LAST UPDATED: September 1, 2023
- Software applications made available by us for use on or through computers and mobile devices, such as SevenFifty and Provi (the “Apps”);
- Our social media pages and apps, including our Facebook, LinkedIn, LinkTree, Instagram, and Twitter pages (collectively, our “Social Media Pages”);
- Offline business interactions you have with us.
Collectively, we refer to the Websites, Apps, Social Media Pages, emails, and offline business interactions as the “Services.”
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:
- Postal address (including billing and shipping addresses)
- Telephone number
- Email address, including business email address
- IP address (we may also derive your approximate location from your IP address)
- Date of birth
- Payment card data
- Account information, including login credentials such as username and password
- Other similar identifiers
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services.
- We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, request a demo, attend one of our events, place an order, contact customer service, submit a support ticket, or refer an account.
- From Other Sources.
- We receive your Personal Information from other sources, for example:
- publicly available databases;
- ad networks;
- business partners, including distributors and suppliers; and
- joint marketing partners, when they share the information with us.
If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.
Use of Personal Information
We and our service providers use Personal Information for the following purposes:
- Providing the functionality of the Services and fulfilling your requests.
- To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related benefits, special promotions, or customer service.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for, or other information about, our Services.
- To complete your transactions, administer orders, process inquiries, verify your information, and provide you with related benefits, special promotions, or customer service.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
- To allow you to send messages to another person through the Services if you choose to do so.
- Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
- To send you marketing related emails with information about our services, new products, and other news about our company or affiliates.
- To facilitate social sharing functionality that you choose to use.
- Analyzing Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
- Allowing you to participate in sweepstakes, contests, or other promotions.
- We may offer you the opportunity to participate in a sweepstakes, contest, or other promotion.
- Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
- Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
- For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
Disclosure of Personal Information
We disclose Personal Information:
- To our third-party service providers, to facilitate services they provide to us.
- These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, return authorization, fraud prevention, information technology, and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.
- To business partners to provide and maintain services and other business purposes.
- These can include retail, distributor, and supplier partners who provide services and other related business activities related to your use of the Services.
- To business partners and third parties, to permit them to send you marketing communications, consistent with your choices.
- To third-party sponsors of sweepstakes, contests, and similar promotions.
- By using the Services, you may elect to disclose Personal Information.
- On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate:
- To comply with applicable law and regulations.
- This may include laws outside your country of residence.
- To cooperate with public and government authorities.
- To respond to a request or to provide information we believe is necessary or appropriate.
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders or provide information we believe is important.
- For other legal reasons.
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
- We may disclose or transfer your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
- Browser and device information
- Usage data
- Information collected through cookies, pixel tags, and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated or deidentified in a manner such that it no longer reveals your specific identity
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Your browser or device.
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Your use of the App.
- When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Pixel tags and other similar technologies.
- Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- Physical Location.
- We may collect the physical location of your device by, for example, using satellite, cell phone tower, or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information if it is combined.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
Subject to applicable data protection and privacy laws, we give you choices regarding our use and disclosure of your Personal Information for marketing purposes. Based upon the laws applicable to you, you may opt-out from:
- Receiving marketing-related emails and/or text messages from us. You can unsubscribe from our marketing or promotional emails and text messages by using the unsubscribe mechanism in the communication. We will still send you transactional, information, and relationship communications about the use of our Services, platforms and/or the relationship between you and us.
- Our sharing of your Personal Information with affiliates for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by clicking here. When you unsubscribe from the list you unsubscribe from us sharing it.
- Our sharing of your Personal Information with third parties for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with third parties for their direct marketing purposes, you may opt out of this sharing by clicking here. When you unsubscribe from the list you unsubscribe from us sharing it.
- Location Access. To the extent permitted by law, you may be able to restrict, limit or prohibit our access to your location through device settings. Please note if you restrict, limit or prohibit our tracking of your location, this may impact your ability to use our Services.
- We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
Attn: Privacy Support
1 N. Dearborn Street, Suite
Chicago, IL 60602
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us. For exercising applicable privacy rights, including opt-outs, please provide (i) your first and last name, email address, and address of residency; (ii) identify the right(s) being exercised; and (iii) the subject line include “Privacy Request.”
If you do not have access to email or based on your personal preference, you may contact us by calling 1-872-356-2329.
We retain Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Services or otherwise to us.
THIRD-PARTY PAYMENT SERVICE
ADDITIONAL INFORMATION REGARDING CALIFORNIA
Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, (collectively, the “CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents. As amended by the California Privacy Rights Act (collectively, the “CCPA”).
Collection, Use, Sale, Sharing, or Other Disclosure of Personal Information
Categories of Personal Information
Disclosed to Which Categories of Third Parties for a Business Purpose
Behavioral Advertising or Sold to Which Categories of
Identifiers, including name, email addresses, IP address
Affiliates, service providers; third-party partners; government entities
Affiliates, third-party partners, including marketing and advertising partners
Protected classification characteristics as defined in the California customer records law, including age, financial account number
Affiliates; service providers; third-party partners; government entities
Commercial Information, such as transaction information and purchase history, including purchases considered
Affiliates; service providers; business partners; third-party partners including joint marketing and advertising partners;
Third-party partners, including marketing and advertising partners
Internet or network activity information, such as browsing history, search history and interactions with our online properties or ads
Affiliates; service providers; business partners
Geolocation Data, such as device location and approximate location derived from IP address or GPS, Wi-Fi or BLE tracking
Affiliates; service providers; business partners
Inferences drawn from any of the Personal Information listed above to create a profile about individuals reflecting their preferences and/or behavior
Affiliates; service providers; business partners
Sensitive Personal Information, including
Affiliates; service providers; business partners
We do not knowingly “sell” the Personal Information of minors under 16 years of age.
Sources of Personal Information
As described above, we collect this Personal Information from you and from ad networks, business partners, including distributors and suppliers, and joint marketing partners, when they share the information with us.
Use of Personal Information
We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
CCPA Rights and Requests
If you are a California resident, you may make the following requests:
- You may request to know whether we process your Personal Information, and to access such Personal Information.
- You may request that we disclose to you the following information covering the 12 months preceding your request:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The business or commercial purpose for collecting, sharing or selling (if applicable) Personal Information about you;
- The categories of Personal Information about you that we sold or shared and the categories of third parties to whom we sold or shared such Personal Information (if applicable); and
- The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).
- You may request to correct inaccuracies in your Personal Information;
- You may request to have the Personal Information you provided to us deleted.
- You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, request to obtain a copy of your Personal Information in a portable, readily usable format.
- You may request to opt out of the “sharing” of your Personal Information for cross-context behavioral advertising (as defined by California law); and
- You may request to opt out of the “sale” of your Personal Information.
We will not unlawfully discriminate against you exercising your rights. To make a privacy request, please contact us at email@example.com or 1-872-356-2329. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. In some instances, we may decline to honor your request where the law or right you are invoking does not apply or where an exception applies. We may need to request additional Personal Information from you, such as name, email address, physical address, account number, etc. in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.
To request to opt out of any future sale of your Personal Information, or to opt out of any future sharing of your Personal Information for purposes of cross-context behavioral advertising, click here
If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “CCPA Rights and Requests.” Not all kinds of requests can be made by authorized agents in all states. As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.
Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.