1. CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION
We have implemented commercially reasonable security measures and follow generally accepted industry standards to protect personally identifiable information sent to our Website or Portal or provided to our Services, both during transmission and afterwards. It is your responsibility to ensure that you do not disclose your password to anyone.
We also use a credit card processor that follows the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data. We do not handle credit card data directly.
Despite our efforts to maintain the confidentiality and security of your account, no method of transmission over the Internet and no method of electronic storage is completely secure.
Although we make every effort to protect your personal information, we cannot guarantee its absolute security.
2. PERSONAL INFORMATION WE WILL COLLECT
We collect the following personal information through our Website, Portal, and Services:
When you register and create and account with us, we will collect your first name and last name, country, phone number, and email address. We will also ask that you create a password for your account, and provide credit card information to our payment processor.
In addition, we may collect the IP address of your computer for analytics purposes and in order to identify the source of the web traffic, but the IP addresses we collect will not be identifiable to you or other clients.
If you choose not to provide above-listed information, we may not be able to provide you with the requested Services.
If you provide personal information in notes that you submit through our Portal, we will collect the personal information you submit as notes too.
Except for the above-listed items, we do not collect personal information about you.
Furthermore, we do not collect sensitive personal information about you, whether directly from you or any website pages you submit to us, or from third parties.
3. HOW WE COLLECT THE INFORMATION
We collect personal information through standard web-based forms which we make available to you through our Portal, in which you are specifically asked to provide the personal information, and through Google Analytics. Thus, with exception of information collected through Google Analytics, any personal information we collect is provided by you with your express consent and at your direction.
4. HOW YOUR INFORMATION IS USED
Our policy is to collect personal information from you for the following purposes:
(a) to provide Services to you;
(b) to generate analytics for the improvement of the Website and Services and for marketing purposes;
(c) to maintain a commercial relationship with you and to communicate with you as we provide and complete the Services;
(d) to meet legal and regulatory requirements; and
(e) as otherwise required by law.
5. YOUR CHOICES
You should direct all questions about how we collect and use your personal information to our customer service at [insert email address].
(a) As described above, you can choose not to provide personal information, but then you may not be able to take advantage of many of our Services.
(b) You can add and update the personal information we have collected. Please direct all such addition or update requests to [insert email address].
(c) You have the right to request access to or the deletion of your personal information. Please see “How to Submit a Verifiable Request” for further instructions on how to make your request.
6. SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES
We do not share personal information with third parties, except to provide Services, which you request, when we have your permission, or under the following circumstances:
(a) We use a third party for credit card processing;
(b) We may share your aggregate anonymous information with third parties in order to improve the quality or design of the Website, Portal, or Services; to create new features and functionality; and to maintain and upgrade the Website, Portal or Services.
(c) We use a third-party host to provide cloud-based client access to our Website and Portal;
(d) We use a cloud-based third-party workspace provider to host our email and office services;
(e) We use a multi-cloud database service to manage our databases;
(f) We may share your personal information if required by law and if we believe that the disclosure is required or necessary to protect our rights and/or comply with a judicial processing or legal process served on our Website, Portal, or Services;
(g) We may share your information with third party contractors such as developers to maintain the Services.
(h) We may transfer personal information to a third-party entity in the event of an assignment of the Website, Portal or Services for any reason.
(i) We may share personal information with our legal, financial, and other
(j) We may share personal information with third parties upon receiving your consent as required by law.
Except as provided above, we will not share any of your information to any third party without permission.
We do not sell your information to third parties for money.
7. SHARING PERSONAL INFORMATION WITH LAW ENFORCEMENT
Please be advised that we are required to share personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
8. RETENTION PERIOD
We will retain your personal information for as long as we are providing Services to you and up to ninety (90) days thereafter, unless we are otherwise required to retain your personal information for longer, in which case we will retain your personal information for only as long as we are required by applicable law. We may retain personal information in de-identified form thereafter solely for our business purposes.
9. WEB-BASED TRACKING TECHNOLOGIES WE WILL USE
We do not use web-based tracking technologies in our business. If we decide to employ web-based tracking technologies in the future, we will notify you of the change and provide information about the technologies we are using, how we use those technologies, how the technologies may affect you, and what you can do to modify or control them.
We are committed to protecting the privacy of children. In furtherance of this commitment, we restrict the use of our Website and Services to persons eighteen (18) years of age or older. We do not knowingly or intentionally collect personal information from children under the age of thirteen (13). We do not sell the information of minors under the age of eighteen (18).
11. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION
You have the following rights with respect to your personal information:
(a) Right to request that we disclose personal information or categories of personal information that we collect, use disclose, and sell;
(b) Right to request that we delete personal information we have collected from you;
(c) Right to request we opt you out of the sale of your personal information; and
(d) Right to non-discrimination.
We will not discriminate against you because you exercise your rights.
12. PROCESS USED TO VERIFY AN ACCESS OR DELETION REQUEST
If you make an access or a deletion request, you will be required to submit three pieces of information including but not limited to your name, address, and home number. We will use this information to search our systems and determine if we have information about you. If we are able to locate information about you, we will fulfill your request. If we are not able to match all three pieces of information you submit, we may provide you with a report that includes the categories of information we collect, use, disclose and sell.
If you are an authorized agent, you will be required to submit your name, address, and phone number, as well as the name, address, and phone number of the person on whose behalf you are making a request. If we are able to locate the information about the person on whose behalf you are making the request, we will fulfill your request. As an authorized agent, you will also be required to complete a form certifying you have the right to make this request on behalf of the third party.
13. HOW TO SUBMIT A VERIFIABLE REQUEST
You can make or submit a request using the methods listed below:
- Access Requests: Contact ADA Buzz at [insert 1.800 number] or click this link
- Deletion Requests: Contact ADA Buzz at [insert 1.800 number] or click this link
- Do Not Sell My Information Requests: Click this link
14. CALIFORNIA SHINE THE LIGHT
If you are a California resident and have a relationship with us, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties for their own direct marketing uses. California law provides that you have the right to submit a request to us at our email address in order to receive information on the categories of customer information that we shared and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To obtain this information, please submit your request to ADA Buzz, Attn: California Shine the Light Inquiry, [insert address]. Please allow 30 days for a response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
15. CALIFORNIA MINOR REQUEST
If you are a California resident under 18 years old, you can request that we remove content or information that you have posted to our Website. Note that fulfilment of the request may not ensure complete or comprehensive removal. To request remove of content or information, please contact us at [insert 1800 number].
16. NEVADA RESIDENTS
Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties. The right applies even if their personal information is not currently being sold. If you are a Nevada consumer and wish to exercise this right, please submit your request at this link: [insert link].
17. EUROPEAN UNION RESIDENTS
If you are a resident of the European Union, you have additional rights with respect to your personal information:
(a) Right to transfer any personal information we have collected by requesting a copy in a commonly used format that can then be imported by a third party;
(b) Right to correct any personal information that we have collected that is inaccurate or incorrect;
(c) Right to object to our continued storage, use or sharing of your personal information; and
(d) Right to withdraw consent to our communications with you.
To make a request based on any of the above rights, please submit your request to this email address: [insert email address].
18. ALTERNATIVE FORMAT REQUESTS
20. DATA TRANSFER, STORAGE & PROCESSING
If you are accessing our Website or Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that your personal information will be transferred to, stored, and processed in the United States. We take steps to ensure that the vendors that we work with utilize industry best practices for maintaining data privacy and security. Our current list of vendors and the specific personal information we share with them is linked here.
If we are transferring personal information out of the European Union, please be advised that we will take such measures as are necessary to ensure that the transfer is in compliance with the EU General Data Protection Regulation (Regulation 2016/679 also known as the “GDPR”), including but not limited to transferring the personal data to a recipient in the United States that has executed standard contractual clauses adopted or approved by the European Commission.
We acknowledge and agree that we are liable for all onward data transfers.
21. CONTACT US
If you are unhappy with how we are handling your personal information and wish to make a complaint you should submit your complaint via mail to ADA Buzz at [insert address] or by email to [insert email address]. We will notify you that we have received your complaint and will resolve your issue within a reasonable amount of time.
In the event you are unable to obtain satisfactory resolution of your complaint following submission to ADA Buzz, you should submit your dispute to [insert dispute organization].
23. EFFECTIVE DATE