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Privacy Policy

Last Updated: 06/17/24

MOQ1 (“Company,” “we,” “us,” or “our”) respects the privacy of our users and has created this Privacy Policy to describe our policy about the collection, use, security and disclosure of information we obtain from users of our website and all other websites, mobile sites, applications, platforms and tools where this Privacy Policy appears or is linked, and through the use of our services (“Site”) .   This Privacy Policy also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

 We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States, the United Kingdom General Data Protection Regulation, and the General Data Protection Regulation which applies across the European Union, and we are responsible as “controller” of that personal information for the purposes of those laws.

We encourage you to take time to read and understand this Privacy Policy, and to contact us if you have any questions or concerns regarding this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the “Terms and Conditions” for this Site. 

By using the Site, creating an account, or providing information to us (by any means, whether in correspondence, via our Site, or otherwise) you acknowledge that you have read, understood, and consent to our collection, use and disclosure of your information, including personally identifiable information, as described in this Privacy Policy.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR OUR PRACTICES, YOU MAY NOT USE OUR SITE. THIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME AND YOUR CONTINUED USE OF OUR SITE CONSTITUTES YOUR ACCEPTANCE OF THOSE CHANGES. WE ENCOURAGE YOU TO REVIEW THIS PRIVACY POLICY PERIODICALLY.

1. Information Collected by the Company

We receive and store any information you enter on this Site or give us in any other way, including information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“personal information”), when you register for an account, access our Site, including certain content or features, place orders, enter into Company programs or offerings, or if you send us personal correspondence such as emails. We may collect the following types of personal information about you as described below:

      (a) Personal information you provide to us,

      (b) Personal information we may automatically collect, and

      (c) Personal information we may receive from third parties.


A. Personal Information You Provide to Us

In using our Site, you may provide us with personal information, which may include, but are not limited to, the following:

  • Identifiers, e.g. your contact information such as name, email address, postal address and telephone number(s), country of residence;
  • Characteristics of protection classifications, e.g. demographic information such as birth date;
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, e.g. account information and log in credentials, including unique identifiers such as username and password, payment and transaction information including credit card or bank information
  • Internet or other electronic network activity information, e.g. your device information;
  • Commercial information, e.g. products ordered and any related customization;
  • Preferences for communications;
  • Communications and opinions in chat rooms, message boards, forums, surveys, polls, and online forms;
  • Sensory data, e.g. photos and/or videos;
  • Professional or employment-related information, e.g. type and nature of business and where located; and
  • Any additional information that we describe to you, when we collect your data with your consent.

B. Personal Information We May Automatically Collect About You

We may automatically receive and store certain types of non-personally identifiable information, including, but not limited to, the following:

Information about your use of our Site

  • Commercial information about any orders you place through the Site, such as your order identification number, items ordered and the cost of your order; 
  • Internet or other electronic network activity information 
    • Your interactions with other users on the Site, the type of web browser you are using, the website that led you to our Site, the website you go to after leaving our Site, the dates and times you access our Site; and the pages you view on our Site and your movement and activity within the Site, which is aggregated with other personal information, IP address (which is the number associated with the service through which you access the Internet, such as through your Internet service provider);
    • Domain server from which you are using the Site;
    • Type of computer, search engine used, operating system, or platform you use;
    • Mobile device information, including the type of device you use, operating system version, and the device identifier.
  • We may also collect Site visitation statistical information through cookies, tools such as Google Analytics, and other technology, as further described in the “Cookies” Section, to speed navigation of the Site by allowing the Site to recognize each user and his or her access privileges and to track the user’s usage of the Site.

Log Files
The Site server automatically recognizes the Internet Uniform Resource Locator (“URL”) from which you access the Site. We may also log your Internet protocol (“IP”) address, which may be helpful, for example, for system administration and troubleshooting purposes. (An IP address indicates the location of your computer on the Internet.)

C. Personal Information We May Receive from Third Parties

If you access the Site through a third-party social media account (such as OpenID, Google+, Facebook. LinkedIn, Twitter, Instagram), third party data providers, and other third party sources, we may access information about you from that third-party source, including your user ID for the third-party source and certain information from your profile for that third-party source (such as your location data, profile information, your activities on social media accounts). The Site may combine information that we collect with information from all third-party websites.

When you provide personal information to us on a third-party website or platform, the personal information you provide may also be separately collected by the third-party website or the social media platform. Please review the privacy policies of the applicable third-party website or social media platform for their privacy practices.

2. How Company Uses the Information it Collects and Why

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

  • To comply with our legal and regulatory obligations;
  • For the performance of our contract with you or to take steps at your request before entering into a contract;
  • For our legitimate interests or those of a third party; or
  • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information forOur reasons
To provide you with the Site and products, and related promotions, newsletters, programs, education, and information you request;
To respond to your inquiries and provide you with requested information and other communications, including by email or chat, and including alerts, notification of promotions, contests, and events
For billing and payment processing
To facilitate the services you request, to create accounts and allow use of services and ordering of products on the Site
For the performance of our contract with you or to take steps at your request before entering into a contract
To maintain, improve, customize, or administer the Site, perform business analyses, or other internal purposes to improve the quality of our business and the SiteFor our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
To comply with any applicable laws and regulations and respond to lawful requests 
To prevent and detect fraud against you or Company and for detecting security breaches
To maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets and our business
For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you and to ensure the network and information security of our Site
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodiesTo comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use, and to enforce our Terms and Conditions.For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
To resolve disputesTo comply with our legal obligations
For our legitimate interests or those of a third party, i.e. to protect our company from legal claims
To troubleshoot problems and identify and repair errors in our Site’s functionalityFor our legitimate interests or those of a third party, i.e. to ensure the network and information security of our Site and to be as efficient as we can so we can deliver the best service for you at the best price
Operational reasons, such as improving efficiency, training and quality controlFor our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive informationFor our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures
To improve our marketing and promotional efforts, improve our content and product offerings, and customize the Site’s content, layout and services
To perform analytics for business purposes and business intelligence, such as monitoring traffic to our Site, counting ad impressions
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systemsFor our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating and enhancing customer recordsFor the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Ensuring safe working practices, staff administration and assessmentsTo comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of selected third parties to:

  • existing and former customers;
  • third parties who have previously expressed an interest in our services;
  • third parties with whom we have had no previous dealings.

Including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and other third parties, provided that you have not already opted-out of receiving such communications

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information we hold is among the assets transferredFor our legitimate interests or those of a third party, i.e. where it is necessary for the sale of the business or shares to disclose the data to a potential buyer
External audits and quality checks, e.g. for the audit of our accountsFor our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards to comply with our legal and regulatory obligations.

We may also anonymize, aggregate or de-identify personal information so the end-product does not identify you or any other individual. For example, we may use this information to generate norms by industry, geography, level, etc., enable us to understand where our services are being utilized, conduct ongoing validation studies, compile reports, and improve the services. Such aggregated, anonymized or de-identified information is not considered personal information for purposes of this Privacy Policy and we may use it for any purpose.

3. Cookies

We and our third-party providers and advertisers, use cookies and other technologies to optimize the functionality of the Site, to help us understand how the Site is used and to provide users with interest-based content or advertising based upon their browsing activities and interests.

Cookies

Cookies are small text files of information stored by the Internet browser on your computer’s hard drive. We may use these cookies to collect browsing data to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal or confidential information and are not spyware. 

There are a number of different types of cookies, however, our Site uses:

  • Essential or Strictly Necessary – These cookies are necessary to the core functionality of our Site and some of its features, such as access to secure areas.
  • Performance and Functionality – These cookies are used to enhance the performance and functionality of our Site. For example, we may use these cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and your geographic location. These cookies are nonessential to the use of our Site, however, without these cookies, certain functionality may become unavailable. Third-party cookies are used.
  • Targeting – These cookies are used to make advertising messages more relevant to you. They prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and in some cases select advertisements that are based on your interests. Our Company sometimes shares online data collected through these cookies with our advertising partners. This means that when you visit another Site, you may be shown advertising based on your browsing patterns on our Site. In some case it is possible to opt-out from personally targeted advertising. We may use Google AdSense, Google AdMob and other third-party advertising companies to serve advertising when you visit the Site. 
  • Analytics and Customization – Our Company uses these cookies and technologies to analyze how the Site is accessed, used, or performing in order to improve your user experience and to maintain, operate and continually improve the Site. For example, we use Google Analytics on the Site to collect: page url/page title and user browser/system information, which includes browser type, referrer, language, java/flash support, IP address, and ad-serving data. For information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, visit Google’s “How you can control the information collected by Google on these sites and apps” article available here. 
  • Unclassified – These are cookies that have not yet been categorized. We are in the process of classifying these cookies with the help of their providers.

Web Beacons
Our Site contains electronic images known as web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns. We use a third party to gather information about how you and others use our Site. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our Site is used.

Targeted Advertising
Targeted Advertising (also known as online behavioral advertising) uses information collected on an individual’s web browsing behavior such as the pages they have visited or the searches they have made. Third parties collect this information by placing or accessing cookies in your browser when you visit this Site, or other, websites. If you would like to learn more about the third party advertisers that may be aware of the fact that you visit the Site, and to understand your choices about having such advertisers’ cookies turned off, please visit http://www.aboutads.info/choices/, http://www.youronlinechoices.com/, or http://www.networkadvertising.org/.

How to Manage Cookies
You have the right to decide whether to accept or reject certain cookies. You can set your browser not to accept cookies, and the above websites tells you how to remove cookies from your browser. However, in a few cases, some of our Site features may not function as a result. Essential cookies cannot be rejected, as they are strictly necessary to provide you with our Site.

4. Do Not Track

We do not track users across the web and therefore do not respond to web browser “do not track” signals. 

We do not authorize third parties to collect personal information from your visit of the Site for third party use without your consent.

5. Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our Site, our products, or our services, including exclusive offers, promotions or new products or services.

We have a legitimate interest in processing your personal information for promotional purposes (see below “How Company Uses the Information it Collects and Why”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us by using one of the methods listed in the “Contact Information” Section below;
  • Using the “unsubscribe” link in emails or “STOP” number in texts; or

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With

We routinely share personal information with:

  • Our affiliates;
  • Service providers we use to help deliver our products or services to you, such as third-party payment providers, warehouses and delivery companies;
  • Other third parties we use to help us run our business, such as marketing agencies, software-as-a-service platforms, database management companies, website hosts;
  • Third parties approved by you, including sites you choose to link your account to (e.g. social media sites you choose to link your account to or third-party payment providers).

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. 

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

The Company may disclose any information about you if required by law or under the compulsion of legal process. We may also disclose information about you if, in our sole discretion, we believe such disclosure is necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, or other activity that is illegal or may expose us or you to legal consequences.

7. Data Retention

We will keep your personal information while you have an account with us or while we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. Third Party Links

Our Site may contain links to other websites that are not owned or controlled by us, including links to social media platforms, or may redirect you off our Site or away from our products and services to other websites for information or other services. This Privacy Policy only applies to information collected by our Site. We are not responsible for the privacy and security practices of those other websites or social media platforms, the information they may collect (which may include IP address), or for how that party may use or disclose any information you may provide to them. We urge you to exercise caution before providing them with your personal information and you should refer to such third parties’ privacy policies on their sites to determine their respective privacy practices. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, social media platform, content, or of any products or services provided by such third party. We do not control, nor are we responsible for, such third party websites, product or service offerings. Nor do we review the third party’s privacy policy for information on its data processing practice.

You should contact the site administrator for such third party website if you have any complaints, claims, concerns or questions regarding such third party website or its privacy practices.

9. Security

No computer system or information can ever be fully protected against every possible hazard. In order to help protect your information and the information and data contained on our Site, the Company employs reasonable and appropriate technical, physical and administrative security measures to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. 

THE COMPANY CANNOT GUARANTEE SECURITY. THE COMPANY ASSUMES NO RESPONSIBILITY OR LIABILITY FOR DISCLOSURE OF YOUR PERSONAL INFORMATION. WE DO NOT GUARANTEE THAT YOUR PERSONAL INFORMATION WILL NOT BE MISUSED BY THIRD PARTIES. WE ARE NOT RESPONSIBLE FOR CIRCUMVENTION OF ANY PRIVACY SETTINGS OR SECURITY FEATURES.

If you believe that your personal information has been accessed or acquired by an unauthorized person, please promptly contact us at Legal@MyLocker.net so that necessary measures can quickly be taken.

10. Where Your Personal Information is Held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the country where we originally collected your personal information. For more information, including on how we safeguard your personal information when this occurs, see below: “International Transfers of Personal Information”.

11. International Transfers of Personal Information

To bring you our Site, we operate globally. Therefore, it is sometimes necessary for us to share your personal information outside the country where we originally collected your personal information, e.g.:

  • With our offices in the United States;
  • With your and our service providers located throughout the world;
  • If you are based outside the European Economic Area; or
  • Where there is an international dimension to the services we are providing to you.

These outside countries may not have the same data protection laws as the country where we originally collected the personal information. In particular, you are advised that the United States uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. We will, however, ensure the transfer complies with data protection law. If you are located outside the United States, we will only transfer your personal information if:

  • you provide your explicit consent;
  • the country to which the personal information will be transferred has been granted an appropriate adequacy decision by your local supervisory authority; or
  • we have put in place appropriate safeguards in respect of the transfer, for example we have entered into the appropriate standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a supervisory authority.

Our Company is headquartered in the United States and utilizes service providers both in the United States and throughout the world. As such, our Company and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

Where the laws of your country allow you to do so, by using the Site or our services, you consent and authorize our Company to transfer, store, and use all such information in the United States and any other country where we operate which may not offer an equivalent level of protection to that required in the country where you reside and to the processing of that information by us on its servers located in the United States as described in this Privacy Policy. If you do not want your personal information transferred to the United States and any other country where we operate, please do not submit any information to us or use our Site or services.

If you would like further information, please contact us (see “Contact Information” below).

12. Children Under Thirteen

Our Site is not directed to children, and you may not use our Site if you are under the age of 18. If you are under age 18, do not use our services, access the Site, or provide any information about yourself including, without limitation, your name, address, email address or any screen name or user name you may use. The Company does not knowingly accept personal information from anyone under the age of 13. By using the Site and/or providing personal information, you represent and warrant that you are over the age of 13. If we learn that we have collected or received personal information from a child under age 13 without verification of parental consent, in compliance with the Children’s Online Privacy Protection Act, we will purge such information from our database and cancel the corresponding accounts. If you believe we may have any information from or about a child under age 13, please see our “Contact Information” Section below. Please visit the FTC’s website at www.ftc.gov for tips on protecting children’s privacy online.

13. Changes to Our Privacy Policy

This Privacy Policy was published on the date “Last Updated” above. The Company may amend this Privacy Policy from time to time by posting the amended terms on this Site. You are responsible for regularly reviewing this Privacy Policy and all such amended terms. By viewing, using or accessing the Site after any amended terms have been posted, you consent to the Privacy Policy of the Site then in effect.

14. Contact Information

If you have any questions, comments, complaints or concerns about this Privacy Policy or your privacy, contact us at Legal@MyLocker.net.

15. Your Rights and Choices

  • If you are located in the European Economic Area or if you are a resident of Canada, California, Colorado, Connecticut, Iowa, Virginia, or Utah please go to our Privacy Notice Addendum to learn about additional rights you may have under applicable data protection laws.

Privacy Notice Addendum

This Privacy Notice Addendum (“Notice”) supplements the information contained in the above Privacy Policy and applies solely to all visitors, users, and others who reside in Canada or the State of California, Colorado, Connecticut, Iowa, Virginia, or Utah (“consumers” or “you”). We adopt this Notice to comply with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), General Data Protection Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), the Colorado Privacy Act of 2021, the Connecticut Data Privacy Act of 2022, the Iowa Consumer Data Protection Act of 2023, the Utah Consumer Privacy Act of 2022, the Virginia Consumer Data Protection Act of 2023, and certain other privacy and data protection laws, as applicable (collectively, the “Statutes”). Any terms defined in the Statutes will have the same meaning when used in this Notice. Any terms used in this Notice but undefined herein shall have the meaning provided in the Privacy Policy.

As further set forth in our Privacy Policy, we may collect certain information that is (i) linked or reasonably linkable to an identified or identifiable individual or natural person, or (ii) that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household, or (iii) as further defined in the Statutes as “Personal Data” or “Personal Information,” as further set forth below:

Categories of Personal InformationExamples (not intended to be exhaustive)Collected
IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiersYes
Information that identifies, relates to, describes, or is capable of being associated with, a particular individualHis or her 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 informationYes
Characteristics of protected classifications under California or federal lawAge (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
Commercial informationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendenciesYes
Biometric informationA retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometryNo
Internet or other electronic network activity informationBrowsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisementYes
Geolocation dataPhysical location or movementsNo
Sensory dataAudio, electronic, visual, thermal, olfactory, or similar informationNo
Professional or employment-related informationCompensation, business contact information, paystubs for employment verificationYes, if an individual applies for a job with us
Education information, defined as information that is not publicly available personally identifiable information (as defined in the Family Educational Rights and Privacy Act (FERPA))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 recordsNo
Sensitive personal information(1) Personal information that reveals: (A) A person’s social security, driver’s license, state identification card, or passport number; (B) A person’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) A person’s precise geolocation; (D) A person’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) The contents of a person’s mail, email, and text messages unless the business is the intended recipient of the communication; (F) A person’s genetic data;
(2) the processing of biometric information for the purpose of uniquely identifying a consumer;
(3) personal information collected and analyzed concerning a consumer’s health, or a personal information collected and analyzed concerning a consumer’s sex life or sexual orientation
Only if an individual applies for a job with us (driver’s license and social security number)
Inferences drawn from any of the information identified aboveProfile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudesYes

2. Canada’s Personal Information Protection And Electronic Documents Act

The Personal Information Protection and Electronic Documents Act (PIPEDA) provides consumers who are Canadian residents with specific rights regarding their Personal Information. This section describes your rights under PIPEDA and explains how to exercise those rights.

  • You have a right to know how your Personal Information will be used. We will explain why we need your Personal Information before or when we collect it, if the purpose is not already clear.
  • We will collect Personal Data only for the purposes we’ve identified or for the primary uses described in our Privacy Policy. We shall collect information by fair and lawful means only.
  • We will not use or disclose your Personal Data other than for the purposes for which it was collected unless we receive your consent or unless we are required or permitted to by law.
  • We will keep your Personal Information only for as long as it needs to for the purposes identified in our Privacy Policy, as required by law, or as necessary to resolve any disputes you may have concerning our Portal or Services. We will follow internally set guidelines and use care in the disposal, destruction, or de-identification of Personal Information to prevent unauthorized parties from gaining access to such Personal Information.
  • We will maintain accurate, complete and up-to-date Personal Information as required for the identified purposes associated with its collection. Please let us know if your contact or other Personal Information changes.
  • Upon your written request, and subject to exceptions as permitted or mandated by law, we will inform you of the existence, use and disclosure of your Personal Information and will give you access to that Personal Information. You may challenge the accuracy and completeness of your Personal Information and have it amended as appropriate.

Complaint Compliance

We maintain procedures for addressing and responding to all inquiries or complaints from you about our handling of Personal Information. We will inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures. We may seek external advice where appropriate before providing a final response to individual complaints. We shall investigate all complaints. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and procedures.


3.  Your Rights Under the GDPR

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws.

Right to AccessThe right to be provided with a copy of your Personal Data (the right of access)
Right to RectificationThe right to require us to correct any mistakes in your Personal Data
Right to be ForgottenThe right to require us to delete your Personal Data—in certain situations
Right to Restriction of ProcessingThe right to require us to restrict processing of your Personal Data —in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data PortabilityThe right to receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object

The right to object:

  • at any time to your Personal Data being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your Personal Data, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-MakingThe right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

4. For further information on each of those rights, including the circumstances in which they apply, see the guidance from the European Data Protection Supervisor on individual rights under the General Data Protection Regulation

5. How to File a GDPR Complaint

6. We hope that we can resolve any query or concern you raise about our use of your information.

7. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. The current list of supervisory authorities who may be contacted are provided here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

8. Your Rights Under the CCPA and CPRA

The California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA) provides consumers who are California residents with specific rights regarding their Personal Information. This section describes your rights under the CCPA and CPRA and explains how to exercise those rights.

Disclosure of Personal Information We Collect About You

You have the right to know:

  • The categories of Personal Information we have collected about you;
  • The categories of sources from which the Personal Information is collected;
  • Our business or commercial purpose for collecting or selling Personal Information;
  • The categories of third parties with whom we share Personal Information, if any; and
  • The specific pieces of Personal Information we have collected about you.
Personal Information Sold, Shared, Disclosed, or Used for a Business Purpose

In connection with any Personal Information we may sell or disclose to a third party for a business purpose, you have the right to know:

  • The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and
  • The categories of Personal Information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your Personal Information. If you exercise your right to opt-out of the sale or disclosure of your Personal Information, we will refrain from selling your Personal Information, unless you subsequently provide express authorization for the sale of your Personal Information.
We do not sell or share your Personal Information for monetary or other valuable consideration.

Right to Limit Use and Disclosure of Sensitive Personal Information.You have the right to opt-out of the use and disclosure of your sensitive Personal Information for anything other than supplying requested goods or services.
We do not use or disclose any of your sensitive Personal Information for any reason other than supplying the requested goods or services.
Right to CorrectionYou have the right to request correction of inaccurate Personal Information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Information.
Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your Personal Information from our records; and
  • Direct any service providers to delete your Personal Information from their records.

Please note that we may not delete your Personal Information if it is necessary to:

  • Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.

9. Personal Information We Sold or Disclosed for a Business Purpose.

In the preceding 12 months, we have not sold any third parties any categories of personal information.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal InformationCollected
IdentifiersYes
Information that identifies, relates to, describes, or is capable of being associated with, a particular individualYes
Commercial informationYes
Internet or other electronic network activity informationYes
Professional or employment-related informationYes, if an individual applies for a job with us
Sensitive personal informationOnly if an individual applies for a job with us (driver’s license and social security number)
Inferences drawn from any of the information identified aboveYes

10. Your Rights Under the Colorado Privacy Act of 2021

The Colorado Privacy Act provides consumers who are Colorado residents with specific rights regarding their Personal Data. This section describes your rights under the Colorado Privacy Act and explains how to exercise those rights.

Right to Opt-Out

You have the right to opt out of the processing of Personal Data concerning you for the purposes of:

  • Targeted Advertising;
  • The Sale of Personal Data; or
  • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
Right of AccessYou have the right to confirm whether we are processing Personal Data concerning you and to access your Personal Data.
Right to CorrectionYou have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
Right to DeletionYou have the right to delete Personal Data concerning you.
Right to Data PortabilityWhen exercising the right to access Personal Data, you have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
You may exercise this right no more than two times per calendar year
Right to AppealWe hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.
The Colorado Privacy Act also gives you right to contact the Colorado Attorney General if you have concerns about the results of your appeal.

11. Your Rights Under the Connecticut Data Privacy Act of 2022

The Connecticut Data Privacy Act of 2022 provides consumers who are Connecticut residents with specific rights regarding their Personal Data. This section describes your rights under the Connecticut Data Privacy Act of 2022 and explains how to exercise those rights.

Right to AccessYou have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.
Right to CorrectionYou have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
Right to DeletionYou have the right to request that we delete Personal Data provided by, or obtained about, you.
Right to Data PortabilityYou have the right to obtain a copy of your Personal Data processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means.
Right to Opt-Out

You have the right to opt out of the processing of the Personal Data for purposes of:

  • Targeted advertising;
  • The sale of personal data; or
  • Profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer.
Right to AppealWe hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.

12. Your Rights Under the Iowa Consumer Data Protection Act of 2023

The Iowa Consumer Data Protection Act of 2023 provides consumers who are Iowa residents with specific rights regarding their Personal Data. This section describes your rights under the Iowa Consumer Data Protection Act of 2023 and explains how to exercise those rights.

Right to AccessYou have the right to confirm whether we are processing your Personal Data and to access such Personal Data.
You may exercise this right no more than twice annually.
Right to DeleteYou have the right to request we delete Personal Data provided by you.
Right to Data PortabilityYou have the right obtain a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically practicable, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means.
Right to Opt-OutYou have the right to opt out of the sale of Personal Data.
We do not sell your Personal Data.
Right to AppealWe hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.
The Iowa Consumer Data Protection Act of 2023 also gives you right to contact the Iowa Attorney General if you have concerns about the results of your appeal.

13. Your Rights Under the Utah Consumer Privacy Act of 2022

The Utah Consumer Privacy Act of 2022 provides consumers who are Utah residents with specific rights regarding their Personal Data. This section describes your rights under the Utah Consumer Privacy Act of 2022 and explains how to exercise those rights.

Right to AccessYou have the right to confirm whether we are processing your Personal Data and access your Personal Data.
Right to DeleteYou have the right to delete your Personal Data that you provided to us.
Right to Data Portability

You have the right to obtain a copy of your Personal Data that you previously provided to us, in a format that:

  • To the extent technically feasible, is portable;
  • To the extent practicable, is readily usable; and
  • Allows you to transmit the data to another controller without impediment, where the processing is carried out by automated means.
Right to Opt-Out

You have the right to opt-out of the processing of your Personal data for purposes of:

  • Targeted advertising; or
  • The sale of personal data.

14. Your Rights Under the Virginia Consumer Data Protection Act of 2023

The Virginia Consumer Data Protection Act of 2023 provides consumers who are Virginia residents with specific rights regarding their Personal Data. This section describes your rights and explains how to exercise those rights under the Virginia Consumer Data Protection Act of 2023.

Right to AccessYou have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.
You may exercise this right no more than twice annually.
Right to CorrectionYou have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
Right to DeleteYou have the right to request we delete Personal Data provided by or obtained about you.
Right to Data PortabilityYou have the right to obtain a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means.
Right to Opt-Out

You have the right to opt out of the processing of the Personal Data for purposes of:

  • Targeted advertising;
  • The sale of personal data; or
  • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
Right to AppealWe hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.
The Virginia Consumer Data Protection Act of 2023 also gives you right to contact the Virginia Attorney General if you have concerns about the results of your appeal.

15. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please:

  • Call us, toll-free, at 877-898-3366; or
  • Contact us using one of the available methods in the “How to Contact Us” section of our Privacy Policy.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address and customer or matter reference number);
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

You may use a representative, called an “authorized agent,” to submit a request to us. An authorized agent means a natural person, or a business entity registered with the California Secretary of State, that you have authorized to act on your behalf. In order to protect your privacy, Company requires you to confirm that you have provided the authorized agent permission to submit the request and you must provide the authorized agent with signed permission. “Signed” means that the written attestation, declaration, or permission has either been physically signed or provided electronically pursuant to the Uniform Electronic Transactions Act. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required. Company may deny a request from an authorized agent that does not submit proof that they have been authorized to act on your behalf. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above. 

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

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