Our Culture

Date of Posting: 6/30/2023

This Privacy Policy discloses our privacy practices of our Website ("Website"). It explains how we collect and use your Personal Information we collect. Your use of our Website is governed by the Privacy Policy. If you do not agree with this policy and our practices, you are not authorized to use our Website. We have the right to make material changes to this Privacy Policy. We will post those changes through a prominent notice on the website with no further notice to you. Please review this policy often so that you will always know what information we gather, how we might use that information, and with whom we disclose, share, and sell it.

INFORMATION COLLECTION.

We collect the following categories of information about you when you visit and use our Website or participate in our Surveys or other promotions:

Personal Information. This is information collected which can identify you. This includes your name and email address, employment status or other unique information you provide to us during your participation in online surveys, signing up for our emails, or through the course of communicating with us for any reason.

Demographic Information. This includes your zip code, mobile phone carrier, age, gender, salary range, education, marital status, occupation, military service, industry of employment, personal and online interests. If you can be personally identified through this information, it is Personal Information.

Our Website Tracking. We may track and record your movement through our Website including the pages, articles, and ads you visit on our website, what services or products you access or order, information about your computer hardware and software, including your IP address, general geographic location of the computer or device you are using, browser preference, operating system other websites you visit. When we can identify you personally, through the use of this information, it is Personal Information.

Third-Party Information. We may collect personal information about you from a third-party who licenses or sells the information to us. This includes, information found in cookies or persistent identifiers, and email opt-in records. We may not have access or control over these cookies and other tracking devices as they are owned and used by unaffiliated parties including advertisers, networks, ISPs, analytics consultants, or social media networks. We have no responsibility or liability for the policies and practices of these parties.

Technology Information. We automatically collect you IP address, browser type, internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and/or clickstream data from cookies, web beacons or other technology.

No Information Collected from Children. We will never knowingly collect any Personal Information from anyone under the age of 16. If we accidently do collect such information, we delete the same upon notice.

TECHNOLOGY INFORMATION COLLECTION.

Generally. We, our vendors, networks, ISP(s) and supporting advertisers use technologies such as cookies, web beacons, and java scripts to collect information about you. Using these technologies, we collect your IP addresses, browser type, ISP, referring/exit pages, operating system, date/time stamp, and/or clickstream data. We use this to analyze trends, monitor and update our Website, ease of movements through our Website and gather demographic information about our user base, as a whole, to attract advertising on our Website. We may create reports or logs based on these technologies on an individual or aggregated basis. California residents should be advised we do not respond to do not track signals or cookies. You can control our collection through these technologies through your browser settings or mobile device settings.

Cookies. If enabled, cookies store small amounts of information on your computer about actions you take on our Website. This helps us track which of our features you visit most often, and what content you view and keep track of the number of return visits. We accumulate and aggregate statistical information generally pertaining to our Website, to market our Website and deliver specific content to you based on your past viewing history. We may allow third parties to place advertising cookies which helps serve advertising content that is relevant to you. We may also use analytics and customization cookies which analyze your useage for site optimization and finally we use performance and functionality cookies which facilitates measurement and analytics for improved browsing experience.You can modify or disable cookies, but our Website may not function properly for you. You may read more about cookies at http://cookiecentral.com/faq/.

Third-Party Cookies. We use various ad services provided by Google that connects the activity on our Website with their advertising network and they may use cookies that collects information regarding certain patterns in your browsing history. To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google’s Analytics Advertising. This includes: (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) Google controlled Campaign Manager integration; and (iv) Google Analytics Demographics and Interest Reporting. Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis service. Google utilizes the data collected through its cookies to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-on here https://tools.google.com/dlpage/gaoptout/.

Site Recordation Technology.We use site visit recordation technology to memorialize site visits, including technology provided by third parties, including Jornaya’s Lead ID or Active Prospect’s TrustedForm, as applicable. We use LeadID and/or TrustedForm to independently document users’ consent to be contacted. We use LeadID and/or TrustedForm to independently document users’ consent to be contacted. The LeadID and/or TrustedForm Script is embedded on our website and collects the following information when you interact with the page(s) where the script is present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user’s computer, time on the page, date and time that the LeadID and/or TrustedForm Script was loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user’s browser (“Data Collection Pages”). For more information about ActiveProspect’s data use and collection policies and practices, please review the ActiveProspect Privacy Policy, located at https://activeprospect.com/privacy-policy/. For more information about Jornaya’s data use and collection policies and practices, please review the Jornaya Privacy Policy, located at https://www.jornaya.com/consumer-privacy-policy/.

Web Beacons. We use web beacons to collect information about your visit to our Website, measure and improve the effectiveness of advertisements and track delivery of advertising. Web Beacons collect only a limited set of information including a cookie number, time, and date of page view, as well as a description of the page on which the Web Beacon resides. We may also use Web beacons in email messages sent to you. This allows us to determine if you opened or acted upon the email message. Because Web beacons are the same as any other content request, you cannot opt-out or refuse them. However, they can be rendered ineffective by either opting-out of cookies or changing the cookie setup in your browser.

Pixels. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

USE OF PERSONAL INFORMATION.

Providing Products and Services. We use Personal Information to provide you with the services and/or products you have requested. We may share your information with a third-party to provide such services or products. We do not control the privacy practices of third-parties. Please contact the third-party with any questions about their privacy practices.

Website Functionality. We use the Personal Information to respond to any questions you have, operate, and improve the functionality of our Website. We also use it for testing, research, analysis and product or marketing development. Our services may include the display of personalized products, content, and advertising, relating to your experience and interests. This includes maintaining and improving the safety, security and integrity of our Website, databases, and technology assets.

Marketing and Promotion. We use the information to promote our and third-party marketing campaigns related to products and services that might be of interest to you. We also use the information to respond to your questions concerns or requests.

Third-parties. will use the information when we share, lease, or sell it to provide you with their services and products.

SHARING AND SALE OF INFORMATION.

Generally. All information, including the personal information (including your name and email), may be leased, licensed, shared, disclosed, or sold to third-parties including to our affiliates, service providers, vendors, advertisers, or other third-parties for third-party marketing. This may result in unsolicited email messages to you about those third-party products and services.

Website Functionality. We share all categories of information set out in this policy with third-party Service Providers we employ to perform technical or analytical functions on our behalf. Examples include third-parties who host our Website, analyze our data, provide marketing assistance, and provide customer service.

Third-Party Products and Services. We share all categories of information set out in this Privacy Policy with third-parties including affiliated entities, service providers, and data aggregators with your information with third-parties who will provide you with their opportunities, products, or services.

Anonymized information. We share aggregated anonymous information about you, combined with Service Providers and other third-party vendors and clients for their analysis, promotion, and marketing. This includes demographic information and behavioral information.

Legal Process. We disclose your information, if legally required to do so, or at our discretion, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect our rights or property, or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.

Acquisition or Merger. We may disclose and transfer your information to a third-party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of, such information in a transaction approved by the court.

THIRD-PARTY COLLECTION AND USE OF INFORMATION.

Clients. Advertising agencies, advertising networks, and other companies who place ads on our Website, may use their own technology, to collect information about you. We do not control the use of such technology and have no responsibility for the use of such technology to gather information about you. We also do not control how such information is used or shared. Please be sure to read their privacy policy and practices.

Hyperlinks on Website. For your convenience, our Website and email messages sometimes contain hypertext links to websites owned by third-parties. We are not responsible for the privacy practices or the content of such other websites. We do not operate or control any information, software, products, or services, available on these third-party websites. The inclusion of a link on our Website does not imply any endorsement of the services, products or website, or its sponsoring organization.

Analytics. As described above, we use Service Providers and Third Parties to monitor, analyze and report on the traffic to, from and within our Website and email messages.

DISCLAIMER OF THIRD-PARTY COLLECTION AND USE.

Our Website offers links to third-party owned and operated websites, including links embedded in advertisements and links to various news sources not under our control. These third-party websites may have information policies and practices different from ours. In addition, certain companies associated with our Website have their own privacy policies. We do not own or control such companies and websites and are not responsible for the privacy policies or practices or the content of websites.

STORAGE AND SECURITY OF INFORMATION.

We use reasonable industry-accepted technology and controls to protect your information and data from disclosure to unauthorized third-parties. This includes firewalls, secured facilities, and logged and limited access. Although mostly effective to prevent disclosure, no guarantee can be given that all information you provide to us will not be accessed by unauthorized persons. Thus, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Any transmission of data to use or through our Website is at your own risk.

CALIFORNIA CCPA AND CPRA NOTICE.

This Privacy Notice for California Residents supplements the information contained in our primary privacy policy 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 ("CCPA") and as amended and effective January 1, 2023, the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and CPRA have the same meaning when used in this Notice. The CCPA and CPRA are collectively referred to as the "CCPA" for purposes of this Notice.

Category Collected	Exemplar	Source	Business Purpose	Share or Sale
Identifiers	First and Last Name, Postal Address, Unique Personal Identifier, Online Identifier, Internet Protocol Address, Email Address	Directly and indirectly from consumers, Third party data providers, Ad exchanges, Supply-side platforms, Clients	Personalize Website; Respond to Consumer request; targeted advertising through Google. Provide services or products requested by consumer; Process consumer and client invoicing and payments; Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.	Service providers, Contractors, Third-party vendors and data management companies; ESP providers, Clients, Affiliated companies
Personal and Sensitive Information	First and Last Name, Address, Telephone Number, Credit Card or Debit Card when purchases are made	Directly from Consumers	To process consumer requests for purchases, transactions, Payments, or Prevent fraud	Service providers, Contractors Third-party vendors, Clients, Affiliated companies
Commercial Information	Records of products or services purchased, obtained, or considered. History or tendencies toward products and services or response to advertising.	Directly and indirectly from consumers, Third party data providers, Technology providers and Ad exchanges, Supply-side platforms, Clients	Personalize Website; Respond to Consumer request; targeted advertising through Google AdWords. Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. To process consumer requests, purchases, transactions, payments, and prevent fraud.	Service providers, Contractors, Third-party vendors, Clients, Affiliated companies
Internet or other Similar Network Activity	Browsing history, Search history, Information on a consumer's interaction with a website, application, or advertisement	Directly and indirectly from consumers, third party data providers, Ad exchanges, Tech and analytics third party platforms, Clients	Personalize Website; Respond to Consumer request; targeted advertising through Google. Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our Website, products, marketing and services. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.	Service providers, Contractors, Third-party vendors, Clients, Affiliated companies
Geolocation Data	Through collection of your IP, we collect your general location, upon requesting services, or product we collect your physical address	Directly and indirectly from consumers, Third party data providers, Tech and analytics third party platforms, Clients.	Personalize Website; Respond to Consumer request; targeted advertising through Google. Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.	Service providers, Contractors, Third-party vendors, Clients, Affiliated companies
Inferences Drawn from other Personal Information	From information we collect as set forth herein and information provided by third-parties, we are able to profile a general understanding of your preferences, characteristics, and personal preferences to determine what ads or products or services you may be interested in receiving.	Directly and indirectly from consumers, Third party data providers, Third party analyst companies, Tech and analytics third party platforms, Clients	Personalize Website; Respond to Consumer request; targeted advertising through Google. Maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.	Service providers, Contractors, Third-party vendors, Clients, Affiliated companies
Highly Sensitive Information	Credit card or financial information for purposes of a transaction involving our products or services.	Consumers	To respond to request of consumer for products or services	Marchant account provider Porcessor Clients

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 and Correction of Specific Information and Data Portability Rights.

You have the right to request that we disclose and or correct 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 (see Exercising Access, Data Portability, and Deletion Rights below), 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 (see Exercising Access, Data Portability, and Deletion Rights below), 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
• 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.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Opt-Out of the Sale of Personal Information.

You have the right to opt-out of any sale of your Personal Information by us. If you are requesting a product or service, this is an exemption from this right, and we will process your request. However, you have the right to cease all further sale of your Personal Information. You may email us or use our web portal and fully fill out the request form.

Opt-Out Preference Signal (Global Privacy Control).

You may use an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”), to opt-out of the sale/sharing of your personal information. However, this technology and our use of it is not fully developed by the market. Our database containing your information may not be linked to your browser identification and because your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account or database information as the connection between your browser and our database is not known to us, we may not be able to fulfill this request.

If you would like us to make the connection between your browser and your account within our database, please email us or submit the requested form through our website portal below.

Exercising Access, Data Portability, and Deletion Rights.

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

• Visiting and calling the Toll Free Number listed on our web portal : optconsumerprivacy.com
• Visiting and completing the form on our web portal: optconsumerprivacy.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. The appointment must be in writing and presented by your agent. If your authorized agent requests sensitive information about you then we may ask you to provide us with a sworn declaration to further verify your identity.

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, which may include:

• You will be required to provide your full name, email address, and zip code.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

Response Timing and Format.

We will honor your request to cease sharing and sale within ten (10) days of receipt of your request and endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by email unless you request, we mail the same to you and provide a current mailing address.

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 usable and should allow you to transmit the information from one entity to another entity without hindrance.

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

Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights.

Retention of Personal Information.

We retain Personal Information as long as is reasonably necessary to fulfill the purpose for which it was collected, as required by an applicable law, rule, regulation or contractual provision. We will retain your Personal Information for the purposes of commercial marketing to you until you request we cease further efforts to provide you such offers or in the event you request deletion of your Personal Information. To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Changes to Our Privacy Notice.

We reserve the right to amend this privacy notice at our discretion and at any time. The only notice to you will be our posting of the updated notice on the Website and update the notice's effective date.