information using SSL.

Transfer of Personal Data Abroad:

If you utilize our Services from a country other than the country where our servers are located, your communications with us may result in transferring your personal data across international borders. Also, when you call us or initiate a chat, we may provide you with support from one of our global locations outside your country of origin. In these cases, your personal data is handled according to this Privacy Policy. You understand that we may transfer information about in in the United States and other countries, which may have different data protection laws than those in the country you reside.

Rights of EEA Users:

You have the right to request any personally identifiable information we have on file about you.

If you would like a copy of this information you can contact us at [email protected] to request it. We will require proof of your identity before sharing this information. If you find that our information is out of date you may ask us to update that information.

In the event that your information is within one of our 3rd party Email Marketing programs listed above you can always change or update that information as well as your settings by following the links at the bottom of any emails sent to you by our company.

You may ask us to delete all of your information. It may not be possible for us to delete all of the information we hold about you where we are fulfilling a transaction or have a legal basis to retain the information, however, feel free to contact us and we can assist you with your request.

If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements. If you make a request to obtain a copy of or port your personal data, to the extent we have any, we will respond within a reasonable time frame.

Email Marketing —

If you are receiving emails from us and no longer wish to have them to sent to you all you need to do is click the ‘manage subscription’ or ‘unsubscribe’ buttons at the bottom of any and all emails. This does not apply to transactional based emails where are required to send you proof of purchase and fulfillment of our contractual obligations to deliver purchased products to you.

With respect to personal data that we do not maintain or control, you may also may also make your request to access, view, update, delete or port your personal data (where available), or to update your subscription preferences, by following the links at the bottom of any email communication you receive by clicking the “unsubscribe” link or the “manage subscription” link.

We utilize 5 different email-marketing platforms due to the fact that each one has features and functionality that the other does not. We use each platform for a specific type of correspondence with you; however, you are able to opt-out at the bottom of any and all emails that we send to you. If you’d like us to remove you from every platform at once you can send that request to [email protected] with the subject line “Opt Out Of Email Marketing” and we will take care of that request immediately.

For other requests, contacting us at [email protected] with the subject line “Opt Out Of Email Marketing” and we will take care of that request immediately.

To our knowledge all of our data controllers have sent out updates that they are now GDRP compliant. We will continue to monitor and make sure that we only utilize companies who are in compliance with all regulatory requirements.

Notice to California Residents – Your California Privacy Rights:

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

Under California Law SB 27, California residents have the right to receive, up to twice a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to Company, to the email address provided in our contact information and please include the phrase “California Privacy Request” in the subject line, the domain name of the Web site you are inquiring about, along with your name, address and email address. We will respond to you within forty-five days of receiving such a request. More information about your rights is below:

Privacy Notice for California Residents —

Effective Date: January 1, 2020
Last Reviewed on: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended, (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Website collects 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, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:

CategoryExamplesCollected
A. Identifiers.A real name, Internet Protocol address, email address, or other similar identifiers.YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, 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.NO
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).NO
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YES
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NO
F. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.YES
G. Geolocation data.Physical location or movements.YES
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.YES
I. Professional or employment-related information.Current or past job history or performance evaluations.NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).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.NO
K. Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.YES

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

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

  • Directly from you. For example, from forms you complete on our website.
  • Indirectly from you. For example, from observing your actions on our Website or interactions with our ads, promotions, emails, forums, web browsers and third-party advertisers.
  • We may receive personal information from other third-party sources such as social media platforms with which you choose to interact.  For example, if you connect your social media account(s) to your customer account, the social media company may share information with us about your use of their services, including information about your profile, contacts, and viewed or liked content.  We encourage you to read the applicable privacy policies of social media platforms with whom you choose to interact. We have no responsibility for the data collection and use practices of the social media companies.

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 you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • 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.
  • To customize, tailor and present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To complete a transaction.
  • To offer similar products and services to you in the future.
  • To contact you by automatic means, which may include the use of an automatic telephone dialing or SMS text system and/or autodialer.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may share your personal information with the following categories of third parties:

  • Vendors who provide SMS marketing, opt-in/out, outbound automated messaging;
  • Vendors who provide email marketing campaign and promotions technology;
  • Vendors who provide sales tax compliance services;
  • Vendors who provide metrics, trends data and analytics reports;
  • Vendors who provide sales conversion and guided user experience technology;
  • Vendors who provide technology that helps customize your user experience;
  • Vendors who provide fraud protection technology;
  • Vendors who provide live streaming training platforms;
  • Vendors who provide technology to process, track and fulfill orders; and
  • Vendors who provide customer service and support via email and telephone.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed personal information for the following business purposes:

  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Short-term, transient use, provided the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
  • Undertaking internal research for technological development and demonstration; and
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your 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.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The 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).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable 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 provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please send a message to [email protected]. 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.

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 forty-five (45) days of its receipt. If we require more time (up to [45/90] 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 readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

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 goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us at [email protected].

IF YOU ARE UNDER EIGHTEEN YEARS OF AGE, YOU ARE NOT PERMITTED TO ACCESS THIS WEB SITE FOR ANY REASON. DUE TO THE AGE RESTRICTIONS FOR USE OF THIS WEB SITE, NO INFORMATION OBTAINED BY THIS WEB SITE, FALLS WITHIN THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) AND IS NOT MONITORED AS DOING SO.

Where to Direct Questions About Our Privacy Policy.

If you have any questions about this Privacy Policy or the practices described herein, you may contact us through the contact information provided on this Web site.

We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

To easily access, view, update, delete or port your personal data (where available), or to update your subscription preferences, please sign into your Account and visit “User Profile.” Please Contact us [email protected] for additional information and guidance for accessing, updating or deleting data.

Revisions to This Policy

Our company reserves the right to revise, amend, or modify this policy, our Terms of Service agreement, and our other policies and agreements at any time and in any manner, by updating this posting. Your use of this site after such changes are implemented constitutes your acknowledgement and acceptance of these changes. Please consult this privacy statement prior to every use for any changes.

Contact Information

If you have any questions or comments about this notice, the ways in which We collect and uses your information as described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows