Last Updated: 01-02-2022
4. INFORMATION WE MAY COLLECT
User Data and Personal Information
We may collect the following categories of personal information about you:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
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, 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.
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).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like: 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;
- 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.
Sources of Information
We obtain this information directly from you and your agents, as well as from affiliates, independent sales representatives, and third parties, including those to whom you have previously provided data and those to whom you have directed us to obtain information, service providers, and from publicly available sources, like government records, or from information you have made public.
5. USE OF INFORMATION
We use your information to:
- establish and administer user accounts on our Websites;
- deliver Websites, mobile applications, content and services to you;
- carry out our obligations and enforce our rights arising from any contracts between you and us;
- process payments;
- perform identity verification;
- personalize your experience when using the Websites;
- debug to identify and repair errors that impair existing intended functionality;
- respond to your inquiries about our services;
- analyze site usage and improve the services provided through our Websites;
- deliver to you any administrative notices or alerts and communications relevant to your use of our Websites or our services;
- detect and protect against errors, fraud, or other criminal activity;
- fulfill any other purpose for which you provide such information or with your consent;
- fulfill regulatory or legal obligations; and
- in connection with a merger, sale, of substantially all of our assets, or corporate reorganization.
We may disclose personal information that we collect to the following:
- With third party entities, such as insurance companies, with your consent, and for the purpose for which you provided the personal information;
- With our related entities to perform their everyday business purposes; and
- With independent agents, contractors, professional service providers, and business consultants that we use to support our business. These third parties are bound by contractual obligations to keep personal information that we share with them confidential and use it only for the purposes for which we disclose such information to them.
6. SHARING OF INFORMATION
We may disclose your personal information to third parties in order to operate, manage, and maintain our business; provide products and services offered by us or independent sales representatives; manage our employees, contractors, and third parties; and accomplish our business purposes and objectives. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Identifiers, Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), Protected classification characteristics under California or federal law, Professional or employment-related information, and Inferences drawn from other personal information.
We may also share your information with other third parties in the following cases:
- Where disclosure is required or appropriate in order to comply with laws, regulations, legal process, or an agency or governmental request;
- With law enforcement officials, government authorities, or third parties, if we think doing so is necessary to protect the rights, property, or safety of the Company, users, or the public;
- To protect the security or integrity of our Websites;
- To respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person;
- To investigate and defend ourselves or others against any third-party claims or allegations;
- While negotiating or in relation to a business transaction, such as a merger, sale of assets, or bankruptcy;
7. PROTECTION OF YOUR PERSONAL INFORMATION AND GENERAL INFORMATION
In order to protect both the personal information and the general information that we receive from you through our website, we have implemented various security measures, such as using SSL encryption on pages where personal information is transmitted to us, encrypting stored data, and enforcing internal access controls.
Please keep in mind, however, that whenever you give out personal information online, there is a risk that third parties may intercept and use that information. While we strive to protect your personal information and privacy, we cannot guarantee the security of any personal information you disclose to us.
8. CHILDREN’S PRIVACY – NO USE OF THIS SITE BY PERSONS UNDER 18 PERMITTED
We are not a general audience site, and do not direct any of our content specifically to anyone under 18 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 18, we will promptly delete any personal information in that user’s account.
9. LINKS TO THIRD PARTIES
10. YOUR CHOICES
If you have created an account, you can update your profile information by logging in and editing your profile. If you need to change the name or social security number associated with your account, please login and submit an E-Form request for “Associate Information Change”.
Email Subscriptions. You can always unsubscribe from promotional emails via the link provided in the emails. Even if you opt out from receiving promotional messages from us, you will continue to receive administrative messages from us.
If you would like to delete your registered account, please log in and submit a “Contracting Request” marked “other” through our E-form system with the text “Terminate My SYNCIS Connect Account” in the notes. Alternatively, you may email firstname.lastname@example.org with the subject line of: “Terminate My SYNCIS Connect Account”.
11. CONSENT TO TRANSFER
12. CALIFORNIA RESIDENTS ONLY: CALIFORNIA PRIVACY RIGHTS
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Your Right to Know and Receive Copies of Your Personal Information
You have the right to know certain information about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer 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 share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Your Right to Request We Delete Your Personal Information
You have the right to request that we delete any of your personal information that we collected from you and retained unless retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (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 if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, California residents may submit a verifiable consumer request to us by either:
Logging into your SYNCIS Connect account and submitting a “CCPA Request” through our E-Form system or calling us at our toll free number: 1-888-777-6057
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Pursuant to the CCPA we will attempt to respond to a verifiable consumer request within forty five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to the email address on file with account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Pursuant to the CCPA any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will not discriminate against you, deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA rights.
13. NEVADA RESIDENTS: NEVADA PRIVACY RIGHTS
Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell your personal information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law.
14. QUESTIONS OR COMMENTS