Effective Date: June 30, 2024
Notice Version: 1.0
Our privacy notice governs our privacy practices when you are using our website and all other websites owned or operated by our company including our mobile application(s), hereinafter and collectively referred to as our website.
Our privacy notice tells you what personal data and nonpersonal data we collect from you, how we collect them, how we protect them, how we share them, how you can access and change them, and how you can limit our sharing of them. Our privacy notice also explains certain legal rights that you have concerning your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our website.
NONPERSONAL DATA’ (NPD) means any information that is in no way personally identifiable. ‘PERSONAL DATA’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person can be identified directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data. ‘SENSITIVE PERSONAL DATA’ (SPD) a consumer’s social security, driver’s license, state identification card, or passport number; a consumer’s account login, financial account, debit card, or credit card number in combination with any required security, access code, password, or credentials allowing access to an account; a consumer’s exact geolocation; a consumer’s ethnic or racial origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, text messages, and email unless the business is the intended receiver of the communication; a consumer’s genetic data; the processing of biometric data for the purpose of uniquely identifying a consumer; personal information collected and analyzed about a consumer’s health; sex life or sexual orientation. Sensitive personal Information that is "publicly available" is not considered sensitive personal information or personal information.
Contact us using the information at the top of this privacy notice to exercise any of your legal rights contained within this privacy notice. We will respond to your request within 30 days after receiving it.
When using our website and submitting PD to us, you have certain rights under privacy laws in the United States including the California Consumer Privacy Act of 2018 (CaCPA), the California Privacy Rights Act of 2020 (CPRA), and privacy laws of other countries including the European Union General Data Protection Regulation of 2016 (the “EU GDPR”), the UK General Data Protection Regulation (UK GDPR / the Data Protection Act 2018), the Data Protection Act 2018, and other global privacy laws. Even if not listed here, we will make reasonable efforts to honor data subject access requests even though we may be under no legal obligation to do so. However, we reserve the right to decline any data subject access request that we are not legally obligated to comply with. Your rights include but are not limited to the following:
Generally, you control the amount and type of information that you provide to us when using our website.
When you register as a user or when buying our products or services, we may collect some or all of the following information: your username, email, password, phone number, address, personal videos, social security numbers, payment information, photo id, and other information listed in any questionnaires you are required to fill out so we can provide our services to you.
Our legal basis for collecting and processing your PD when you buy our products, services, or fill in any of the contact forms on our website is based on the necessity for the performance of a contract or to take steps to enter into a contract. Our legal basis for collecting and processing your PD when you sign up for our newsletter, download free information, and access free audios, videos, and webinars through our website is based on consent.
We automatically receive information from your web browser or mobile device. This information may include the IP address of your computer/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our website. We use all this information to help improve our website.
When you enter and use our website and agree to accept cookies, some of these cookies may contain your PD.
Our website uses cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well.
By agreeing to accept our use of cookies you are giving us and the third parties with which we partner permission to place, store, and access some or all the cookies described below on your computer and or mobile device.
We may use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails.
By using our website, you are subject to the Google Privacy Policy and Terms of Service. When collecting and processing user data, including PD from Google APIs, we will follow Google API Services User Data Policy. We also require that our employees, contractors, and agents comply with the Google API Services User Data Policy.
Hotjar is a service that helps us better understand our users’ experience - how much time they spend on which pages, which links they click on, what they do and do not like, etc. This lets us build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular the IP addresses of their devices captured and stored only in anonymized form); the screen size, type, unique identifiers of devices; browser information; geographic location (country only); and languages used to display our website. Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we use this information to identify individual users or to match it with further data on individual users. You can opt-out of the creation of a user profile, Hotjar’s storing of data about your usage of our website, and Hotjar’s use of tracking cookies on other websites by visiting: https://www.hotjar.com/legal/compliance/opt-out.
Our website may contain chat software or contact forms that enable visitors to communicate with us online or offline by email. In some cases, visitors can communicate with us without buying our products and services. When you use our chat software or contact forms, we may collect some or all the following information: your email address, first name, last name, location, and any other information you willingly choose to give us. You should limit the information you give to us to one that is necessary to answer your questions.
Our website uses Google Analytics to collect information about the use of our website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our website, what pages they visit, and what other websites they have used before coming to our website. We use the information we get from Google Analytics to analyze traffic and improve our marketing, advertising, and website. We do not combine the information collected using Google Analytics with PD. You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout
Third-party vendors, including Google, use cookies, pixels, and other technologies to serve ads based on a user's past visits to our website. These technologies are also used to track your activities on our website and other websites, including the web pages that you visited, the ads or content that you clicked on, any items you may have purchased, and the search terms you used to deliver tailored advertising to you. Users may opt-out of the use of Google’s cookies for interest-based advertising by visiting http://www.aboutads.info/choices/. For European users visit: http://www.youronlinechoices.eu
Our website and applications use remarketing advertising services. These remarketing services are provided by companies that show our ads on websites and devices across the Internet. With remarketing you may see ads for our products you have previously looked at. As an example, suppose you visit a website that sells computers, but you do not buy a computer on your first visit to that website. The website’s owner might like to encourage you to revisit their site and buy a computer by showing you their ads on other websites that you visit. We use remarketing for similar purposes. For this to happen remarketing companies will read a cookie in your browser. This can only happen if your browser is set to let it happen. You can opt-out of these types of advertising cookies by visiting http://www.networkadvertising.org/choices.
We may share your PD with third parties for similar audience marketing purposes. Similar audience marketing is also called lookalike audience marketing. The third parties we share your PD with for this type of marketing include Facebook and/or Google. Using your PD for similar audience marketing or lookalike audience marketing helps us find new audiences (users and customers) based on similar interests to yours. This helps us improve our marketing services. Your PD is only shared with Facebook and Google for this type of marketing. By using our website and agreeing to our privacy notice you are giving consent for your PD to be used for the marketing purposes described within this section.
If you do not provide us with enough PD, we may not be able to provide you with all our products and services. However, you can access and use some parts of our website without giving us your PD.
We use the information we receive from you to:
When we communicate with you about our website, we will use the email address you provided when you registered as a user or customer. We may also send you emails with promotional information about our website or offers from us or our affiliates unless you have opted out of receiving such information. You can change your contact preferences at any time through your account or by contacting us using the information at the top of this privacy notice.
If you provide a mobile telephone number, or landline telephone number to us, you are giving your express consent and authorize us or a third-party to contact you by using any of these communication methods. You are not required to give us your consent to contact you through these communication methods. However, withholding your consent may interfere or prevent us from providing some or all our services to you. You can stop receiving text messages, push notifications, and telephone calls at any time by contacting us or using one of our opt-out methods.
We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your NPD, which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. At times we give your PD to third-party service providers whom we hire to provide services to us so that we may provide certain services to you. These third-party service providers may include but are not limited to payment processors, web analytics companies, advertising and marketing networks, call centers, data management services, help desk providers, providers of registered agent services in states in which we do not have a physical presence, financial institutions and financial technology companies, government agencies including the Internal Revenue Service, Office of Foreign Assets Control, and the United States Department of Treasury, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.
We may disclose your PD if such disclosure is (a) required by subpoena, law, or other legal processes; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to protect us from legal action or claims from third parties, including you and or other users; or (d) necessary to protect the legal rights, personal and or real property, or the personal safety of our company, users, employees, and business partners.
If our business is sold or merges in whole or in part with another business that would become responsible for providing the website to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or company.
Our website may offer the ability for users to communicate through online community discussion boards, blogs, or other mechanisms. If you choose to post on these discussion mechanisms, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you disclose your PD through such postings. Also, PD which you post on our website for publication may be available worldwide on the Internet. We cannot prevent the use or misuse of such information by others.
We will maintain your PD in a structure that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this privacy notice, or for legal, business, or tax purposes. We will attempt to permanently erase or anonymize your PD once it reaches the end of its retention period or if we receive a valid request from you to do so. However, our ability to permanently erase or anonymize your PD will be limited by certain legal and attorney ethical obligations to which we are subject (for example, certain laws require us to keep information about your identity during the time we provided registered agent services). In addition, some of your data may still exist within our systems, for example, if it is waiting to be overwritten or when this data has been put away from use, meaning, that while it still exists on our archive system, it cannot be readily accessed by any of our operating systems, or any of our employees or contractors.
If you make any postings on our website that contain information about third parties, you agree that you have permission to include that information. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified if such postings violate the privacy rights of others.
Some web browsers have settings that enable you to request that our website not track your movement within our website. Our website does not obey such settings when transmitted to and detected by our website. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.
Our website may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. We have no responsibility for these websites, and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk.
Our website is not designed for use by anyone under the age of 18. We do not knowingly collect PD from children under the age of 18. If you are a parent or guardian and believe that your child is using our website and they are under the age of 18, please contact us. Before we remove any information, we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child under the age of 18 is accessing our website, we will delete their information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor have any liability to do so.
You can always opt-out of receiving email correspondence from us or our affiliates. We will not sell, rent, or trade your email address to any unaffiliated third-party without your permission except in the sale or transfer of our company, or if our company files for bankruptcy as described in the section Disclosures to Successors.
We have built our website and services using industry-standard security measures and authentication tools to protect the security of your PD. We and the third parties who provide services to us also maintain technical and physical safeguards to protect your PD. Unfortunately, we cannot guarantee the prevention of loss or misuse of your PD or secure data transmission over the Internet because of its nature. We strongly urge you to protect any password you may have for our website and not share it with anyone.
You may have to provide a credit or debit card to buy products and services from our website. We use third-party billing services and have no control over them. We use commercially reasonable efforts to ensure that your credit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorized use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number.
PD that we collect from you may be stored, processed, and transferred among any countries in which we operate. The European Union has not found the United States and some other countries to have an acceptable level of protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. If you are a European Union user, or a user from another country, with your consent your PD may be transferred to the United States or other countries when you request information from us. When you buy goods or services, we will use your PD for the performance of a contract with you. Wherever we transfer, process, or store your PD, we will attempt to apply reasonable safeguards to protect it. We will use the information we collect from you by following the practices described in our privacy notice. Also, we enter into data processing agreements and standard contractual clauses when appropriate. By using our website, services, or products, you agree to the transfers of your PD described within this section.
We reserve the right to change this privacy notice at any time. If our company decides to change this privacy notice, we will post those changes on our website so that our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email sent to the email address on file in your account. Otherwise, we will use and disclose our users’ and customers’ PD in agreement with the privacy notice in effect when the information was collected. In all cases, your continued use of our website, services, and products after any change to this privacy notice will constitute your acceptance of such change. If you have questions about our privacy notice, please contact us through the information at the top of this privacy notice.
* Company Sage™ is the tradename of The Things We Do PR, LLC, a Puerto Rico limited liability company.