Privacy Notice

(Last updated: June 1, 2023)

Introduction

Privacy is our business. This Privacy Notice (“notice”) applies to the personal information that Privacy Partners Inc. (“we,” “us,” or “our”) collects about you when you use our website and describes the rights and obligations applicable to us, and to you as a user of our website. If you use this website, you are agreeing to both the Terms + Conditions and this Privacy Notice, so make sure you are familiar with both. This policy applies to Privacy Partners Inc., its subsidiaries and affiliates.

This Privacy Policy applies to the personal information we collect related to our:

· websites located at privacyclue.com and any other website that displays this policy (together, our "website(s)");

· events, marketing and business development activities;

· business communications engaged in during the sales and contracting process, and other online and offline business interactions.

This Notice does not apply to the personal information that we collect about employees and other personnel, contractors, or applicants and candidates. A separate Notice is provided in those situations.

This Notice does not address information provided to us by our clients; please refer to our engagement Agreement (or other contract) for details regarding data used in the context of that relationship.

California Consumer Privacy Act

If you are a California resident, please review the additional privacy information for California residents, included below, for important information about how we collect, use and disclose personal information about California residents and your rights under the California Consumer Privacy Act.

EU and UK GDPR

This website is directed primarily towards US-based businesses. While we are pleased to interact with individuals located in the EU or UK, we do not have a separate policy or different practices with regard to our interactions with residents of the EU or UK. If you wish to exercise rights granted to you under the EU or UK GDPR or other laws and regulations, we will honor those to the extent required with regard to the location and nature of our processing operations.

Scope of this Privacy Notice

This Privacy Notice ("Notice," also commonly referred to as a “Privacy Policy”) explains how Privacy Partners LLC and its affiliated companies, process the Personal Information of website visitors, users of our apps, users of our gift card and branded payments services.

You should read and understand this Notice because it constitutes the core of our obligations to you when you use this website, when you provide your Personal Information to us either directly or through automated processes. For your convenience we have summarized several of the most important points, which are:

We may collect and process your personal information in conjunction with your usage of this website, in the course of providing services to you, or in contemplation of entering a business relationship with you.
We may also use your personal information for our own legitimate and lawful business interests, including (but not limited to): improving our websites and services, communicating information about our services through direct advertising (such as email) and indirect advertising (such as ads appearing on other websites), conducting fraud detection and prevention activities, maintaining records and communicating notices that are required by law.
We do not sell your information.
We may share your information with the service providers needed to deliver our services to you, but those service providers are bound by law and contract to only use your information for the purposes we specify.
We may receive your information when we function as a service provider for other companies; we are bound by law and contract to only use your information for the purposes they have specified.
This Notice applies to websites and mobile applications operated by us.
Data protection laws in your jurisdiction may provide you with rights to access or delete your personal information and this policy provides you with instructions on how we do this. For example, if you are a resident of the European Union or the State of California in the United States, laws in those jurisdictions grant you specific rights that are discussed below in the section called “Your Rights.”

You are strongly encouraged to read this Privacy Notice in its entirety, not just the above highlights, so that you will fully understand our commitment to responsible data governance and the protection of your personal information. Please also note that this Notice may have changed since the last time you read it, so you should make sure that you have familiarized yourself with any terms that may have changed since the last time you read it.

Who

This Privacy Notice (“Notice”) applies to the activities of Privacy Partners Inc., and its affiliates (“we,” “us,” or “our”). It applies to our usage of your personal data, whether you are an individual or you are interacting with us as part of your job.

What

This Notice describes how we collect and process your personal information (which includes “personal data” or “personal information” as defined under applicable data protection laws) and the rights you have regarding such data.

Where

This Notice applies to our collection and processing of personal data about users of our website. It also applies to those channels through which individuals communicate with us about our services, whether in person, by telephone, by postal mail, e-mail, or other means.

When

When you provide data directly to us, we function as a Controller of your data. This means we define the purposes for which your personal information is processed, and we control the means by which your information is processed. When we act as a Data Controller, we bear the primary responsibility to you, the Data Subject, for protecting your information and honoring your rights.

It is very unlikely given the nature of our business, however, should there ever be a circumstance in which we process data on behalf of another Data Controller, we would be considered a Data Processor. In such a circumstance, we would collect, use, and disclose certain personal information only under the Controller’s instruction, and our processing of your personal information is subject to their instructions and privacy policies. As noted, we do not typically function as a Data Processor and if any of our activities could be construed as such, we will advise you at the time of data collection.

Please note: Links to third-party websites are provided solely for your convenience; when you go to those sites, your experience there is subject to the privacy notices and terms of use of those third-party sites, not ours, unless you are explicitly told otherwise.

Personal Information We Collect

We collect personal information directly from you, through third parties, or automatically through our Sites and related to our Services, subject to applicable laws as set out below. Where the personal information we collect is needed to comply with law, or to enter into or perform an agreement with you, we will inform you at the time of such data collection. If we cannot collect this data, we may be unable to register you as a client, to complete certain transactions, or provide products or services to you.

Personal Information We Collect Directly from You

We may collect any or all of the following information directly from you when you are interacting with our website or otherwise contacting us:

Contact information, such as name, email address, mailing address, or phone number;
Payment and financial information, such as credit or other payment card information, bank account, or billing address;
Shipping address and related details;
Your resume, employment and education history, name and contact details, background details, and references when you apply to job postings or contact us about employment opportunities;
Company and employment information when you contact us on behalf of your employer or when your employer uses one of our services;
Unique identifiers such as username, account number, or password;
Preference information such as website user interface settings or marketing preferences;
Information about your business such as company name, size, or business type; and
Demographic information, such as when you provide your age, gender, interests and ZIP or postal code.

Comments, Posts, Chats, and Submissions

When you submit comments, join online discussions, or contact us for any reason (including to inquire about services), we will collect your personal information, such as contact information, and other information you choose to share. Any information you provide in these areas may be read, collected, and used by others who access them.

Location

We may use the website to record geolocation-based information for general usage analytics or fraud prevention purposes. You may withdraw your consent to the processing of location-based information at any time by changing the settings on your device. If you do, you might not be able to use certain features, especially when we use location-based information to prevent fraud.

Personal Information We Collect from Third Parties

Sometimes, we may collect personal information from third-party sources. For example, if you fill out any forms on our website, many of those are powered by third party services and they may use that information to validate the authenticity of your communications to prevent abuse, spam, or other inappropriate behavior. If personal information about you has been provided to us and you want us to delete it, you may contact us using the process described in the Contact Us section below.

Personal Information We Collect Automatically

This website is operated on a third-party hosting service, Squarespace.com, which provides various technical means to automatically gather information about your use of the website. These measure include cookies, web beacons, java script, log files, pixels, and other technologies, and they capture information which may include: your domain name, browser type, browser language preference, device type and operating system, page views and links you click within the Sites, IP address, device ID or other identifier, location information, date and time stamp, and time spent using the Services, referring URL, your activity within the Sites, and device geolocation information (where permitted by your device settings). We may also use analytic services, including Google Analytics, to compile and analyze information derived from the use of our Services, such as aggregate usage patterns, user preferences, peak demand times, preferred content and other information. See the “Cookies and Online Tracking” section below for details.

Uses and Legal Bases for Processing Your Personal Information

We may use the personal information we collect for the following purposes:

Provide Our Services: To provide our Services, operate our website, respond to your enquiries and fulfill your requests and orders, process your payments, for bug and error reporting and resolution, to perform upgrades and maintenance;
Customer Service and Support: To send you important information, such as changes to terms, conditions, and policies and/or other administrative information;
Personalization: To personalize your experience on the website, such as by tailoring the content we send or display to you in order to personalize help and instructions, and to otherwise personalize your experience using the Services;
Alerts and Required Notices: To send you messages that you have requested such as service-related alerts and any notices required by contract or applicable law;
Marketing and Promotions: To send you marketing communications you have signed up for;
Advertising and Referrals: To assist in advertising the Services on third-party websites and to track referrals from partner websites;
Analytics and Improvement: To better understand how our users access and use the Services, and for other research and analytical purposes, such as to evaluate and improve the Services;
Verify Identity and Detect Fraud: To verify your identity and/or location in order to allow access to your accounts, conduct online transactions, and secure your personal information, and for risk control, fraud detection and prevention, and compliance with laws and regulations;
Protect Our Legal Rights and Prevent Misuse: To protect the Services, prevent unauthorized access and other misuse, and where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Privacy Notice.
Comply with Legal Obligations: To comply with the law or legal proceedings such as when required to disclose information in response to lawful requests by public authorities, including responding to national security or law enforcement disclosure requirements; and
General Business Operations: Where necessary to the administration of our general business, accounting, recordkeeping and legal functions.

Aggregated and Anonymized Information

We may also generate aggregated, pseudonymized, and/or anonymized information about users for marketing, advertising, research or similar purposes.

Purpose of Processing

Below we explain the purposes for which we use and process your personal information, as well as the legal bases for such use and processing (such as those permitted under the European Union’s General Data Protection Regulation (“GDPR”) and other applicable laws).

To Provide Our Services

Necessary to enter into or perform a contract with you (upon your request, or as necessary to make the Services available)
Our legitimate business interests*

Marketing and Advertising

Our legitimate business interests*
With your consent

Analytics and Improvement

Our legitimate business interests*

Verify Identity and Detect Fraud

Protect Our Legal Rights and Prevent Misuse

Comply with Specific Legal Obligations

Compliance with applicable laws and regulations
Establish, defend or protect our legal interests
Our legitimate business interests*

General Business Operations

Our legitimate business interests*
Establish, defend or protect our legal interests
Compliance with law

* For personal information from the EU, the processing is in our legitimate interests to the extent they are not overridden by your interests and fundamental rights. Our legitimate interests include our interests in verifying identify, detecting and preventing fraud, protecting and improving our products and services, in support of our general business operations, and to comply with our legal obligations. We only send marketing communications to consumers who provide opt-in consent or who are covered by "soft opt-in" exemptions (where allowed by law).

How We Disclose Personal Information We Collect

In this section, we describe the types of disclosures we make and the categories of third parties to whom we may disclose your personal information. All third parties to whom your personal information is disclosed are subject to contractual agreements that govern how your information can be used and must be protected.

Sale of Data

We do not sell your personal information to third parties. Because we do not sell your personal information, we do not provide any further detail regarding such sales, nor do we provide a process for opting out of such sales.

Service Providers

We disclose your personal information to certain companies that provide services to us and on our behalf and subject to our written instructions, such as shipping, payment, hosting, and other support services; these companies may be located in the EU, the United States, and other jurisdictions. As noted above, we may also disclose your information to service providers who assist us in the detection or investigation of fraudulent or illegal activities, for verification of identity, and for compliance activities, such as required transaction-related reporting or to verify your address in order to accurately calculate or process tax-related matters.

Additional Disclosures

We may also disclose your personal information under the following circumstances:

As permitted or required by law, such as to comply with a subpoena or court-issued discovery order, a warrant, a government request, or similar legal process;
When we believe in good faith that disclosure is necessary to respond to claims asserted against us; to protect our rights; to protect your safety or the safety of others; or, to investigate or prevent fraud.
If we are involved in a merger, acquisition, or sale of all or a portion of its assets, or in the event of a bankruptcy or dissolution of our business, your personal information may be transferred to an acquiring business or third party, including in contemplation of or related to due diligence for such business transactions, subject to any applicable restrictions under applicable laws. You will be notified by email and/or by a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
We may disclose your data to any other third party with your prior consent.

Aggregate and Anonymized Information

We may share aggregate and anonymized information about users with certain third parties, including for marketing, advertising, research or similar purposes.

Cookies and Online Tracking

We and our third-party service providers collect information automatically through cookies, beacons, pixels, tags, scripts, and HTML5, as well as log files. We, or our service providers, may combine this information with other information, including personal information we collect about you, to record your preferences, gather information about the use of our Services, identify when our emails are viewed, personalize content and ads and track information about the performance of our advertisements.

Cookies

These are small files with a unique identifier that are transferred to your browser through our websites. These technologies allow us to collect information such as browser type, time spent on our Sites, pages visited, language preferences, and your relationship with us. We can use this information to analyze trends, administer the website, track users’ movements around the website, measure the effectiveness of our communications, tailor our advertising to you, and gather demographic information about our user base as a whole. These technologies may provide us with information about devices and networks you utilize to access our Services, and other information regarding your interactions with our Services. If you do not wish for cookies to be set on your device, please refer to the instructions for your browser to control cookies. Please be advised that disabling cookies may make certain parts of our website non-functional or may not function as originally intended.

"Do Not Track" Preferences

Our Site does not recognize do-not-track signals; however, we do not use your personal information to track your online activities across different Sites. We only track your activity within a Site to the extent you log into your account. Therefore, our practices remain the same whether or not you enable the "Do Not Track" feature. In addition, some of our advertising partners, may use standard technologies, such as cookies, pixel tags, and web beacons, to collect information about your Internet activities across websites. We do not share your personal information with those services; any information we provide is in an anonymized or de-identified format.

Third-Party Analytics

We also use automated devices and applications, such as Google Analytics (more info here) to evaluate use of our Services. We use these tools to gather non-personal information about users to help us improve our Services and user experiences. These analytics providers may use cookies and other technologies to perform their services on our behalf.

Marketing and Newsletters

If you subscribe to our newsletters, we will use your name and email address to send them to you. You may choose to stop receiving our newsletter or marketing emails at any time by following the unsubscribe instructions included in these emails or accessing the email preferences in your account.

Opting Out of Ad Networks

We do not use Advertising Networks or engage in Online Behavioral Advertising. Should we do so in the future you may wish to opt out. If you wish to not have this cross-site information used for the purpose of serving you targeted ads, you may opt-out of many ad networks by visiting the DAA WebChoices Tool (or if located in the European Union, by visit Your Online Choices). You will continue to receive ads on the sites you visit, but the ad networks from which you have opted out will no longer target ads to you based upon your activities on other sites. Please note, however, that these opt-out mechanisms are cookie based, so if you delete cookies, block cookies or use another device, your opt-out will no longer be effective. For more information about Interest Based Advertising, please visit Your Ad Choices.

Social Media Widgets

Our website may include social media features either hosted by a third-party or hosted directly on our website (“Widgets”). Please refer to the privacy policies of the relevant third-party websites or services to find out more about the collection, use, and disclosure of your information through such features. We will comply with any legal obligations placed on the use of these technologies by certain jurisdictions, which may affect how these Widgets function.

Security

The security of your personal information is important to us. We have implemented safeguards designed to protect the personal information submitted to us. Please note that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any personal information that we process.

Data Retention

It is our policy to retain your information only for as long as is necessary to fulfill the purpose for which it was collected and processed. We will retain your information for as long as your account is active or as needed to provide you services and for as long as may be required to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. Even if you request for your information to be deleted, laws and regulations may require us to retain a copy of your information in our files for a longer period of time. Unless a specific applicable law requires a different retention period, most data will be retained for no longer than seven (7) years.

Your Rights

For EU Residents

The European Union’s General Data Protection Regulation (“GDPR”) gives you certain rights, including: a right to be notified of our data collection practices; the purposes and lawful bases under which we process your data; if our legitimate interests are a basis for processing, what those interests are; the categories of data processed; the categories of third parties with whom data is shared; the details of any data transfers outside of the EU and the safeguards in place; the applicable retention periods or policies; the right to access, correct, and delete (under certain circumstances) your personal information; the right to receive a copy of your information in a “portable” form so that you may transfer it to other services; the right to withdraw consent for processing; the right to lodge a complaint with a data protection authority; the right to be advised of the existence of any automated decision-making, including profiling, and the right to object such decisions; and, the right to withdraw consent without detriment. This Notice provides details on how we honor those rights and the process for exercising them.

For California Consumers

California law gives you certain rights, including: a right to be notified of (and to request more information about) our data collection practices; the categories of data we process; the categories of third parties with whom data is shared; the right to request disclosure (up to twice per year) of the personal information we have about you or have had within the last 12 months: the right to delete that information (under certain circumstances); the right to know if your data is being sold; the right to know what personal information is being sold and to opt-out of such sales (if applicable); the right to receive a copy of your information in a “portable” form so that you may transfer it to other services; and, the right to not be discriminated against for exercising these rights. This Notice provides details on how we honor those rights and the process for exercising them.

California Reporting

In 2020 we received zero (0) verified requests for access or deletion under applicable California data privacy laws. Because we do not sell data, we have no procedures or activities related thereto about which any reporting is required. Because there were no requests received, the median time to respond is not available.

In 2021 we received zero (0) verified requests for access or deletion under applicable California data privacy laws. Because we do not sell data, we have no procedures or activities related thereto about which any reporting is required. Because there were no requests received, the median time to respond is not available.

For All Customers

Regardless of your location and jurisdiction, we may at our sole discretion choose to extend the rights described in the Privacy Notice to all individuals, and to comply with reasonable requests in the manner detailed below. We do not charge for these services. Where you are entitled to exercise a right, we will respond to your request within the timeframe set out by applicable law (for EU residents this is typically thirty (30) days, for California residents this is typically forty-five (45) days). Where we provide answers on a voluntary basis, we will provide a response within a reasonable timeframe.

Access, Correction, Portability, and Deletion

You have the right to access, correct (“rectify”), or delete (“erase”) your personal information held by us (“be forgotten”), or may ask for a restriction of processing. You may also have the right to ask for an overview or copy of your personal information or to request that certain of your personal information be exported in a format so that you may take your data to another provider where technically feasible (“data portability”).

On some of our Sites, you may exercise your rights to access, correct, or delete your personal information by making the change directly on your account page. You may also make these requests by using the process described in the Contact Us section below.

Please note that there are some limitations to these rights. For example, we will not be able to delete your personal information if we are required by law to keep it or if we hold it in connection with a contract with you. Similarly, access to your personal information may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information. If we cannot fulfill your request, we will inform you about why we cannot comply with your request.

Withdrawal of Consent

Where we process your personal information based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing that occurred based on your consent before its withdrawal. Please keep in mind that certain services are directly dependent upon our ability to process your personal information, so if you withdraw your consent, request for your information to be deleted, or if you otherwise object to our processing of certain personal information, those services may no longer be functional.

Object to Processing

You have the right to object to processing (including profiling) that occurs based on legitimate interest grounds, where we are relying upon legitimate interests as the primary basis for processing your personal information. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal information for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

Object to Marketing

You have the right to object to our use of your personal information (including profiling) for direct marketing purposes, such as when we use your personal information to invite you to our promotional events.

Right to Lodge a Complaint

If you believe that our processing of your personal information infringes your rights or violates applicable data protection laws, you have a right to lodge a complaint with the relevant supervisory authority. If you are located in the European Union, a list of supervisory authorities is available here. If you are in the United States, you may contact the US Federal Trade Commission (residents of California may contact the California Department of Justice). Residents of Canada may contact the Privacy Commissioner of Canada or their provincial data protection commissioner. If you are located in another jurisdiction, you will need to research or contact your local government for further guidance.

Exercising your Rights

To exercise your rights as described in this Notice, you may contact us via the process described in the Contact Us section below. We will respond to your request in accordance with applicable law, and if we are unable to comply with your request, we will provide information regarding why.

When Submitting a Privacy Request

Depending on the nature of your request, we may request further proof of your identity in accordance with applicable law. When sending a request, you can expedite this process by providing the following information with your initial inquiry:

Full name;
Email address associated with the relevant transaction(s) (if applicable);
Postal address associated with your account or transaction (if applicable); and,
Why you believe we have your personal information.

If the nature of your request in unclear we may ask you for further clarification. In the event that we require additional time to process your request (if allowed by applicable law), we will advise you of that. If you are unable to or refuse to provide satisfactory verification information, we may deny your request in accordance with applicable law. If you do not follow the procedures described in this Notice, including failure to lodge your request through the channels or processes specified, there may be significant delays in responding to your request for which we will not held liable.

Please note that we will only respond directly to you, or your duly authorized agent (with authority documented in strict accordance with applicable law), in cases where we are the Controller of your personal information.

Protecting Children’s Privacy Online

Our website is not directed to children, and we do not knowingly collect personal information from anyone under the age of eighteen (18). We request that such individuals do not provide personal information through our website. We reserve the right to delete the personal information and terminate the access of anyone violating this age policy.

International Transfers

The personal information we collect from you may be transferred to, stored at, or processed in other countries, including the United States or outside the European Economic Area, which may not provide equivalent levels of data protection to your home jurisdiction.

We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements. For transfers from the EU, United Kingdom (“UK”), or Switzerland, to the US, we relies on adequacy decisions by the EU Commission or putting in place standard contractual clauses as approved by the European Commission (the form for the standard contractual clauses can be found here: EU Commission Standard Contractual Clauses) or another applicable supervisory body.

Updates to this Notice

This Notice is subject to change, so if this is your first time reading it, please make sure it is not the last. If we make any changes to this Notice, we will post those changes on this page and revise the “Last Updated” date at the top. If we make any changes to the ways in which we process your information that could be reasonably be considered material or substantial, we will make additional efforts to notify you of those changes, either by email or via a prominent notice on this Site prior to the change becoming effective. Where required by law, we will obtain your consent or give you the opportunity to opt out of such changes. Any changes will become effective when we post the revised Notice.

Contact Us

If you have any questions or concerns regarding this Privacy Notice, the ways in which your personal information is being processed, or wish to exercise any of the rights described above, please reach out to us using the contact information below:

Privacy Partners Inc.
privacy@privacyclue.com

Other Queries or Complaints

If you have any further queries or complaints that we are not able to answer, you are recommended to contact the Data Privacy Supervisory Authority for the country in which you reside. A list of EU/EEA Data Protection Authorities can be found via the European Data Protection Board here. A list of data protection authorities in other countries/regions can be found here.