Revised: January 1, 2020
WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DID WE GET THAT INFORMATION?
When you visit our Web page, create an account with us, post materials on one of our chat rooms or bulletin board, or contact us for support or other offerings, we collect information that identifies you. This includes information such as your name, company name, email address, or payment information. We may also sometimes collect other information that does not identify you, such as information regarding browser name, operating system, internet service provider, mobile device type, and your mobile network information. In addition, when you access an offer by one of our advertisers, we collect online identifiers. We provide more detail in the list below.
- Contact Information: If you are a member or customer of our services, we will collect general contact information that you provide to us. This includes: your name, address, telephone number and, where applicable, your company name and job title. We may also collect social media contact information including your Instant Messenger, LinkedIn and Facebook profiles.
- Payment Information: When we provided a fee-based service for you, we will collect the following information that you provide to us: billing address, credit card information, and authorized signature.
- E-mail Addresses: We also collect the e-mail addresses of visitors
- who post messages to our bulletin board;
- who communicate with us via e-mail; and
- who make postings to our chat areas.
- Login Information: If you are a member or customer or our services, we will collect your user id (e-mail address) and password.
- Online Identifiers: When you access an offer by one of our advertisers, we obtain your Internet Protocol address, browser user agent, and sometimes your device id.
- Domain Names: For each visitor to our Web page, our Web server automatically recognizes only the consumer's domain name but not the e-mail address (where possible).
- Data Trackers, Including Cookies and Web Beacons: We collect information on
- what pages visitors access or visit;
- user-specific information on what pages consumers access or visit; and information volunteered by the consumer, such as survey information and/or site registrations.
THIRD PARTY INFORMATION COLLECTION/”DO NOT TRACK”
With respect to Ad Servers: To try and bring you offers that are of interest to you, we have relationships with other companies that we allow to place ads on our Site. As a result of your visit to our Site, ad server companies may collect information such as your domain type, your IP address and clickstream information. For further information, consult the privacy policies of the companies representing the ads or http://www.google.com/privacy_ads.html.
Third parties with whom we partner to provide certain features on the Site or to display advertising based upon your web browsing or application activity use Flash cookies and HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
“Do-Not-Track” is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to Do-Not-Track signals.
If you wish to limit the collection of information by us or third party partners to provide you with advertising based upon your website browsing activities and interests, you may click [http://preferences-mgr.truste.com] to opt out. To opt out of targeted advertising on your mobile device, iOS users can click here: https://support.apple.com/en-us/HT205223 to learn how to limit ad tracking and Android users can click here: https://support.google.com/ads/answer/2662922?hl=en to learn how to opt out of interest-based ads. Please note that opting out of interest-based/targeted advertising does not limit all advertising. You will continue to receive generic advertisements.
HOW WE USE THE INFORMATION WE COLLECT
We use contact information, including e-mail addresses, to communicate with you if you are a member and/or a customer of our services. This helps us to carry out your requested services and to notify you about updates to our Website. When you subscribe to our fee-based services, we use this contact information, as well as payment information, for billing purposes and to carry out your requested services.
More Information On Data Trackers:
- Authenticating and identifying you on our websites so we can provide you the services you requested
- Keeping track of information you have provided to us such as items that you add to your shopping cart or pages that you visit
- Storing your preferences
- Measuring your use of our Web pages so that we can improve them and tailor our websites to your interests
This allows us to customize Web page content, alert you to new areas that we think might interest you, provide better services, and ensure that you are not repeatedly sent the same banner ads, when you return to our Web pages.
Web beacons (sometimes called “tracking pixels”, “transparent GIFs”, “clear GIFs”, “pixel gifs”, or “pixel tags”) are tiny, invisible images that allow us to track activities on our Web pages and on e-mails we send. We receive tracking pixel data primarily through offer pages published by our advertisers. Tracking pixels help us figure out if certain features, notifications, and products or services are effective and if they can be improved.
We may use your information for any other purposes with your consent.
HOW LONG WILL YOU KEEP MY PERSONAL INFORMATION?
We will retain your personal information for as long as necessary to provide you with the product and services you have requested and as needed to comply with our legal obligations and enforce our agreements.
If you supply us with your e-mail address, you may receive periodic e-mails from us with information on new products and services or upcoming events. If you do not want to receive e-mails from us in the future, please let us know by sending us e-mail to: email@example.com. However, we may still contact you concerning administrative or transactional matters.
If you supply us with your postal address, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by calling us at the number provided below, writing to us at the below address, or e-mailing us at firstname.lastname@example.org.
Persons who supply us with their telephone numbers may receive telephone contact from us with information regarding new products and services or upcoming events. If you do not wish to receive such telephone calls, please let us know by calling us at the number provided below, writing to us at the below address, or e-mailing us at email@example.com.
HOW WE SHARE THE INFORMATION WE COLLECT
Clickbooth works with companies that help us run our business. From time to time, we need to share some of your personal information with these companies so that they can perform requested services. They can only access your personal information to carry out the tasks we have asked them to do. They are required to meet both legal and industry standards to ensure that your data is protected.
We may share your personal information with:
- Service Providers: Clickbooth may share information about our visitors, members, and/or customers with our contracted service providers so that these service providers can provide services on our behalf. These service providers are authorized to use your personal information only as necessary to provide the requested services to us. Without limiting the foregoing, Clickbooth may also share information about visitors, members, and/or customers with our service providers to ensure the quality of information provided. Without your permission, Clickbooth does not share, sell, rent, or trade any information with third parties for their promotional purposes.
- Affiliates: Clickbooth may share information with affiliate companies in order to work with them. For example, we may need to share personal information with other companies within our corporate family for customer support, marketing, technical operations and account management purposes.
- Business Partners: Sometimes Clickbooth partners with our affiliated companies and other companies to offer new products, services, or advertising opportunities to existing clients. We may share personal information collected in connection with your purchase or expression of interest with our partner(s). If you do not wish for your information to be shared in this manner, you may opt out of receiving such communications by contacting us at firstname.lastname@example.org.
- Third Parties: We discussed in the section of the Privacy Statement, What information do we collect about you and how did we get that information?, that we, or our advertisers, may collect information about your through cookies and web beacons. You can control this collection through your Web browser. We may also disclose your personal information to any third party with your prior consent.
- Billing: Clickbooth uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on our behalf.
- Compelled Disclosure: Sometimes, we are required to use or disclose information provided if required by law or if we reasonably believe that use or disclosure is necessary to protect the Clickbooth’s rights and/or to comply with a judicial proceeding, court order, or legal process.
Upon request we provide site visitors with access to information that we have collected and that we maintain about them. Clickbooth will offer EEA individuals whose personal information has been transferred to us the opportunity to choose whether the personal information it has received is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at email@example.com.
WHERE DO YOU STORE MY PERSONAL INFORMATION?
Your personal information and files are stored on Clickbooth’s servers and the servers of companies we hire to provide services to us. Your personal information may be transferred across national borders because we have servers located worldwide and the companies we hire to help us run our business are located in different countries.
HOW WE PROTECT YOUR INFORMATION
We understand that the security of your personal information is important. We have reasonable and appropriate administrative, technical, and physical security measures in place to protect against the loss, misuse or alteration of information that we have collected from you at our site.
Sensitive and private data exchange between the Site and its users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. In the context of a transfer of credit card information (such as for processing), that information is encrypted. Also, we store only a truncated portion of credit card information.
You should note that the security of your personal information also depends on you. Please do not communicate any information to us through unsecured channels, such as when you are in public areas. Where we have provided you or you have chosen a password, access code, or similar security feature, you must keep the password, access code or security feature confidential. Please do not share your password with anyone. If you believe your password or account has been compromised, please contact us immediately at firstname.lastname@example.org.
Please note that the transmission of information via the Internet or other means of communication is not completely secure. Although we take reasonable measure to secure your information, we cannot guarantee the security of your information transmitted to our Site or through other means of communication. Any transmission of information is at your own risk. We are not responsible for the circumvention of any privacy setting or security measures contained on any of our systems, including but not limited to our Site.
ACCESSING AND CORRECTING YOUR INFORMATION
Under the law of some countries, you may have the right to access the information that you provide us and that we collect. You may also have the right to correct mistakes to that information, and to delete personal information that we no longer have business reasons for retaining. To review, correct, delete or otherwise modify this information, or to remove your email address from our marketing database, please email your request to email@example.com or otherwise review the “Contacting Us” section below. Requests to access, change, or delete your information will be addressed within a reasonable timeframe. Please note that we need to retain certain information about you for legal and internal business reasons, such as fraud prevention. We will retain your personal information for as long as necessary to provide you the services you have requested and as needed to comply with our legal obligations and enforce our agreements.
CHILDREN UNDER 13
Our Site and products or services available through this Site are not intended for children under 13 years-old. We do not knowingly solicit data online from or market online to children under 13 years-old. If we knowingly receive a child’s personally identifiable information, we will immediately delete it from our system. If you are the parent or legal guardian of a child under 13 years old and you believe we have received personal information from your child, please contact us at firstname.lastname@example.org.
LINKS TO THIRD PARTY WEBSITES
ACCOUNTABILITY FOR ONWARD TRANSFERS
To effectively serve the needs of our clients, Clickbooth may need to share that data with certain third parties or sub-processors. In such instances, Clickbooth will execute any needed contracts, clauses or addendums to ensure that any third-party agents that it engages to process personal data does so in a manner that is consistent with the Privacy Shield Principles. Clickbooth is potentially liable for onward transfers to third parties of personal data of EU individuals received pursuant to Privacy Shield.
WILL YOU TRANSFER MY PERSONAL INFORMATION ACROSS NATIONAL BORDERS?
We primarily store information about our visitors, members, and customers in the United States. However, we may transfer your personal information across national borders to other countries in compliance with applicable laws. If you are a European resident, we transfer your data based on one or more of the following legal mechanisms: the EU-U.S. Privacy Shield or Standard Contractual Clauses.
For more information about our Privacy Shield Certification, please see the section entitled EU-U.S. PRIVACY SHIELD FRAMEWORK, below.
EU-U.S. PRIVACY SHIELD FRAMEWORK
In compliance with the Privacy Shield Principles, Clickbooth commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Clickbooth at:
Clickbooth has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.
RECOURSE & ENFORCEMENT
In instances where other redress possibilities have been exhausted under EU law, or where the complaint has not been resolved by any other means, EU end users may be entitled to invoke binding arbitration option before the Privacy Shield Panel. Clickbooth acknowledges that any final decision by the Privacy Shield Panel is a legally binding decision, enforceable in US courts.
If our information practices change at some time in the future we will post the changes to our Privacy Statement Web page to notify you of these changes. We encourage you to periodically review this Privacy Statement for the latest information on our privacy practices.
YOUR ACCEPTANCE OF THESE TERMS
By using this Site, you signify your acceptance of this Policy. If you do not agree to this Policy, please do not use our Site. Your continued use of the Site following the posting of changes to this Policy will be deemed your acceptance of those changes.
CLICKBOOTH.COM, LLC PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This Privacy Notice for California Residents supplements the information contained in Clickbooth.com, LLC's above PRIVACY NOTICE and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some its requirements.
Information We Collect
Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:
- Publicly available information from government records.
- Deidentified 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:
|A. Identifiers.||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.||YES|
|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).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|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.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|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.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Our Website obtains the categories of personal information listed above from the following categories of sources:
- Tracking information received indirectly from forms you complete or products and services you purchase.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Service providers.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
Category F: Internet or other similar network activity.
Category G: Geolocation data.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
Sales of Personal Information
In the preceding twelve (12) months, Company had not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if 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 et. 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, please submit a verifiable consumer request to us by:
- Emailing us at email@example.com
Only you, or someone legally authorized 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, which may include:
- Full name, email address, date & time of transaction
- 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.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor 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 that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 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. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically in a csv document.
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.
Personal Information Sales Opt-Out and Opt-In Rights
We do not sell the personal information of consumers.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write us at: 401 N. Cattlemen Rd. Suite 200 Sarasota, FL 34232.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Attn: Privacy Department
401 N. Cattlemen Rd.
Sarasota, FL 34232