Effective date: __December 2020
Collection of Personal and Non-Personal Information (PII and Non-PII)
We collect and store certain personally identifiable information about you i.e., information which may identify you in some way; such as your name, number, email address and screen name (“PII”) only when you voluntarily submit it. We may request that you submit PII in certain instances, such as when youcontact us or book an appointment or utilize other features or functions of a Site.
When you connect to our Site, there is certain technical, non-personally identifiable information which does not identify any individual (“Non-PII”) that may be collected and stored through the use of “cookie” technology and IP addresses. PII is not extracted in this process. Non-PII may include, but is not limited to, your IP host address, internet browser type, personal computer settings, and the number, duration, and character of page visits. This information assists us to update a Site so that it remains interesting to our visitors and contains content that is tailored to visitors’ interests.
- To respond to your questions, comments, and requests; to provide you with access to certain areas and features on a Site; and to communicate with you about your activities on a Site.
- To investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, the rules or policies of a Site, or the rights of third parties; or to investigate any suspected conduct which we deem improper.
- To the extent that you provide us with financial information in connection with shopping or commercial services offered on a Site, we may use the financial information that you provide to fulfill the services.
- To help us develop, deliver and improve our services, content and advertising.
- To share with our parent, subsidiary, and affiliated companies, and promotional partners involved in creating, producing, delivering, or maintaining a Site, as required to perform functions on our behalf in connection with the Site (such as administration of the Site, administration of promotions or other features on the Site, marketing, data analysis, and customer services). In order to share such information, it may be necessary for us to transmit your PII outside the jurisdiction set forth below and you agree to this transfer. Further use or disclosure of PII by these parties for other purposes is not permitted.
- To share with third party service providers whom we employ to perform functions on our behalf in connection with the Site (such functions may include, but are not limited to, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data and providing marketing assistance, and providing customer service). These third party service providers have access to PII that is needed to perform their functions, and may collect or store PII as part of their performance of these functions, but are not authorized to use it for other purposes.
- For our internal purposes such as auditing, data analysis, and research to improve our products, services and customer communications.
- For other purposes as disclosed when your PII is collected or in any additional terms and conditions applicable to a particular feature of a Site.
- For disclosures required by law, regulation, or court order.
- For the purpose of or in connection with legal proceedings or necessary for establishing, defending, or exercising legal rights.
- In an emergency to protect the safety of users of a Site or the general public, or in the interests of national security.
Except as provided for herein, we will not provide any of your PII to any third parties without your specific consent.
Managing Your Personal Information. You have the ultimate control over the PII that we collect and use. You can always chose not to provide certain PII, but please keep in mind that you may not be able to use some of the features offered by a Site unless you provide us with your PII. If you wish to verify, update, or correct any of your PII collected through a Site, contact us on the details provided in the contact section of this policy.
We may also use your PII for the following purposes:
Direct Marketing. We may use your personal information to send you Carefree Consulting – related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Your Choices section below.
For research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.
To create anonymous data. We may create aggregated, de-identified or other anonymous data records from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
To comply with laws and regulations. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber-attacks and identity theft.
With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. The security on the internet is not 100% guaranteed, however we use best efforts to keep it secure for the users. We do not accept liability for unintentional disclosure. We encourage you to use caution when using the Internet.
NOTICE TO CALIFORNIA RESIDENTS – CCPA
We are required by the California Consumer Privacy Act (“CCPA”) to provide to California residents an explanation of how we collect, use and share their Personal Information, and of the rights and choices, we offer to California residents concerning that Personal Information.
Your California privacy rights. The CCPA grants California residents the following rights. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- You can request information about how we have collected, used and shared and used your Personal Information during the past 12 months.
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- You can ask us to delete the Personal Information that we have collected from you.
You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.
How to exercise your California rights. You may exercise your California privacy rights described above as follows:
- Right to information, access and deletion. You can request to exercise your information, access and deletion rights, by emailing firstname.lastname@example.org. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
- Request a list of third party marketers. California’s “Shine the Light” law (California Civil Code § 1798.83) allows California residents to ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide certain information about the companies’ sharing of certain personal information with third parties for their direct marketing purposes during the preceding year (if any). You can submit such a request by sending an email to email@example.com with “Shine the Light” in the subject line. The request must include your current name, street address, city, state, and zip code and attest to the fact that you are a California resident.
We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others in accordance with the CCPA. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
Carefree Consulting does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13 in order for compliance with the requirements of the Children’s Online Privacy Protection Act (COPPA).
In the case of discovering a child under 13 has provided us with personal data, we will immediately remove it from our servers. If you are a parent or guardian and are aware that your child has provided us with personal data, please contact us so that we will be able to take necessary action.
Data Protection Rights Under the GDPR
Carefree Consulting is committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object but also the following rights where the respective legal requirements are satisfied:
- Right to information, Art. 15 of the GDPR
- Right to correction, Art. 16 of the GDPR
- Right to deletion (“Right to be forgotten”), Art. 17 of the GDPR
- Right to limit processing, Art. 18 of the GDPR
- Right to data transmissibility, Art. 20 of the GDPR
- Right to object, Art. 21 of the GDPR
To exercise your right, please contact us as indicated in the “Contact Us” section below.
In order to be able to process your request, as well as for identification purposes, please note that we will use your personal information in accordance with Art. 6 para. 1 (c) of the GDPR.
You also have the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR in combination with Section 19 GDPR.
Third party websites
We may use third party platforms for the performance of our services (e.g.Appointy). We do not control the content or links that appear on third party sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies.
Our website uses Google Analytics, a web analysis service of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, www.google.com (“Google Analytics” or “Google”). Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there.
In using Google Analytics our website employs the extension “anonymize”. In doing so, Google abbreviates and thereby anonymizes your IP address before transferring it from EU/EEA member states. Google uses this information to analyze your use of our site, to compile reports for us on internet activity and to provide other services relating to our website.
Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used.
You can find additional information on how to install the browser add-on referenced above at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
For the cases in which personal data is transferred to the US, Google has self-certified pursuant to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework).
Facebook Pixel: This involves incorporating a tracking pixel (Facebook Pixel) in the head section of our website, which marks website visitors and recognizes them the next time they visit the social network. The pixel uses browser information, visited websites, and a hashed Facebook ID of the website user. This makes it possible for us to employ retargeting, i.e. to show you relevant Facebook ads about products or services of interest to you.
If you do not wish the Facebook pixel to use your information in this way, it is possible to opt-out of this and many other third-party cookies.
We use the CRM system “Bitrix24” of the provider Bitrix, Inc., 901 N. Pitt St, Suite 325 Alexandria VA 22314, USA, in order to be able to process inquiries of the users faster and more efficiently.
Bitrix24 uses users’ data only for the technical processing of inquiries and does not pass them on to third parties. To use Bitrix24 at least the specification of a correct e-mail address is necessary. A pseudonymous use is possible. During the processing of service requests it may be necessary to collect further data (name, address).
If users disagree with data collection and data storage in Bitrix24’s external system, we offer alternative contact options for submitting service requests by e-mail, telephone, fax or post.
We will retain your information for as long as needed to provide you the Site services, for our valid business purposes, and as necessary to comply with our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements.
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.