1.1. PURPOSE OF THIS POLICY
PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a Site user is under age 13, we will promptly delete or deidentify any personal information in that user’s account.1.3. ABOUT THE GENERAL DATA PROTECTION REGULATION
The General Data Protection Regulation (GDPR) takes effect on May 25, 2018, and includes substantial changes to the European Union data protection laws. The purpose is to standardize data protection laws across the EU, enable people in the EU enhanced rights to their data, and require businesses to meet technical and organizational controls around the collection and processing of personal data. The Company has made changes in line with these new standards, which changes are set forth below in Section 7.
Please read this statement carefully and contact our Data Protection Officer at email@example.com if you have any questions about our privacy practices.
2. INFORMATION COLLECTION PRACTICES
2.1. WHAT BASIC INFORMATION DOES THE COMPANY COLLECT?
We gather data that identifies, pertains to, characterizes, mentions, is reasonably capable of being connected with, or could reasonably be associated with, a specific consumer, household, or device (referred to as "personal information"). Personal information does not encompass:
- Publicly available information from government records; or
- Deidentified or aggregated consumer data.
In particular, within the last twelve (12) months, we have acquired the following categories of personal information from consumers:
- Contact data, including your name, address, phone number, email, and similar details.
- Financial data, such as the last four (4) digits of the credit card number utilized for your purchase completion. All other credit card details used for your purchase are gathered, processed, and stored by Authorize.net, our payment processor.
- Detailed personal data like your date of birth or social security number, if provided.
- Internet or similar network activity, such as domain names and IP addresses (assigned numbers on the Internet).
We obtain the aforementioned categories of personal information directly from you through the forms you fill out or the products and services you procure.2.2. WHAT ADDITIONAL INFORMATION DOES COMPANY COLLECT?
The below categories of information are gathered indirectly from you:
- (a) AUTOMATIC COLLECTION. The Site may also collect "traffic data" from sources like Google Analytics, Google Tag Manager, and Cloudflare. This data may encompass your IP address and browsing history. This information is employed for marketing purposes or enhancing the services we provide.
- (b) COOKIES. Periodically, we may utilize the standard "cookies" feature of popular browser applications, allowing us to store a small data fragment on your computer regarding your visit to our Site. We do not utilize any data capture mechanisms on our Site apart from cookies. Cookies assist us in understanding which sections of our Site are beneficial and which areas require improvement. You can opt to accept or decline cookies by modifying your browser settings. Nevertheless, opting to disable this function may result in a reduced experience on our Website, and some features may not function as intended.
3. USE AND SHARING OF INFORMATION
3.1. WHAT DOES COMPANY DO WITH COLLECTED INFORMATION?
(b) ANONYMOUS INFORMATION. Anonymous information is used for analyzing Site traffic, without examination for individual identifying data. Additionally, we may employ anonymous IP addresses to diagnose server issues, administer the site, or customize content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers in an aggregate and anonymous form.
(d) DISCLOSURE OF PERSONAL INFORMATION. Personal information may be disclosed for the reasons detailed in Section 3.1(a) above, or when required by law or in good faith belief that such action is essential to (1) adhere to legal edicts or comply with legal proceedings against Company or its parent company, subsidiaries, or affiliates, (2) safeguard and defend Company's rights or Site user rights, or (3) act urgently to protect public safety or Site user safety.
(e) SALE OF INFORMATION. To adapt to changes in our business, we may purchase or sell parts of our company or other companies/assets, including information collected through this website. If Company or most of its assets are acquired, customer information will be transferred to the acquirer as part of the assets.
(f) ACCESS TO INFORMATION. Regrettably, we do not maintain procedures for you to review or request modifications to the information we collect about you, except for requesting removal of all your information from our database by contacting us in line with Section 6.1 below.4. SECURITY
The Site implements security measures to deter the loss, misuse, or alteration of the information we gather from you. However, we cannot guarantee our capacity to prevent any such loss, misuse, whether it pertains to you or any third party, stemming from such loss, misuse, or alteration.5. WEBSITE AREAS BEYOND COMPANY’S CONTROL
5.1. PUBLIC FORUMS
The Site may incorporate interactive forums like message boards and chat rooms. Kindly bear in mind that any details disclosed in these areas become public information, so exercise caution when choosing to share your personal information.
5.2. THIRD PARTY WEBSITES
The Site might feature links to other websites. If you opt to visit these other websites, we are not accountable for their privacy practices or content. It is your responsibility to review the privacy policies of those websites to ensure you comprehend and consent to their policies.6. CONTACT INFORMATION AND POLICY UPDATES
6.1. CONTACTING US
If you have any inquiries regarding this Policy, our practices pertaining to this Site, or if you wish to have your information removed from our database, please reach out to us at the following address: firstname.lastname@example.org.
6.2. UPDATES AND CHANGES
We retain the right to add, alter, update, or modify this Policy at any time, by merely publishing such changes, updates, or modifications on the Site, without any additional notice to you. Such changes, updates, or modifications will be immediately effective upon their posting on the Site. It is your responsibility to periodically review this Policy to ensure your ongoing agreement with all of its provisions.
6.3. UNSUBSCRIBE POLICY
When you register on our Site, request information, make a purchase, or undertake other activities on the Site, you furnish us with details about yourself, including your name, username, password, email address, and phone number. If you make a purchase, our payment processor, Authorize.net, collects your credit card information and billing address to facilitate the transaction. Authorize.net provides us with the last four (4) digits of your credit card number as a transaction identifier.
For further insight into the personal data we collect and additional data collected, please refer to Section 2 above.
The legal basis for processing the personal data we collect (in accordance with Company policies, including this Policy), as well as the mechanism for transferring such data from the European Union, is the affirmative consent you provide when engaging with our Site. You can withdraw this consent anytime by contacting our Data Protection Officer at email@example.com. HOW WE UTILIZE AND SAFEGUARD YOUR PERSONAL DATA
We employ the personal data you furnish through our Site for various purposes. These include facilitating the sale of products, notifying you about updates to purchased products, and sharing information about products that we believe might pique your interest. Rest assured, we will not disclose your personal data to third parties without your explicit consent, unless as revealed in Section 3, or when necessary to provide you with our services or adhere to legal requirements. Your personal data may be used for identity verification, qualification checks, or for follow-ups on Site-initiated transactions. Additionally, we may use your contact details to inform you of Site modifications or send you supplementary information about our Company. If you opt in during the account registration process, we might share your contact details with our business partners or other companies for promotional materials.
We also make use of anonymous information to analyze Site traffic, employing anonymous IP addresses to assist in diagnosing server issues, administering our site, or personalizing content based on your preferences. Cookies might be employed for purposes like delivering content tailored to your interests and saving your password to eliminate the need for repeated entries. Occasionally, promotions or advertisements on our site may utilize cookies. Please note that we do not have control over the information gathered by external advertisers on our site. You can modify your web browser settings to reject cookies, although this may affect your Site experience.
Your information is retained only when you make a purchase or submit a form, providing affirmative consent for us to collect your personal data for the purposes outlined herein. Once the data no longer serves its original purpose, it will be promptly removed.
We've implemented various industry-standard encryption and security technologies and protocols to safeguard information, including your personal data, stored within our computer systems. While we endeavor to employ commercially acceptable methods for protecting your personal information, it's important to acknowledge that no method of transmission over the Internet or electronic storage can guarantee 100% security. Moreover, we uphold standard physical and electronic procedural safeguards that restrict access to your personally identifiable information. Access is limited to our employees (or individuals operating under confidentiality agreements on our behalf) who require such access as part of routine business operations.7.4. SHARING AND DISCLOSURE OF PERSONAL DATA
We collaborate with service providers to offer specific services, including credit card processing, analytics tools, DNS services, data management, web hosting, and web development. Only essential information is shared with these service providers to enable them to fulfill their roles as part of our contractual obligations or as a measure in preparation for such contractual engagements with you, in accordance with Art. 6 (1) b GDPR.
We may also share the information we collect with our affiliates. In the event of a merger, sale, or transfer of some or all of our assets, we might disclose or transfer the information we've collected as part of such transactions, grounded in our prevailing legitimate interests in cooperation with our affiliates or as part of such transactions, in compliance with Art. 6 (1) f GDPR.
Disclosure of your information to third parties may occur under the following circumstances: (a) when required to comply with applicable laws, regulations, legal processes, or governmental requests (Art. 6 (1) GDPR), (b) to enforce our agreements, policies, and terms of service (Art. 6 (1) f GDPR), (c) to safeguard the security or integrity of our Services (Art. 6 (1) lit. f GDPR), (d) to protect the rights, property, and safety of us, our customers, or the public from harm or illegal activities (Art. 6 (1) f GDPR), (e) to respond in emergencies where we believe in good faith that disclosing information is necessary to prevent the death or serious bodily injury of any person (Art. 6 (1) d GDPR), or (f) to investigate and defend ourselves against third-party claims or allegations (Art. 6 para. 1 lit. f GDPR).7.5. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
7.5.1. You have the liberty to review, amend, update, or modify your account registration information. This can be accomplished by accessing your settings within your user profile on the Site or by reaching out to our Data Protection Officer (DPO) at firstname.lastname@example.org.
- 184.108.40.206. You have the right to access your personal data processed by us.
- 220.127.116.11. You can request the rectification or erasure of your personal data ("right to be forgotten").
- 18.104.22.168. You may seek to restrict the processing of your personal data, effectively barring further access.
- 22.214.171.124. You have the right to receive a copy of your personal data and request the transfer of your personal data ("right to data portability").
7.5.3. Furthermore, you hold the option to object to any processing of your personal data if such processing is legally founded on our prevailing legitimate interests, in accordance with Art. 6 (1) f GDPR. You can express your objection by contacting our DPO at email@example.com or using any other contact method outlined in Section 9 below. Please provide personal reasons for discontinuing such processing. We will honor your objection unless we can demonstrate overriding legitimate interests in continuing to process your personal data, including the necessity of using your personal data for protecting legal claims or defending against them.
7.5.4. Additionally, you have the right to object to the processing of your personal data for advertising purposes without having to provide any reasons. This objection can be raised by contacting our DPO at firstname.lastname@example.org or through other contact channels detailed in the Policy.
8.1. Information We Collect
When you register on our Site, request information, make a purchase from us, or engage with us in any other way, you share various details about yourself. This may include your name, username, password, email address, and phone number. In case of a purchase, we gather payment card information, but please note that we neither store nor process this data beyond transmitting it to our payment card processor.
For more comprehensive information about the personal data we collect, along with additional data categories, refer to Section 2 above.8.2. Use of Personal Information
We employ, may sell, or disclose the personal information we collect to fulfill the specific purpose for which you provided it. For instance, if you share your contact details to inquire about our products or request a price quote, we'll use this information solely to respond to your query. Similarly, if you provide personal information to make a purchase, we'll use it for payment processing and order facilitation.
For more insight into how we utilize the personal data, please refer to Sections 3 and 7.3 above.
We are committed to not collecting additional categories of personal information or using the personal data we've gathered for materially different, unrelated, or incompatible purposes without notifying you accordingly.8.3. Sharing Personal Information
We may share your personal information with a third party for various business purposes, and in some cases, we might sell your personal information, but you have the right to opt-out of such sales. When we share personal information for business purposes, we establish a contract outlining the specific purpose and requiring the recipient to keep the information confidential, using it solely for the contract's direct performance. It's important to note that the CCPA prohibits third parties from reselling the personal information we hold unless you've been explicitly informed and given the option to opt-out of further sales.
For a more comprehensive understanding of how we share the personal information we collect, please refer to Sections 3.1 and 7.4 above.
In the past twelve (12) months, our payment processor, Authorize.net, collected the following categories of personal information directly from customers who initiated transactions on our Site:
- Consumers' full names and billing addresses.
- Credit and debit card numbers.
In the same timeframe, we disclosed the following information to our marketing firm, TribalVision:
- Consumers' full names.
- Consumer's email addresses.
We also disclosed the following information to our email distributor, HubSpot:
- Consumers' full names.
- Consumer's email addresses.
In the previous twelve (12) months, Company has shared personal identifiers such as names, mailing addresses, and email addresses with MarketDigits Ltd. This was done to fulfill customer orders and for marketing purposes. Company has also disclosed names and email addresses to our marketing firm, TribalVision, and our email distributor, HubSpot, for marketing endeavors. Furthermore, our payment processor, Authorize.net, collected financial information like credit card numbers and billing addresses from customers making purchases on the Site for the sole purpose of completing those transactions.8.3.2. Sales of Personal Information
In the preceding twelve (12) months, Company has not engaged in the sale of any personal information it has collected.8.4. Your Rights and Choices
The CCPA grants specific rights to consumers (California residents) concerning their personal information. This section outlines your CCPA rights and provides guidance on how to exercise them.8.4.1. Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain details about our collection and utilization of your personal information over the previous twelve (12) months. After we receive and verify your request (as described in Section 8.4.3.), we will provide you with the following information:
- The categories of personal information we gathered about you.
- The sources from which we obtained your personal information.
- Our business or commercial purpose for collecting or selling your personal information.
- The categories of third parties with whom we shared your personal information.
- The specific pieces of personal information we collected about you (also referred to as a data portability request).
- If your personal information was sold or disclosed for a business purpose, we will provide two (2) separate lists identifying the categories of personal information each category of recipient purchased (sales) and obtained (disclosures for a business purpose).
It's essential to note that we do not offer these access and data portability rights for business-to-business (“B2B”) personal information.8.4.2. Deletion Request Rights
You possess the right to request the deletion, deidentification, or aggregation of your personal information that we have collected and retained, subject to specific exceptions. Once we receive and confirm your verifiable consumer request (as outlined in Section 8.4.3.), we will proceed to delete, deidentify, or aggregate your personal information from our records. However, this action may not apply if a statutory exception relating to the data is present.
We may decline your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete a transaction for which we collected the personal information, provide a requested good or service, take actions reasonably expected within our ongoing business relationship with you, fulfill the terms of a written warranty or product recall as required by federal law, or otherwise execute our contract with you.
- Detect security incidents, safeguard against malicious, deceptive, fraudulent, or illegal activity, or prosecute individuals responsible for such actions.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable internal uses aligned with consumer expectations based on your relationship with us.
- Comply with legal obligations.
- Engage in other internal and lawful uses of the information that are compatible with the context in which you provided it.
It's important to note that we do not provide these deletion rights for B2B personal information.8.4.3. Exercising Access Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights detailed above, please initiate a verifiable consumer request by either:
- Calling us at +1 510-730-3200.
- Emailing us at email@example.com.
Only you, or an individual legally authorized to act on your behalf, can submit a verifiable consumer request concerning your personal information. You may also make such a request on behalf of your minor child. To appoint an authorized agent, kindly submit a document containing your authorized agent’s full name, contact information, a statement granting the agent access to your personal information or requesting the deletion of your personal information, and your signature to firstname.lastname@example.org.
You may make a verifiable consumer request for access or data portability only twice within a twelve (12) month period. The verifiable consumer request must:
- Provide adequate information enabling us to reasonably confirm your identity as the person for whom we collected personal information or as an authorized representative. This may entail:
- Completing a two-step authentication process for your MarketDigits account.
- Submitting evidence of your identity matching two (2) data points already in MarketDigits' possession.
- Outline your request with enough detail to allow us to comprehend, assess, and address it appropriately.
If we cannot validate your identity or authority to make the request and confirm that the personal information pertains to you, we cannot respond to your request or provide you with personal information. Please note that creating an account with us is not necessary for making a verifiable consumer request. Nonetheless, requests made through your password-protected account will be deemed sufficiently verified when they pertain to personal information associated with that specific account.
We will solely employ personal information supplied in a verifiable consumer request to validate the requestor’s identity or authority for making the request.
For instructions on how to exercise your sale opt-out rights, please refer to Section 8.4.5 below.8.4.4. Response Timing and Format
We strive to respond to verifiable consumer requests within forty-five (45) days of receiving them. If more time is needed, up to an additional forty-five (45) days, we will notify you of the reason for the extension in writing.
If you have an account with us, we will send our written response to that account. If you do not have an account with us, you can choose to receive our written response either by U.S. mail or electronically.
Our disclosures will cover only the twelve (12) months preceding the receipt of your verifiable consumer request. If applicable, our response will also clarify why we cannot fulfill a request. For data portability requests, we will provide your personal information in a readily usable format, such as a downloadable .pdf or .csv file, allowing you to transmit the information smoothly from one entity to another.
We do not impose a fee for processing or responding to your verifiable consumer request, unless the request is excessive, repetitive, or clearly unfounded. If we determine that a fee is warranted, we will explain the reasons for this decision and provide a cost estimate before proceeding with your request.8.4.5. Personal Information Sales Opt-Out and Opt-In Rights
If you are sixteen (16) years of age or older, you have the option to instruct us not to sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we know are under sixteen (16) years of age unless we receive affirmative consent (the “right to opt-in”) from either the consumer aged thirteen (13) to less than sixteen (16), or the parent or guardian of a consumer younger than thirteen (13). Consumers who have opted in to the sale of personal information may opt out of future sales whenever they choose.
To exercise the right to opt-out, you (or your authorized representative) can send a written request to opt-out of your information being sold to email@example.com.
Upon submitting an opt-out request, we will wait at least twelve (12) months before requesting your authorization again to sell your personal information. However, you can change your mind and opt back in to personal information sales anytime by submitting a written request to opt back in to firstname.lastname@example.org.
You do not need to create an account with us to exercise your right to opt-out. Any personal information provided in an opt-out request will be used solely to process and comply with the request.8.5. Nondiscrimination
We are committed to not treating you unfairly for exercising your CCPA rights. As outlined in the CCPA, we will not:
- Refuse to provide you with products or services.
- Apply different prices or rates for products or services, including offering discounts or penalties.
- Offer you varying levels or qualities of products or services.
- Imply that you might receive different prices or rates for products or services or differing levels or qualities of products or services.
MarketDigits Inc. records all outgoing and incoming calls for the purpose of training and development, as well as effective client requirement assessment. All recorded calls are treated with the utmost confidentiality. If you prefer that we delete call recordings or refrain from recording calls altogether, please notify us via email or during a phone call with any MarketDigits Inc. representative.