Last Updated: 01/01/2020
CONFLICT BETWEEN THIS POLICY AND LOCAL LAWS AND REGULATIONS
INFORMATION WE COLLECT
We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
- Personal Identifiers (eg., name, social security number, taxpayer identification number, driver’s license number, date of birth, IP address, security questions & answers);
- Contact Information (eg., mailing address, email address, phone number);
- Financial Information (eg., bank account number, credit card number, expiration date);
- Commercial Information (eg., internal or third-party customer account numbers, product interest and purchase history);
- Audio/Visual Information (eg., call recordings);
- Characteristics of Protected Classifications (eg., age);
- Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.
We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business or a business contact.
Usage Data and Site Activity
We automatically collect information in connection with the actions you take on the Site (“Usage Data”). For example, each time you use the Site, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.
We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to such recording and retention of communications.
HOW WE COLLECT INFORMATION
We may ask you to provide us with Personal Information when you communicate with us (online or offline), when you place an order, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as the companies whose products we market and sell.
Cookies & Other Automated Tools
We use the following types of cookies:
- Session Cookies: Session cookies keep track of you or your information as you move from page to page within the Site and are typically deleted once you close your browser. For example, session cookies allow your online shopping cart to function properly.
- Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the Site. For example, persistent cookies may allow us to remember your preferences.
- Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.
We employ software technology that enables us to track certain aspects of a user’s visit to the Site. This technology helps us better manage content on the Site by informing us what content is effective, how consumers engage with the Site, and how consumers arrive at and/or depart from the Site. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.
Online Behavioral Advertising
Information from Advertisements
If you arrive at the Site via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).
From time to time we may request Personal Information from consumers via surveys. Participation in these surveys is completely voluntary and you have a choice whether or not to disclose Personal Information. The requested information typically includes personal identifiers and contact information.
Sweepstakes and Contests
We may offer opportunities for consumers to participate in sweepstakes or contests. Participation in these sweepstakes or contests is completely voluntary but participation usually requires providing certain Personal Information. The requested Personal Information typically includes personal identifiers and contact information.
Social Media Widgets
The Site may include social media features, such as the Facebook, YouTube, LinkedIn, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.
THIRD-PARTY PERSONAL INFORMATION COLLECTION ON SITE
Certain third parties collect Personal Information and/or Usage Data from users of our Site using automatic information collection tools such as cookies and tracking pixels. The collection, use, and disclosure of Personal Information and/or Usage Data by these third parties is governed by their privacy policies.
HOW WE USE AND SHARE INFORMATION
We use Personal Information for internal purposes, such as to:
- Provide you with the Site and Services;
- Process or complete transactions you requested;
- Improve the Site and Services, including customization and personalization;
- Notify you of products and services via mail, email, telephone, and/or text messaging;
- Communicate with you about the Site, the Services, and other matters via mail, email, telephone, and/or text messaging; and
- Compile information and analyses to enhance the customer experience and improve our business.
If you provide a testimonial, we may post it publicly on the Site or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
We may establish a relationship with other businesses to provide services to us (“Service Providers”), including:
- Online hosting and maintenance;
- Marketing and promotion design and management;
- Communication facilitation such as printing and mailing or telecommunication services;
- Payment processing;
- Management of access to services;
- Data storage and management;
- Data analytics; and
- Identity and contact information validation.
We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
We share the following types of Personal Information with one or more Service Providers: personal identifiers; contact information; financial information; commercial information; audio/visual information; characteristics of protected classifications; internet or other electronic network activity; inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may share your Personal Information with Third Parties to market products or services likely to be of interest to you, or to provide you with special offers and opportunities or to complete transactions you have requested.
We share the following types of Personal Information with one or more Third Parties: personal identifiers; contact information; financial information; commercial information; audio/visual information; characteristics of protected classifications.
We may use your Personal Information to market products or services likely to be of interest to you, or to provide you with special offers and opportunities, via email. With respect to commercial email communications from us, you may opt out of these emails via a link in the footer of all commercial email messages.
SUMMARY OF PERSONAL INFORMATION COLLECTION, USE, AND DISCLOSURE
|Categories of PI we Collect||Categories of Sources from which we Collect PI||Our Business Purposes for Collecting, Using, Sharing, or Selling PI||Whether we Sell PI to Third Parties for a Business Purpose||Categories of Third Parties to whom we Share or Sell PI|
|Audio/Visual Information||Consumers||Facilitating consumer transactions; maintaining records of consumer transactions; payment processing; business non-marketing analytics; general business recordkeeping||Yes||Providers of products and services we sell|
|Characteristics of Protected Classification||Consumers; Identity verification services; Providers of products and services we sell||Marketing analytics and ad distribution; facilitating consumer transactions; maintaining records of consumer transactions; business non-marketing analytics; general business recordkeeping||Yes||Providers of products and services we sell|
|Commercial Information||Consumers; Providers of products and services we sell||Marketing analytics and ad distribution; facilitating consumer transactions; maintaining records of consumer transactions; payment processing; business non-marketing analytics; general business recordkeeping||Yes||Providers of products and services we sell|
|Contact Information||Consumers; Identity verification services; Providers of products and services we sell||Marketing analytics and ad distribution; facilitating consumer transactions; maintaining records of consumer transactions; payment processing; business non-marketing analytics; general business recordkeeping||Yes||Providers of products and services we sell|
|Financial Information||Consumers||Facilitating consumer transactions; payment processing; maintaining records of consumer transactions; business non-marketing analytics; general business recordkeeping||Yes||Providers of products and services we sell|
|Inferences from PI||Infinity; Data analytics (marketing & non-marketing) firms||Marketing analytics and ad distribution; business non-marketing analytics;||No||N/A|
|Personal Identifiers||Consumers; Identity verification services; Providers of products and services we sell||Marketing analytics and ad distribution; facilitating consumer transactions; maintaining records of consumer transactions; payment processing; business non-marketing analytics; general business recordkeeping||Yes||Providers of products and services we sell; Marketing services|
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially-reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Site or Services, you do so at your own risk.
Please be aware that third-party websites accessible through the Site or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.
COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, Clients, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
HOW LONG WE RETAIN YOUR DATA
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. Generally, we retain Personal Information for approximately ten (10) years after our relationship with you has ended, but the term for which we retain your Personal Information may be longer or shorter. We do so in accordance with our data retention policies and applicable law.
The Site and Services are not intended for children under the age of 18 and we do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.
ADDITIONAL CONSUMER RIGHTS
If you are a resident of California, you have additional rights to access and control your Personal Information, including a right to request that we disclose the Personal Information we collect, use, disclose, and sell. We have decided to extend the same rights to every consumer from whom we collect Personal Information.
Right to Know
You have the right to request twice per 12-month period that we provide you (i) the categories and specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of third parties with whom we shared your Personal Information; and (v) the categories of third parties to whom we sold your Personal Information.
To request access to your Personal Information and the information listed above, you may submit a request through our Access Request Page or call us at 1-833-933-2437. If you choose to call us, please review the Access Request Page first because it contains important descriptions of the process we use to verify and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the Access Request Page.
Right to Deletion
You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies (in California) or a policy exemption applies (in all other states) such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.
To request deletion of your Personal Information and the information listed above, you may submit a request through our Deletion Request Page or call us at 1-833-933-2437. If you choose to call us, please review the Deletion Request Page first because it contains important descriptions of the process we use to verify and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the Deletion Request Page.
Right to Opt-Out from the Sale of Personal Information
You have the right to direct us not to sell your Personal Information to third parties. You may exercise your Right to Opt-Out by calling us at 1-833-933-2437 or submitting a request via our Do Not Sell My Personal Information web page. You may also designate an authorized agent to submit a request on your behalf as described on the Do Not Sell My Personal Information page.
California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our Site and Services do not respond to “do not track” signals.
Infinity Sales Group, LLC
Attn: Legal Dept.
5201 Congress Ave.
Boca Raton, FL 33487
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