FinancialReliefCenter and
Consumer Concierge Privacy Policy
Last Updated: 8/29/2024
Thank you for visiting the
FinancialReliefCenter and Consumer Concierge website located at
FinancialReliefCenter.org (the "Website"). The Website is an Internet
property of FinancialReliefCenter and Consumer Concierge (collectively,
"Company," "us," "our" or "we"). We believe in
100% permission-based marketing. All visitors to, or Users of, the Website are
referred to, individually, as "User," "you" or
"your." Capitalized terms not defined herein shall have the meaning
set forth in the FinancialReliefCenter and Consumer Concierge Terms and
Conditions (the "Terms").
I. Introduction
We have created this
FinancialReliefCenter and Consumer Concierge Privacy Policy (the "Privacy
Policy") in order to disclose our information gathering and dissemination
practices. In particular, this Privacy Policy will outline the following: (a)
your acknowledgement and agreement to be bound by the terms of this Privacy
Policy; (b) the means by which changes will be made to this Privacy Policy; (c)
your privacy rights including - for all California state residents - your
California Privacy Rights; (d) what information we collect and how we use it;
(e) to whom we may share the information collected; (f) your choices regarding
the sharing of information including, without limitation, your ability to
opt-out of having your information shared; and (g) how to review the
information collected about you. Please carefully review this Privacy Policy
in its entirety. If you do not agree to abide by and be bound by all terms and
conditions set forth in this Privacy Policy, you are NOT authorized to access
and/or use the Website Offerings in any way.
II. Your Acknowledgement and
Agreement
The Website is not intended
for use by any individuals under eighteen (18) years of age (or the applicable
age of majority if the age of majority in your jurisdiction is greater than
eighteen (18) years of age) and/or those individuals who are not legal
residents of the United States of America. Canadian residents are not permitted
to participate in any Reward Program Offers. For the avoidance of doubt, if
you are a resident of a European Union Member State, you are not permitted to
use the Website and/or Website Offerings. If you are not eighteen (18) years
of age or older (or the applicable age of majority if the age of majority in
your jurisdiction is greater than eighteen (18) years of age), and/or you are
not a valid resident of the United States of America, and/or you do not agree
with the terms of this Privacy Policy in its entirety, then you are NOT
authorized to access and/or use the Website Offerings in any way.
You agree to the terms and
conditions contained in this Privacy Policy, in their entirety, when you: (a)
access and/or use the Website and/or various registration forms, web pages and
other online media (collectively, "Online Media"); (b) access certain
text, images, video, audio and other content and information as made available
by: (i) Company (collectively, "Company Content"); and (ii) third-parties
including, but not limited to, content that is submitted by, or aggregated
from, third-party sources ("Third-Party Content," and together with the Company
Content and Member Content, the "Content"); (c) access links to third-party
websites and resources ("Third-Party Links"); (d) register to establish a
Company account ("Account"); (e) register for, and participate in, any of the
drawings, contests, sweepstakes and Reward Program Offers that we may make
available on the Website from time-to-time (collectively, the "Promotions");
(f) request information regarding certain products and/or services featured on
the Website (collectively, "Services"), as offered by third party service
providers, advertisers and marketing partners (collectively, "Partners");
and/or (g) utilize the contact form and/or other functionality as a means to
request to be contacted by Company (collectively, "Contact Services," and
together with the Website, Content, Third-Party Links and Promotions, the
"Website Offerings").
III. Your California
Privacy Rights
Shine the Light.
If you are a resident of the State of California and would like to learn how
your "personal information" (as defined in the Shine the Light Law, Cal. Civ.
Code § 1798.83) is shared with third parties, what categories of personal
information we have shared with third parties in the preceding year, as well as
the names and addresses of those third parties, please e-mail us at:
[email protected];
call us at: (844) 435-3969;
or send us U.S. Mail to: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.
Further, if you are a
resident of the State of California and would like to opt-out from the
disclosure of your personal information to any third party for marketing
purposes, please e-mail us at: [email protected];
call us at: (844) 435-3969;
or send us U.S. Mail to: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213. Please be advised that where California State residents opt-out
from permitting their personal information to be shared, such individuals may
still receive selected offers directly from us, in accordance with applicable
law.
California Consumer Privacy Act of 2018
("CCPA"). In addition to the foregoing, if you
are a resident of the State of California certain other privacy-related rights
may apply to you in accordance with the CCPA, including the right to opt-out of
our sale/sharing of your personal information, as well as the right to know
what personal information about you we have collected, whether your personal
information was shared with third-parties in the preceding year and, if so,
what categories of personal information were shared, as well as the categories
of third parties with whom we shared that personal information. Please see our
"Privacy Provisions for California Residents" below for a more complete
description of your rights under the CCPA as a California State resident.
IV.
Your Nevada Privacy Rights
Nevada State residents have
the right to submit opt-out requests to website operators instructing those
website operators not to sell any "covered information" that the
website operators have collected about the Nevada State residents to any third
party data broker(s). Covered information includes a consumer's name, postal
and email addresses, telephone number and Social Security Number, and includes
the Information described below in the "Types/Categories of Information We
May Collect and How We Use It" section. If you are a Nevada State resident
and you wish to exercise your right to request that we to stop the sale of your
Information to third party data brokers, please submit your request by: (a)
clicking on the link "Do Not Sell My Personal Information"; (b) emailing
us at: [email protected] with
the subject line "Nevada Privacy Rights"; or (c) calling us toll free
at: (844) 435-3969. In your request, please specify that you want to exercise
your rights to opt-out from the sale of covered information under the Nevada
Privacy Law and specify the Website that you visited and the email address you
registered with. Please allow thirty (30) days for a response.
Privacy
Policy Quick Links
Below are links
to key sections of our Privacy Policy:
Changes to this Privacy
Policy
Types/Categories of
Information We May Collect and How We Use It
How We May Disclose
and/or Sell Information
Collection and Use of
Your Non-Personally Identifiable Information
Privacy Provisions for
California Residents
Unsubscribe/Opt-Out
Security
Children's Privacy
Accessing, Modifying and Deleting Your
Information
Limitation of Liability
V. Changes to this Privacy
Policy
We reserve the right, in our
sole discretion, to change, modify, update and/or remove portions of this
Privacy Policy at any time, simply by posting such changes to the Website, so
we strongly encourage you to review this Privacy Policy periodically.
For the avoidance of doubt,
all Privacy Policy changes or modifications will be posted on the Website and
shall take effect immediately upon their posting; provided, however,
that if the manner in which we use personal information changes, Company will
notify Users by: (a) sending the modified policy to our Users via e-mail;
and/or (b) any other reasonable means acceptable under applicable state and
federal law. You will have a choice as to whether or not we use your
information in this different manner, and we will only use your information in
this different manner where you opt-in to such use.
VI. Types/Categories of
Information We May Collect and How We Use It
Please see our Privacy
Provisions for California Residents below for more details regarding our collection
and use of Personally Identifiable Information (as defined below).
·
Information that could reasonably identify a User, such as name, postal
address, email address(es), mobile/landline phone number(s), date of birth and
gender;
·
Information collected from a User's responses to survey questions, including
preferences, products and services of interest, personal attributes such as
marital status, home or auto ownership, political affiliation, views on various
issues and responses to wellness questions, as further described below;
·
Information collected from our web server log files, including device type(s), User
agent data, referring URL(s), and IP address(es);
·
Information collected from our customer support department and fulfillment
vendors, including customer support inquiries, Promotion-related claims and
emails and, as needed, proof of identification and Promotion completion;
·
Information collected from Cookies (as defined below), including whether a User
has previously visited the Website.
·
Information related to a user's consent to receive telemarketing calls, SMS messaging, push notifications, commercial email, and other forms of communication (which may include the creation of a report and session recordation of a user interacting with page(s) that seek to obtain a User's prior express written consent (as defined in the Telephone Consumer Protection Act ("TCPA")) to receive telemarketing and text messages.
·
To carry out our obligations and enforce our rights arising from any contracts entered into between users and us, including for purposes of our Arbitration Agreement, and any inquiry specific to prior express written consent under the Telemarketing Sales Rule ("TSR") and/or the TCPA ("TCPA Consent");
We may be required to
create, collect, maintain, and/or submit certain information requested and/or
required by the government or other regulating authorities, including, without
limitation, IRS Forms W-9 and 1099. This information, which may include your
taxpayer identification number (collectively, "Sensitive Information"), will
not be used, shared, transferred, or sold for any marketing purposes.
We collect and combine your
Personally Identifiable Information and Non-Personally Identifiable Information
(collectively, "Information") when you: (a) open, preview or click on
any e-mail messages that we send on our behalf or on behalf of one of our
Partners; (b) register on the Website to participate in any Promotions and/or
utilize any other Website Offerings; and/or (c) otherwise provide personal
information to us by and through the Website Offerings. For purposes of this
Privacy Policy, "Personally Identifiable Information" refers to data collected that
identifies, relates to, describes, is capable of being associated with, or
could reasonably be linked, directly or indirectly, with a particular consumer
or household including, but not limited to, e-mail address, name, postal
address, date of birth, gender and/or telephone number. Alternatively, for
purposes of this Privacy Policy, "Non-Personally Identifiable Information"
refers to data that cannot be used to identify, relate to, describe, associate
with, or reasonably link, directly or indirectly, with a particular consumer or
household. While the submission of any information is voluntary - and at your
complete discretion - such submissions may be required in order to utilize
certain Website Offerings, including the Promotions.
As noted above, we may use
the collected Information for any legally permissible purpose in our sole
discretion including, but not limited to, those explained below. Without
limiting the foregoing, we may also use your Information to send you
promotional messages regarding various Company products and/or services, as
well as third-party products and/or services that we think may be of interest
to you. If you wish to stop receiving future communications from us, please
follow the instructions at the end of each such marketing message or use any of
the other options available in the "Opt-Out/Unsubscribe" section below
We may employ other
companies and individuals to perform certain functions on our behalf. Examples
include sending direct and electronic mail, removing duplicate information from
our database, analyzing data, conducting drawings and other Promotion-related
activities and providing marketing analysis. The agents performing these
limited functions on our behalf shall have access to your Information only as
needed to perform their functions for us; and we do not permit them to use your
Information for any other purposes.
We may also use your
personal information for customer service functions, to provide you with
information that you may request in connection with the Website Offerings to
customize your experience with the Website Offerings, and/or to contact you -
when necessary - in connection with transactions entered into by you through
the Website Offerings, if any. We may also use your Information for internal
business purposes, such as analyzing, managing and optimizing our business. We
may combine any of the Information that we have gathered from you with
information from other Users and sources.
We reserve the right to
release current or past Information (including Sensitive Information) in the
event that: (i) we believe that you are using, or have used, the Website
Offerings in violation of this Privacy Policy, the Terms, or any of our other
operating rules, policies, schedules now in effect or which we may later
publish from time to time; (ii) we believe that you are using, or have used,
the Website Offerings to commit unlawful acts; (iii) such Information is
subpoenaed or requested pursuant to a judicial or regulatory proceeding or
inquiry; provided, however, that, where permitted by applicable law, we
shall provide you with e-mail notice, and opportunity to challenge the
subpoena, prior to disclosure of any of your Information pursuant to a
subpoena; (iv) we are sold, merge with a third-party or are acquired by a
third-party (collectively, "M&A Transactions") (including where we share
your Information, in connection with the due diligence process associated with
a potential M&A Transaction); (v) if we are the subject of bankruptcy proceedings;
provided, however, that if Company is involved in a bankruptcy
proceeding and/or M&A Transaction, you will be notified via e-mail and/or a
prominent notice on the Website of any change in ownership or uses of your
personal information, as well as any choices that you may have regarding your
personal information; and/or (vi) we deem it necessary or appropriate
including, without limitation, sharing your e-mail address with third parties
for suppression purposes in compliance with the CAN-SPAM Act of 2003, as
amended from time to time. You should also be aware that courts of equity, such
as U.S. Bankruptcy Courts, might have the authority under certain circumstances
to permit personal information to be shared or transferred to third parties
without permission.
By submitting your e-mail
address to us by and through the Website Offerings or otherwise, you agree to
receive e-mail marketing from us (including our other properties).
By registering with the Website,
you agree that such act constitutes an inquiry and/or application for purposes
of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from
time to time (the "TSR") and applicable state do-not-call regulations.
Further, notwithstanding that your telephone number may be listed on the
Federal Trade Commission's Do-Not-Call List, and/or on applicable state
do-not-call lists, we retain the right to contact you via telemarketing in
accordance with the TSR and applicable state do-not-call regulations.
Where
you provide "prior express consent" within the meaning of the Telephone
Consumer Protection Act (47 USC § 227), and its implementing regulations
adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended
from time-to-time ("TCPA"), you consent to receive telephone calls from Company,
including artificial voice calls, pre-recorded messages and/or calls (including
SMS text messages) delivered via automated technology, to the telephone number(s)
that you provided. Please note that you are not required to provide this
consent in order to obtain access to the Website Offerings, and your consent
simply allows Company to contact you via these means.
In connection with the
Website Offerings, we may make available a service by which you can receive
messages on your wireless device via short message service ("SMS
Service"). Your wireless service provider´s standard data and messaging
rates would apply to all such SMS correspondence. All charges are billed by,
and payable to, your mobile service provider. You represent that you are: (I) eighteen
(18) years of age or older (or the applicable age of majority if the age of
majority in your jurisdiction is greater than eighteen (18) years of age); (II)
the owner or authorized user of the wireless device on which SMS messages will
be received; and (III) authorized to approve the applicable charges. Data
obtained from you in connection with this SMS Service may include your name,
address, cell phone number, service provider's name, and the date, time, and
content of your SMS messages. If fees are charged to your wireless account
invoice, we may provide your carrier with your applicable information in
connection therewith. Your wireless carrier and other service providers may also
collect data about your wireless device usage, and their practices are governed
by their own policies. The use of this information will be in accordance with
this Privacy Policy. You may opt out of the SMS Service at any time, by
replying with the keywords "STOP," "END," or
"QUIT" to the SMS text message received from us or by using the
Unsubscribe link on the Website. Please note, by unsubscribing from the SMS
Service, you will not automatically be unsubscribed from other SMS programs to
which you may have also subscribed. You may receive assistance for the SMS
Service by replying with the keyword "HELP" to the message received.
You acknowledge and agree
that the SMS Service is provided via wireless systems which use radios (and
other means) to transmit communications over complex networks. We will not be
liable for any delays in the receipt of any SMS messages, as delivery is
subject to effective transmission from your network operator. The SMS Service is
provided on an "AS IS" and "AS AVAILABLE" basis. We are not responsible for
incomplete, lost, late, damaged, illegible or misdirected SMS messages or for
any technical problems, malfunctions of any telephone lines, computer systems,
servers, providers, hardware/software, lost or unavailable network connections
or failed, incomplete, garbled or delayed computer transmission or any
combination thereof. Furthermore, we assume no responsibility for undeliverable
SMS messages resulting from any form of active or passive mobile filtering by
your wireless service provider or for insufficient space in your mobile phone
account to messages. We also reserve the right, in our sole discretion, to
cancel or suspend the SMS Service for any reason, including where a virus, bug
or other cause beyond our control corrupts the administration, security or
proper operation thereof. We do not guarantee that your use of the SMS Service
will be private or secure, and we hereby disclaim all liability to you for any
lack of privacy or security that you may experience. You are fully responsible
for taking precautions and providing security measures best suited for your
needs and intended use of the SMS Service.
VII. How We May Disclose
and/or Sell Information
Please see our Privacy
Provisions for California Residents below for more details regarding our use,
sharing and sale of Personally Identifiable Information.
We may share and/or sell
Information that we have about Users in many ways and for many purposes, for
which we may be compensated, including the following:
·
By submitting your Information by and through the Website
Offerings, you agree that: (a) we may share, sell, rent, lease or otherwise
provide that Information (other than Sensitive Information) to any third-party
for any purpose permitted by law; and (b) we may work with other businesses to
bring selected third-party offers to you. These businesses and third-parties
may include, but are not limited to: (i) providers of direct marketing services
and applications, including lookup and reference, data enhancement, suppression
and validation; (ii) e-mail marketers; (iii) telemarketers (where permitted by
applicable law); and (iv) direct marketers.
·
We may share your Information with one or more vendors who provide independent
verification of consent, including verification of consent under the TCPA;
·
We may share your Information to enable customer service vendors to perform their
respective tasks, including for fulfillment of Promotions; and
·
We may share your Information to enable our Information verification and fraud
detection vendors to perform contracted for services.
·
With one or more Vendors who provide independent verification of consent, including verification of TCPA Consent for purposes of the TSR and TCPA;
When we share and/or sell
Information, we enter into agreements that describe the purpose for which the
Information is shared/sold, restrict its use to the agreement's specified
purpose and require that all Information remain confidential and protected from
unauthorized disclosure.
VIII. Collection and Use of
Your Non-Personally Identifiable Information
Please see our Privacy
Provisions for California Residents below for more details regarding our collection
and use of Non-Personally Identifiable Information.
Response Data.
Whenever you open, preview
or click on the advertising portion of our e-mail messages, the Website or any
of our other Online Media, we collect such response data and other Non-Personally
Identifiable Information for our internal marketing purposes (collectively,
"Response Data").
Ad-Serving.
We may serve advertisements
to you based, in part, on your IP address, the demographic and geographic Information
you submitted to us, as well as other socio-economic information, psychographic
information, Internet behavior (i.e., browsing, searching, purchasing,
ad-response behavior, etc.), and lifestyle information about you.
IP Address/Browser Type.
We may collect certain
Non-Personally Identifiable Information about you whenever you visit the
Website and/or our Online Media. This Non-Personally Identifiable Information
may include, without limitation, the type of browser that you use (e.g.,
Safari, Firefox, Chrome, etc.), your IP address, the type of operating system
that you use (e.g., Windows or Mac OS) and the domain name of your service
provider. We use the Non-Personally Identifiable Information that we collect to
improve our design and to personalize your experience. We also may use this
Information in the aggregate to analyze usage. We also reserve the right to use
aggregate or group data about our Users for any other lawful purposes.
Aggregate or group data is data that describes the demographics, usage and/or
characteristics of our Users as a group.
Behavioral Tracking.
Company, as well
as third party entities such as Google® and Facebook®, use Cookies (as defined
below), pixels and other tracking technology (collectively, "Tracking
Technology") in connection with the Website for purposes of tracking Users'
activities (such as websites visited, advertisements selected and pages viewed)
after they leave the Website. Company, and its third-party partners, use this
Tracking Technology to target applicable Users with advertisements featuring
Company products and/or services, as well as third-party products and/or
services, that may be of interest to applicable Users.
In general,
Users may be able to disable some, but not all, of this tracking activity by
utilizing the "Do Not Track" setting or similar options within most major
Internet browsers. In addition, Users may be able to opt-out of this form of
tracking utilizing the options made available by the Network
Advertising Initiative or Digital
Advertising Alliance.
Further, Users
can opt-out of this tracking by emailing us at: [email protected]. Users can
also opt-out of certain Google®-related tracking technology, and customize the
Google® Display Network ads that they receive, by visiting the Google® Ads Settings
at: http://www.google.com/settings/ads. Google® also recommends installing the
Google® Analytics Opt-out Browser Add-on for your web browser, which is
available here: https://tools.google.com/dlpage/gaoptout. To the greatest
extent permissible under applicable law, we are not responsible for the
tracking practices of third-parties in connection with the Website.
Cookies.
We collect some information
about you simply by virtue of you accessing the Website. Namely, when you visit
the Website, receive emails/communications, and/or access any of our other
Online Media, we, or a data provider that we have engaged, may place, recognize
or send a unique cookie, single-pixel GIF files/images and/or similar
technologies (collectively, "Cookie") to assign an anonymous, unique
identifier to your Internet browser. A Cookie is a small piece of data stored
on your computer's hard drive containing Non-Personally Identifiable
Information about you.
Cookies are not designed to collect
data from your hard drive, your e-mail account or any other Personally
Identifiable Information about you. No Personally Identifiable Information is
placed into these Cookies. Cookies are used to store information about an
individual's preferences and history in order to better serve the User and/or
present you with customized ads, content and/or services. Cookies may reflect
de-identified demographic or other data linked to data that you have
voluntarily submitted to us, e.g., your e-mail address, in hashed, non-human
readable form. Cookies have many benefits including, enhancing the functionality
of the Website Offerings, delivering a more personalized experience and
improving and delivering certain content and offerings. We may also use
software tools to measure and collect session information, including page
response times, download errors, length of visits to certain pages, page
interaction information (such as scrolling, clicks, and mouse-overs) and
methods used to browse away from the page. To learn more about interest-based
advertising in general and to opt out, please visit http://www.aboutads.info/choices.
If you do not want
information collected through the use of Cookies, there is a simple procedure
in most Internet browsers that allows you to accept or reject most Cookies. To
disable and reject certain Cookies, follow the instructions associated with
your Internet browser. Please note that if you reject our Cookies, it is
possible that you will be prevented from accessing certain Website Offerings,
some of the Website pages and other Online Media may not properly load, your
access to certain information might be denied, and/or you might have to enter
information about yourself more than once. We reserve the right to retain
Cookie data indefinitely.
To protect your privacy, we
do not use Cookies to store or transmit any Personally Identifiable Information
about you on the Internet.
Cross Device Tracking.
Company tracks Users' use of
the Website Offerings across various devices, including Users'
personal computers and mobile devices, in order to optimize and personalize use
of the Website Offerings. Company may collect
certain User personal information across various devices.
Aggregate Data.
Company reserves the right
to transfer and/or sell aggregate or group data about Users of the Website Offerings for lawful purposes. Aggregate or group data is
data that describes the demographics, usage and other characteristics of Website Offerings Users as a group, without disclosing Personally
Identifiable Information.
No Spyware.
We do not install any
spyware or adware in connection with the Website Offerings, or distribute any
commercial message, or authorize any third party to distribute any commercial
message, by means of spyware or adware. "Spyware" or
"adware" is any software which has been downloaded to and/or
installed on an Internet user's computer, without that individual's actual
consent, and facilitates the distribution of any commercial message to that
individual. If you feel that you may have spyware from another company installed
on your machine, there are various anti-spyware/adware software applications
available on the Internet to identify if this has occurred.
Website Tracking
Software/Domain Addresses.
Our web servers, utilize
certain tracking software to capture your domain address (the address of your
Internet service provider) for purposes of tracking statistics. The capture of
your domain address is a common practice among websites for measuring the
number of hits, pages visited and length of time spent on a site. We use this
information to measure the effectiveness of Website offerings in order to
better serve you.
IX. Privacy
Provisions for California Residents
These Privacy
Provisions for California Residents ("Privacy Provisions") supplement,
and do not limit in any way, the Privacy Policy set forth above. These Privacy
Provisions apply solely to residents of the State of California ("CA Users").
We adopt these Privacy Provisions in compliance with the California Consumer
Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have
the same meaning when used in these Privacy Provisions. CA
Users with disabilities who wish to access these Privacy Provisions in an
alternative format can contact us by: emailing us at: [email protected];
calling us at: (844) 435-3969;
or sending us U.S. Mail to: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.
Categories of Information We Collect
We
collect information that identifies, relates to, describes, references, is
capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular CA User or device ("personal information").
In particular, we have collected the following categories of personal
information from CA Users within the last twelve (12) months:
Category
|
Examples
|
Collected
|
A. Identifiers.
|
A real name, alias,
postal address, unique personal identifier, online identifier, Internet
Protocol address, email address, account name, telephone number, or other
similar identifiers.
|
YES
|
B. Personal
information categories listed in the California Customer Records statute
(Cal. Civ. Code § 1798.80(e)).
|
A name, signature,
Social Security number, physical characteristics or description, postal
address, telephone number, passport number, driver's license or State
identification card number, insurance policy number, education, employment,
employment history, bank account number, credit card number, debit card
number, or any other financial information, medical information, or health
insurance information. Some personal information included in this category
may overlap with other categories.
|
YES
|
C. Protected
classification characteristics under California or federal law.
|
Age (40 years or
older), race, color, ancestry, national origin, citizenship, religion or
creed, marital status, medical condition, physical or mental disability, sex
(including gender, gender identity, gender expression, pregnancy or
childbirth and related medical conditions), sexual orientation, veteran or
military status, genetic information (including familial genetic
information).
|
YES
|
D. Commercial
information.
|
Records of personal
property, products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.
|
YES
|
F. Internet or other
similar network activity.
|
Browsing history,
search history, information on a CA User's interaction with a website,
application or advertisement.
|
YES
|
K. Inferences drawn
from other personal information.
|
Profile reflecting a
person's preferences, characteristics, psychological trends, predispositions,
behavior, attitudes, intelligence, abilities, and aptitudes.
|
YES
|
Personal
information does not include:
- Publicly
available information from government records.
- De-identified
or aggregated CA User information.
- Information
excluded from the CCPA's scope, such as:
- health or
medical information covered by the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) and the California Confidentiality of
Medical Information Act (CMIA) or clinical trial data; and
- personal
information covered by certain sector-specific privacy laws, including
the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA)
or California Financial Information Privacy Act (FIPA), and the Driver's
Privacy Protection Act of 1994.
We
obtain the categories of personal information listed above from the following
categories of sources (with the specific categories of personal information
indicated in parenthesis):
- Directly
from our CA Users. For example, from online registration forms that our CA
Users submit to us in connection with the products and/or services that we
offer by and through the Website. (Categories A, B, C, D and K)
- Indirectly
from our CA Users. For example, through information we collect from our CA
Users in the course of providing our products and/or services to them. (Categories
A, B, C, D, F and K)
- Directly
and indirectly from activity on the Website. This includes the type of
browser that the CA User uses (e.g., Safari, Chrome, Internet Explorer),
CA User IP address, the type of operating system used by the CA User
(e.g., Windows or iOS) and the domain name of the CA User's Internet
Service Provider. In addition, we obtain certain Website usage details
and analytics as same are collected automatically by us and our third
party partners. (Category F)
- When our CA
Users interact with us on our social media accounts, including commenting
on and/or liking our posts. (Categories A, B, C, D, F and K)
- From
third-parties that interact with us in connection with the products and/or
services that we offer to our CA Users. For example, third party entities
that assist us in sending direct and electronic mail, removing duplicate
information from CA User lists, analyzing data and providing marketing
analysis. (Categories A, B, C, D, F and K)
Use
of Personal Information
We
may use or disclose the personal information (including: (a)
full name; (b) mailing address/state of residence; (c) e-mail address; (d)
telephone number; (e) gender; and (f) date of birth)
that we collect for one or more of the following business purposes (with the
specific categories of personal information indicated in parenthesis):
- To fulfill
or meet the reason for which the information is provided. For example, if
you provide us with personal information in connection with your request
for the products and/or services featured on our Website, we will use
that information to process your request. (Categories A, B, C, D, F
and K)
- To provide
you with information, products or services that you request from us. (Categories
A, B, C, D, F and K)
- To create,
maintain, customize and secure your account with us. (Categories A, B, C,
D, F and K)
- To provide
you with e-mail, direct mail and telemarketing messages concerning certain
Company products and/or services, as well as third-party products and/or
services, that we believe may be of interest to you. (Categories A, B, C,
D, F and K)
- To deliver
relevant Website content and advertisements to you and measure or
understand the effectiveness of the advertising we serve to you. (Categories
A, B, C, D, F and K)
- To carry
out our obligations and enforce our rights arising from any contracts
entered into between you and us, including the Website's Terms and
Conditions. (Categories A, B, C, D, F and K)
- To improve
the Website and better present its contents to you. (Categories A, B, C,
D, F and K)
- For
customer service purposes and to respond to inquiries from you. (Categories
A, B, C, D, F and K)
- For
testing, research, analysis and product development. (Categories A, B, C,
D, F and K)
- As
necessary or appropriate to protect our rights, property or safety, and
that of our customers or others. (Categories A, B, C, D, F and K)
- To respond
to law enforcement requests and as required by applicable law, court
order, or governmental regulations. (Categories A, B, C, D, F and K)
- As
described to you when collecting your personal information or as otherwise
set forth in the CCPA. (Categories A, B, C, D, F and K)
- To evaluate
or conduct a merger, divestiture, restructuring, reorganization,
dissolution or other sale or transfer of some or all of our assets,
whether as a going concern or as part of bankruptcy, liquidation or
similar proceeding, in which personal information held by us is among the
assets transferred. (Categories A, B, C, D, F and K)
We
will not collect additional categories of personal information or use the
personal information we collected for materially different, unrelated or
incompatible purposes without providing you with notice.
Sharing
Personal Information
Subject
to your right to opt-out of such sharing/sale, we may share your personal
information (including: (a) full name; (b) mailing address/state
of residence; (c) e-mail address; (d) telephone number; (e) gender; and (f)
date of birth) for the other business purposes set forth
above.
When
we disclose personal information to a third party service provider or other
entity, we enter into a contractual relationship that describes the purpose for
which such third party may use the personal information and requires that third
party to both keep the personal information confidential and not use it for any
purpose other than the performance of its services under the applicable
contract. Please note, we do not collect information from CA Users that we
actually know are less than eighteen (18) years of age and we do not share or
sell the personal information of CA Users that we actually know are less than
eighteen (18) years of age. Without limiting the foregoing, we have not shared
or sold the personal information of CA Users that we actually know are less
than sixteen (16) years of age in the preceding twelve (12) months.
In
the preceding twelve (12) months, we have disclosed the following categories of
personal information including: (a) full name; (b)
mailing address/state of residence; (c) e-mail address; (d) telephone number;
(e) gender; and (f) date of birth) for a business
purpose:
Category
A Identifiers.
Category B California Customer Records personal information categories.
Category C Protected classification characteristics under California or
federal law.
Category D Commercial information.
Category F Internet or other similar network activity.
Category I Professional or employment-related information.
We
disclose your personal information (including: (a) full name;
(b) mailing address/state of residence; (c) e-mail address; (d) telephone
number; (e) gender; and (f) date of birth) for a business
purpose to the following categories of third parties (with the specific
categories of personal information indicated in parenthesis):
- Our
affiliates. (Categories A, B, C, D, F and K)
- Service
providers. (Categories A, B, C, D, F and K)
- Third
parties who purchase and/or license your personal information for
marketing purposes, including: (a) providers of direct marketing services
and applications, including lookup and reference, data enhancement,
suppression and validation; (b) e-mail marketers; (c) telemarketers (where
permitted by applicable law); and (d) direct marketers. (Categories A, B,
C, D, F and K).
- Third
parties to whom you authorize us to disclose your personal information in
connection with the products and/or services that we provide to you. (Categories
A, B, C, D, F and K)
In
the preceding twelve (12) months, we have sold the following categories of
personal information including: (a) full name; (b)
mailing address/state of residence; (c) e-mail address; (d) telephone number;
(e) gender; and (f) date of birth) to third parties:
Category
A Identifiers.
Category B California Customer Records personal information categories.
Category C Protected classification characteristics under California or
federal law.
Category D Commercial information.
Category F Internet or other similar network activity.
Category I Professional or employment-related information.
In
the preceding twelve (12) months, we have sold the above referenced categories
of personal information to the third parties who purchase and/or license your
personal information for marketing purposes, as well as the third parties who
provide the products and/or services featured by and through the Website.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt in data and consent; this information will not be shared with any third parties
Your
Rights and Choices
The
CCPA provides CA Users (California residents) with specific rights regarding
their personal information. This section describes your CCPA rights and
explains how to exercise those rights.
Opt-Out
from the Sharing of Your Personal Information
You
have the right to opt-out of our sharing your personal information with third
parties. To exercise your right to opt-out of our sharing your personal
information with third parties, please submit a verifiable CA User request to
us by either:
- Clicking
here;
- Calling us
at: (844) 435-3969;
- Emailing us
at: [email protected]; or
- Sending us
U.S. Mail to: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.
We
endeavor to act on all opt-out requests as soon as practicable, but in all
cases within fifteen (15) business days of the receipt of your request.
Opt-Out from the Use and/or Sharing of
Your Sensitive Personal Information
You
have the right to limit our use of your sensitive personal information,
including any sensitive information from Category B (California Customer
Records personal information), Category C (Protected classification
characteristics under California or federal law), Category D (Commercial
information) and/or Category K (Inferences drawn from other personal
information), to those uses which: (i) are necessary to perform the services or
provide the goods requested by you; (ii) help us to ensure security and integrity
of your personal information to the extent the use of your sensitive personal
information is reasonably necessary and proportionate for these purposes; (iii)
are short-term, transient uses including, but not limited to, non-personalized
advertising shown as part of your then-current interaction with the Website,
provided that your personal information is not disclosed to another third party
and is not used to build a profile about you or otherwise alter your experience
outside the then-current interaction with the Website; (iv) involve performing
services on behalf of Company, including maintaining or servicing accounts,
providing customer service, processing or fulfilling orders and transactions,
verifying customer information, processing payments, providing financing,
providing analytic services, providing storage, or providing similar services
on behalf of Company; and (v) include activities to verify or maintain the
quality or safety of a service or device that is owned, manufactured, manufactured
for, or controlled by, Company, and to improve, upgrade, or enhance the service
or device that is owned, manufactured, manufactured for, or controlled by,
Company.
You
also have the right opt-out of our sharing your sensitive personal information
with third parties, including any sensitive information from Category B
(California Customer Records personal information), Category C (Protected
classification characteristics under California or federal law), Category D
(Commercial information) and/or Category K (Inferences drawn from other
personal information).
To
exercise your right to limit our use of your sensitive personal information
and/or opt-out of our sharing your sensitive personal information with third
parties, please submit a verifiable CA User request to us by either:
- Clicking
here;
- Calling us
at: (844) 435-3969;
- Emailing us
at: [email protected]; or
- Sending us
U.S. Mail to: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.
We
endeavor to act on all such requests as soon as practicable, but in all cases
within fifteen (15) business days of the receipt of your request.
Access
to Specific Information and Data Portability Rights
You
have the right to request that we disclose certain information to you about our
collection and use of your personal information over the past twelve (12)
months. Once we receive and confirm your verifiable CA User request, 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 have shared 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 CA User request, we will delete (and direct
our service providers to delete) your personal information from our (their)
records, unless an exception applies; provided, however, that in some
cases, strictly for regulatory compliance purposes and to better evidence/honor
opt-out/unsubscribe requests (and for no other purposes), we may retain certain
items of your personal information on a de-identified and aggregated basis in
such a manner that the data no longer identifies you.
We
may deny your deletion request if retaining the information is necessary for us
or our service providers 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, or
otherwise perform our obligations in connection with our
contract/relationship 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 rights, ensure the right of another CA User to exercise
her/his free speech rights or exercise another right provided for by law.
- Comply with
the California Electronic Communications Privacy Act (Cal. Penal Code §
1546 seq.).
- 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, but only if you previously
provided informed consent.
- Enable
solely internal uses that are reasonably aligned with CA User 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.
Exercising
Access, Data Portability and Deletion Rights
To
exercise your access, data portability and/or deletion rights described above,
please submit a verifiable CA User request to us by either:
- Clicking
here;
- Calling us
at: (844) 435-3969;
- Emailing us
at: [email protected]; or
- Sending us
U.S. Mail to: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.
Only
you or a person registered with the California Secretary of State that you
authorize to act on your behalf, may make a verifiable CA User request related
to your personal information.
You
may only make a verifiable CA User request for access or data portability twice
within a 12-month period. The verifiable CA User request must:
- Provide
sufficient information that allows us to reasonably verify that you are:
(1) the person about whom we collected personal information; or (2) an
authorized representative.
- 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 that
the personal information relates to you. Making a verifiable CA User
request does not require that you create an account with us. We will only
use personal information provided in a verifiable CA User request to verify the
requestor's identity or authority to make the request.
Response
Timing and Format
We endeavor to respond to all verifiable CA User
requests within forty-five (45) days of the receipt thereof. If we
require more time (up to ninety (90) days), we will inform you of the reason
and extension period in writing. We will deliver our written response by
mail or electronically, at your option. Any disclosures that we provide
will only cover the twelve (12) month period preceding the receipt of your
verifiable request. The response that we provide will also explain the
reasons that 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 useable 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 CA User 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.
Unless permitted by the CCPA, we will not:
- Deny you
goods or services;
- Charge you
different prices or rates for goods or services, including through
granting discounts or other benefits, or imposing penalties;
- Provide you
a different level or quality of goods or services; and/or
- Suggest
that you may receive a different price or rate for goods or services or a
different level or quality of goods or services.
Changes
to these Privacy Provisions
We
reserve the right to amend these Privacy Provisions in our discretion and at
any time. When we make changes to these Privacy Provisions, we will notify you
by email or through a notice on the Website's homepage.
Contact
Information
If
you have any questions or comments about these Privacy Provisions, our Privacy
Policy, the ways in which we collect and use your personal information, your
choices and rights regarding such use, or wish to exercise your rights under
California law, please do not hesitate to contact us by either:
- Calling us
at: (844) 435-3969;
- Emailing us
at: [email protected]; or
- Sending us
U.S. Mail to: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.
X. Unsubscribe/Opt-Out
Please see our Privacy
Provisions for California Residents above for more details regarding opting-out
from the sharing and/or sale of Information.
You may unsubscribe to
opt-out from having your Information shared by us, or opt-out from our e-mail
marketing program altogether at any time by: (a) sending us an e-mail at: [email protected]; or
(b) calling us toll free at: (844) 435-3969. We also include an
unsubscribe/opt-out mechanism within every message that we send.
To opt-out of receiving SMS
text messages from us, you can: (i) text "STOP," "END," or
"QUIT" to opt-out from future messages; or ii) e-mail us at: [email protected].
We attempt to process all
unsubscribe/opt-out requests in a prompt fashion. However, after unsubscribing,
we cannot guarantee that you will never receive another communication from us
because we may obtain your contact information in the future through a
different entity that you have subscribed through. Notwithstanding the
foregoing, we may continue to contact you for the purpose of communicating
information relating to your request for Website Offerings, your participation
in Promotions, as well as to respond to any inquiry or request made by you. To
opt-out of receiving Website Offerings-related, Promotions-related and/or
inquiry response-related messages from us, you must cease requesting and/or
utilizing Website Offerings, cease participating in and/or entering Promotions
and cease submitting inquiries to us, as applicable.
XI. Security
We endeavor to safeguard and
protect our Users' Information. When Users make Information available to us,
their Information is protected both online and offline (to the extent that we
maintain any Information offline). Where our registration/application process
prompts Users to enter Sensitive Information, and when we store and transmit
such Sensitive Information, that information is encrypted with advanced TLS
(Transport Layer Security).
Access to your Personally
Identifiable Information is strictly limited, and we take reasonable measures
to ensure that your Personally Identifiable Information is not accessible to
the public. All of our Users' Information is restricted in our offices, as well
as the offices of our third-party service providers, as applicable. Only
employees or third-party agents who need User Personally Identifiable
Information to perform a specific job are granted access to User Personally
Identifiable Information. Our employees are dedicated to ensuring the security
and privacy of all Information. Employees not adhering to our firm policies are
subject to disciplinary action. The servers that we store Personally
Identifiable Information on are kept in a secure physical environment. We also
have security measures in place to protect the loss, misuse and alteration of Personally
Identifiable Information under our control.
Please be advised, however,
that while we take every reasonable precaution available to protect your data,
no storage facility, technology, software, security protocols or data
transmission over the Internet or via wireless networks can be guaranteed to be
100% secure. Computer hackers that circumvent our security measures may gain
access to certain portions of your Information, and technological bugs, errors
and glitches may cause inadvertent disclosures of your Information; provided,
however, that any attempt to breach the security of the network, our
servers, databases or other hardware or software may constitute a crime
punishable by law. For the reasons mentioned above, we cannot warrant that your
Information will be absolutely secure. Any transmission of data at or through
the Website, Online Media, other Website Offerings or otherwise via the
Internet or wireless networks, is done at your own risk.
XII. Security Breach
In compliance with
applicable federal and state laws, we shall notify you and any applicable
regulatory agencies in the event that there has been an information security
breach. You will be notified via e-mail in the event of such a breach of
security. Please be advised that notice may be delayed in order to address the
needs of law enforcement, to determine the scope of network damage, and/or to
engage in remedial measures.
XIII. Children's Privacy
Please see our Privacy
Provisions for California Residents above for more details regarding the
Personally Identifiable Information of minors.
We encourage parents and
guardians to spend time online with their children and to participate and
monitor the interactive activities of their children. We are very sensitive to
the issue of children's privacy and, therefore, we strive to protect the
privacy of children using the Internet. We do not knowingly solicit or collect
personal information from persons under eighteen (18) years of age. If a person
under eighteen (18) years of age has already provided us with any Information,
his or her parent or guardian may contact us for the purpose of immediately
deleting this Information.
XIV. Accessing, Modifying
and Deleting Your Information
Please see our Privacy
Provisions for California Residents above for instructions on how California
Residents can access, modify and/or delete Personally Identifiable Information
that we have collected.
If you would like to know if
we have any of your Information in our database or would like to review and
update or correct the Information that we have collected from you, simply: (a)
send your request via e-mail to: [email protected]; (b)
call us toll free at: (844) 435-3969; or (c) send us certified postal mail to
FinancialReliefCenter at: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.
To protect your privacy and
security, we may take reasonable steps to help verify your identity before granting
access or making corrections, and we may decline to process requests that are
unreasonably repetitive or systematic, require disproportionate technical
effort, jeopardize the privacy of others or would be extremely impractical (for
instance, requests concerning information residing on backup tapes).
Please be advised that
requesting the deletion of your Information will terminate your right to access
the Website Offerings and/or to participate in Promotions. Please be further
advised that, after you request the deletion of your Information, residual
copies may take a period of time before they are deleted from our active
servers and may be remained in our backup systems. In addition, this deletion
will not change or delete Information which may have already been shared with
third parties, all as provided above in this Privacy Policy. You will need to
contact the third parties that contact you directly to change your preferences
regarding their use of your Information.
XV. Limitation of Liability
YOU HEREBY ACKNOWLEDGE AND
AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF
THIS PRIVACY POLICY, AS WELL AS THE TERMS AND CONDITIONS OF THIS WEBSITE
(INCLUDING LIMITATIONS ON DAMAGES). YOU AGREE THAT COMPANY'S LIABILITY FOR ANY
BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS
OR SERVICES PROVIDED TO YOU BY COMPANY TO THE EXTENT SUCH CLAIM IS NOT
OTHERWISE BARRED BY THE TERMS.
XVI. Transfer of Personal
Information Internationally
If you are accessing the
Website or other online media from a country other than the country in which
our servers are located, your communications with us may result in the transfer
of Information across international boundaries. By accessing the Website or
other Online Media, and/or otherwise communicating electronically with
us, you consent to such transfers. Even if your jurisdiction does not have the
same privacy laws as the jurisdiction where our servers are located, we will
treat your Information as subject to the protections described in this Privacy
Policy.
XVII. Filing a Complaint
with the Federal Trade Commission
See the Federal Trade
Commission (the "FTC") website at https://www.ftc.gov/legal-library/browse/rules/can-spam-rule for
updates on implementation of the CAN-SPAM Act of 2003, as amended. The FTC
maintains a consumer complaint database of violations of the various laws that
the FTC enforces. Consumers can submit complaints online at www.ftc.gov and
forward unwanted and unsolicited commercial e-mail to the FTC at: [email protected].
The FTC works as a consumer advocate in order to prevent fraudulent, deceptive
and unfair business practices. To file a complaint with the FTC or to request
free information about consumer issues, please visit www.ftc.gov or call
toll-free, 1-877-FTC-HELP.