Information We Collect
We collect certain information that is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household. When you visit or use our online services, we may collect personal information from or about you such as your name, email address, mailing/postal address, telephone number(s), account numbers, limited location information (for example, a zip code), username and password, education, employment, and employment history. We may also collect payment card information, social security numbers, passport number, and driver’s license number (or similar identification number) when you provide such information while using Our online services and where we believe it is reasonably required for ordinary business purposes.
Usage and Other Information
For your convenience, We offer you the limited ability to access some of our products and services through mobile applications and mobile-optimized websites. When you interact with Us through a mobile device, We may collect information such as unique device identifiers for your mobile device, your screen resolution and other device settings, information about your location, and analytical information about how you use your mobile device.
In addition, if you use certain features of Our services, website, or platform, We may collect certain telephony information such as phone numbers, time and date of calls, duration of calls, text messages, routing information, device event information (such as crashes, system activity, hardware settings, browser, and language), and device location information (such as IP address, Global Positioning Satellite information, and other sensors that may provide us with information on nearby devices, Wi-Fi access points, and cellular towers).
Widget and Social Media
We may provide widgets that make it possible to share information on third-party services. We may also include social media features, such as Facebook or Twitter button and similar widgets and interactive mini-programs that run on Our site. To the extent We use these features, they may collect your internet protocol address, record which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly by Us. Your interactions with these features are governed by this Policy.
Additional Sources of Information
We may also collect information about you from additional online and offline sources including from co-branded partner sites or commercially available third-party sources, such as credit reporting agencies. We may combine this information with personal and other information have collected about you under this Policy.
Use of Information
We use the information discussed above in a number of ways, including:
- Processing applications and transactions;
- Verifying your identity;
- Preventing fraud and enhancing the security of your account or Our online services;
- Responding to your requests and communicating with you;
- Managing your preferences;
- Performing analytics concerning your use of our online services, including your responses to Our emails and pages and advertisements you view;
- Providing you tailored content and marketing messages; operating, evaluating and improving our business (including developing new products and services; improving existing products and services; performing data analytics; and performing account, auditing and other internal functions);
- Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies; and
- For any other purposes that we may specifically disclosure at the time you provide or we collect your information.
We may also use data that We collect on an aggregate or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations.
Depending on the circumstances, We may rely on your consent or the fact that the processing is necessary to fulfil a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations.
Disclosure of Personal Information
We may share the information We collect from and about you with our affiliates, subsidiaries, and other third parties. For example, we may share your information with:
- Our third-party service providers;
- Our affiliated websites and business in an effort to bring you improved service across our family of products and services, when permissible under relevant laws and regulations;
- Other companies to bring you co-branded services, products or programs;
- Third parties or affiliates and subsidiaries in connection with a transaction, such as a sale, consolidation, or merger of LHS business; and
We may share anonymous or aggregate information with third parties to help deliver products, services, and content that are better tailored to the users of our online services and for other purposes.
Disclosures in the Previous 12 Months
We have not sold or shared any personal information, as defined by the California Consumer Privacy Act, within the last 12 months.
Communications by Us
Requests for Information
If you provided us with your email address or phone number to receive information from Us, We and Our partners may contact you using the contact information you provided Us regarding Our platform, site, or services. We and Our partners may make such contact by email, phone, and/or text (SMS/MMS), including the phone number you provided Us, and We may use automated dialers technology in order to connect you with one of Our representatives. Your mobile phone carrier’s standard message and data rates may apply to text messages. You are not required to provide your phone number as a condition of purchasing access to Our platform, sites, or services.
Email and SMS
We may communicate with you through email and text messaging (SMS/MMS) using your personal contact information on file in Our system to inform you of new products, important industry and company news, information about our platform, sites, and services, and as otherwise provided in this Policy, unless you opt out of such communications.
Protection of Personal Data
We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data, the process, and the threats posed. This includes device safeguards and secured files and buildings.
Please note that information you send to us electronically may not be secure when it is transmitted to use. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to Us.
Cookies, Web Beacons, and Other Tracking Technologies
- Communications Cookies. These cookies are used to enable network traffic to and from Our systems, including helping us detect any errors.
- Strictly Necessary Cookies. These cookies are set as required to provide a specific feature or service that you have accessed or requested. For example, they allow Us to display Our websites in the proper format and language, and to authenticate and verify your transactions.
- Other Cookies. These cookies are used to understand how visitors interact with Our websites and online services, including by helping Us to assess the effectiveness of advertisements and web searches. We also use these cookies to remember choices you make while browsing, so we can provide you with a customized experience.
- Clear GIFs, Pixel Tags, or Web Beacons. These are typically one-pixel, transparent images located on a webpage or in an email or other message that may be used on Our sites and in some of Our digital communications (such as email or other marketing messages). They may also be used when you are served advertisements or you otherwise interact with advertisements outside of our online services. These are principally used to help recognize users, assess traffic patterns, and measure site or campaign engagement.
- Local Shared Objects. Sometimes referred to as “flash cookies”, these may be stored on your hard drive using a media player or other software installed on your device. Local shared objects are similar to cookies in terms of their operation, but may not be managed in your browser in the same way.
Automated Processing and Automated Decision-Making
Automated decision-making refers to a decision that is taken solely based on automated processing of your personal data. Profiling is a form of automated processing that involves evaluating and assessing certain aspects about you, in order to analyze or predict your personal preferences, interests, or behavior.
We may use automated decision-making and profiling in the following instances:
- Chatbots. We may use chatbots, a software that conducts an automated conversation to answer your questions and improve Our customer service.
- Analytics. We may use analytics of your profile and usage experience to provide personalized product recommendations to you.
- Retargeting. We or Our third-party service providers may use “retargeting”, which means we may send you or display to you communications and content specifically tailored to your interests and needs based on your previous internet actions.
You may have the right to object at any time to the use of automated processing or automated decision-making. Please see Your rights and Your Choices sections below for more information about your rights. To turn off personalized advertising, please change your cookie settings.
You will see advertisements when you use many of Our online services. These advertisements may be for our own products or services or for products and services offered by third parties. Which advertisements you see if often determined using the information We or Our affiliates, service providers, and other companies that we work with have about you including information about your relationships with Us (i.e. types of accounts held, transactional information, and location). Where permitted by applicable law, We may share with others the information We collect from and about you.
We may also use online behavioral advertising (“OBA”). OBA refers to the practice of collecting information from a computer or device regarding a visitor’s web-browsing activities across non-affiliated websites over time in order to deliver advertisements that may be of interest to you based on your browsing history. Through OBA, we hope to deliver advertisements that are most likely to be of interest to you using information about your other web-browsing activities (such as the web pages you visit, the search terms you enter, and the way you move through Our online services on your computer or device) or your personal profile (i.e. demographic or location information). Certain companies we work with may set cookies and use related tracking technologies, such as the clear GIFs discussed above, throughout Our online services or in Our communications to support these OBA efforts. If you do not want your information collected and used by the companies we work with for OBA purposes, you can opt out of this form of OBA by following the instructions in the Your Rights and Your Choices sections below.
Testimonials and Reviews
We may select and post testimonials about Us or Our platform, which may contain personal data such as your name and/or city, state, or country in which you live. We will obtain your consent prior to posting any testimonial with your name. If We post such content, it will be available to other customers and visitors. Your posting may also become public and we cannot prevent such information from being used in a manner that may violate this Policy of the law. If you would like Us to remove or delete your name or testimonial, you may contact Us at [CustomerSupport@commissionbasedmarketing.com]. Note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages for a period of time.
We may post reviews provided by you about Us or Our platform, which may contain personal data such as your name and/or the city, state, or country in which you live. When submitting your review, you are giving us permission to post your review. If you post such content, it will be available to other users of our website or platform. Your posting may also become public and we cannot prevent such information from being used in a manner that may violate this Policy or the law. If you would like us to remove your name or review from Our website, you may contact Us at [email address]. Note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages for a period of time.
Children and Personal Data
We do not collect or maintain information on our site from those that We actually know are under the age of 16. Our websites, platforms, and advertising are intended for business audiences, and no part of our website, platform, or advertising is intended to attract anyone under the age of 16.
You may have certain rights relating to your personal data, subject to local data protection laws. Please note that you can only exercise these rights with respect to personal data that we process or collect about you. Your rights are dependent on the location of your domicile.
If your domicile is in the European Union, the United Kingdom, or Brazil, you may have the following rights:
- Right to Access. You may have the right to access your personal data held by Us.
- Right to Rectify. You may have the right to rectify inaccurate personal data and, taking into account the purpose of the processing of the personal data, ensure that it is complete and accurate.
- Right to be Forgotten. You may have the right to erase or delete your personal data.
- Right to Restriction of Processing. You may have the right to restrict Our processing of your personal data.
- Right to Data Portability. You may have the right to transfer your personal data to another control, to the extent possible.
- Right to Object. You may have the right to object to any processing of your personal data carried out on the basis of Our legitimate interests. Where We process your personal data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you may exercise your right to object at any time to such processing without having to provide any specific reason for such objection.
- Automated Processing. You may have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects.
- Withdrawal of Consent. To the extent We base the collection, processing, and sharing of your personal data on your consent, you may have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal. If you have given consent for your details to be shared with a third party, and wish to withdraw this consent, please also contact the relevant third party in order to change your preferences.
If your domicile is located in California, USA, you may have the following rights:
- Right to Know. You have the right to know what personal information We have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about the consumer.
- Right to Delete. You have the right to delete personal information We have collected from you, subject to certain exceptions provided for by law.
- Right to Correct. You have the right to correct inaccurate personal information We maintain about you.
- Opt-Out. To the extent that We sell or share your personal information, you have the right to opt-out of the sale or sharing of your personal information by Us.
- Limited Disclosure of Sensitive Information. If We use or disclose sensitive personal information for reasons other than those set forth in California Civil Code § 7027, you have the right to limit the use or disclosure of sensitive personal information by Us.
- No Retaliation. You have the right not to receive discriminatory treatment by Us for the exercise of the privacy rights conferred by the California Consumer Privacy Act of 2018 (CCPA) including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of these CCPA rights.
To exercise your CCPA rights, you must send Us an email at [CustomerService@commissionbasedmarketing.com] or a written letter to [12621 N Tatum Blvd suite 527, Phoenix 85032] detailing which CCPA right you seek to exercise and what data, specifically, you wish to exercise your rights in regard to. We will attempt respond to your email within seventy-two (72) hours but in no event will we respond later than forty-five (45) days from the date We receive your request. We may request that you provide Us with additional information sufficient to verify your identity, verify that we possess the specified data, and ensure that We are complying with all legal requirements. This may include, but is not limited to, addresses, phone numbers, drivers license number, and social security number. We may also request an additional forty-five (45) to respond to your request where appropriate.
You may authorize an agent to exercise your CCPA rights on your behalf. Your agent must provide Us with a written and notarized agreement whereby you authorize your agent to exercise your CCPA rights on your behalf. Authorized agents may seek to exercise your CCPA rights on your behalf by sending Us an email at [CustomerService@commissionbasedmarketing.com]. Your authorized agent must attach the written and notarized agreement to this email. If We receive the proper documentation authorizing your agent to exercise your CCPA rights on your behalf, We will process the request as if it were made by you.
If you have any questions about this Policy or about your rights thereunder, please email Us at [CustomerService@commissionbasedmarketing.com].
You have choices with respect to your personal data and can choose to not provide personal data to Us. Our platform, sites, and products may require some personal data to provide you with a service. If you choose not to provide data required to provide you with a service or feature, you cannot use that service or feature. We may also need to collect personal data as required by law or to enter into or carry out an agreement with you. If you do not provide any such required personal data, We will not be able to enter into the agreement or provide you with the requested product or service. If you are already using our platform, site, or products and choose not to provide Us with any necessary personal data We may have to suspend or cancel the impacted products or services.
Changes to this Notice