Last Updated: April 20, 2023
Your privacy is very important to us. Prolucent Health, Inc. and its affiliates (“we”, “us”, or “our”), respect
your privacy and are committed to protecting it through our compliance with this policy. This Policy
describes how we collect, use, store, process, protect and disclose “Personal Information,” which is
generally information that identifies, relates to, describes, references, is capable of being associated with,
or could reasonably be linked, directly or indirectly, with a particular individual or device, as more fully
described below, which we obtain from you when you visit the websites that we own or control (today or
in the future), including www.prolucent.com, www.liquidcompass.com (the “Sites”), you use the mobile
applications we own or control (today or in the future) including the Liquid Compass App (the “Apps”),
and when you use any services we provide through the Sites or the Apps (collectively, with the Sites and
the Apps, the “Services”). You can access the Services in many ways, including from a computer or mobile
phone, and this Policy will apply regardless of the means of access.
This Policy also governs the use of Personal Information we obtain from you from any third-party site or
application that you authorize to provide us with Personal Information. This Policy also sets forth your
rights and choices regarding the how we collect, use, and share your Personal Information.
and any data collection or processing activity that takes place on that website will be governed by that
Policy. Please be aware that we cannot control the privacy policies or practices of sites or companies that
we do not own or control and cannot control the actions of people we do not employ or manage.
Please read this Policy carefully. This Policy is incorporated into and is subject to our Terms of Service for
the applicable Services, which are available at https://www.liquidcompass.com/terms-of-use. In the
event of a conflict between this Policy and such Terms of Service, the applicable Terms of Service will
about this Policy, please e-mail us at firstname.lastname@example.org. If you do not want us to collect, use, store
or share your Personal Information in the ways described in this Policy, please do not use the Services. By
using the Services, you consent to our collection, use, storage and sharing of your Personal Information
as identified in this Policy.
Ⅰ. Information We Collect
Information You Provide to Us
We collect information that you provide to us. When you use some of our Services, you may choose to
provide certain information directly to us, to request more information, or for other reasons. We will
collect, use, store and/or share such information, which may include Personal Information, consistent
with this Policy. Examples of the Personal Information we collect that you provide to us include
information you provide when you:
The types of Personal Information you may share with us include your name, email address, physical or
postal address, phone number (including your mobile phone number), and the username and password
you select to use the Services. We will also collect and maintain information about all transactions
associated with your accounts.
Information We Receive From Third Parties
We may collect your Personal Information from third party affiliates or business partners such as social
media sites, ad networks, analytics providers, our distributors, dealers, and retailers, and advertising and
marketing agencies and vendors. We may also receive information from other sources to help us
supplement our records, improve the personalization of our service to you, and detect fraud. Our goal is
to limit the information we collect to the information needed to support our business.
Information We Collect Through Automatic Data Collection Technologies
You also provide us information in other ways through technology to help our Sites and Apps work
properly and support customer service, marketing, and analytics efforts to help us understand our
customers’ needs and provide information about our products and services. Some of this information
may be linked to you personally. When you use our Services, our servers automatically record information
that your browser or device sends whenever you visit a website or utilize an application. This information
may include your IP address, the type of device you are using, the internet service provider or mobile
carrier you are using, your device identifiers, your mobile telephone number, your geographic location
and your activities within the Services, including the links you click, the pages or screens you view, your
session time, the number of times you click a page/screen or use a feature of the Services, the date and
time you click on a page or use a feature and the amount of time you spend on a page or using a feature.
Our Sites also use “cookie” technology to collect additional website usage data and to improve the Sites
and our Services. A cookie is a small data file that we transfer to your computer’s hard disk. A session
cookie enables certain features of the Sites and is deleted from your computer when you disconnect from
or leave the Sites. A persistent cookie remains after you close your browser and may be used by your
browser on subsequent visits to our Sites. We may use both session and persistent cookies to better
understand how you interact with our Sites, to monitor aggregate usage by our uses and web traffic
routing on our Sites, and to improve our Sites and Services. You may also be able to configure your
computer or mobile device to limit the collection of these “cookies,” but that limitation may also limit our
ability to provide all of the services or functionalities of the Sites.
We may also automatically record certain information from your device by using various types of
technology, including “clear gifs” or “web beacons.” This automatically collected information may include
your IP address or other device address or ID, web browser and/or device type, the web pages or sites
that you visit just before or after you visit our Sites, the pages or other content you view or otherwise
interact with on our Sites and the dates and times that you visit, access or use our Sites. We may also use
these technologies to collect information regarding your interaction with email messages, such as
whether you opened, clicked on or forwarded a message, to the extent permitted under applicable law.
We also use Google Analytics to collect information automatically. Google Analytics only collects the IP
address assigned to you on the date you visited the site and does not gather your name or other
identifying information. We do not combine the information collected through Google Analytics with your
identifiable information. Although Google Analytics plants a permanent cookie on your web browser to
identify you as a unique user the next time you visit the site, the cookie cannot be used by anyone but
Google. You can prevent Google Analytics from recognizing you on return visits to this site by disabling
cookies on your browser. For information about how to opt-out of Google Analytics Advertising Features,
When you use our Services anonymously, we may use Segment to create a unique identifier for you using
your IP address that records your activities on our Sites but does not otherwise identify you. If you later
choose to create an account on the Services, your historical visit information is merged into your user
account to improve your user experience and allow us to recommend job listings based on your interests.
In short, we use these automated technologies to collect the following information:
- fill in forms or create an account or user profile on one of our Sites or Apps or otherwise use the
- request customer service, ask service-related questions, share suggestions or feedback, or
otherwise correspond with us using the Services, email, phone, or access or interact with our
pages or accounts on third-party social media platforms such as Facebook, Twitter, Instagram, or
- use the Services
- submit a resume or apply for job
- submit reviews or comments on our Services or social media pages
- participate in a promotion, survey, sweepstakes, or contest
- submit a resume or apply for a position
Information Collected by Third Parties
your interaction with such third-party content. Information collected through third-party web beacons
and buttons is collected directly by these third parties, not by us. Please consult such third party’s data
collection, use and disclosure policies for more information. If you do not consent to such third-party data
collection, use and disclosure practices, do not use or interact with the third-party content on the Sites
Links to Other Websites
The Sites and Apps may contain links to other websites. The fact that we link to a website is not an
endorsement, authorization or representation of our affiliation with that third party. We do not exercise
control over third party websites. These other websites may place their own cookies or other files on your
computer or mobile device, collect data or solicit Personal Information from you. Other sites follow
different rules regarding the use or disclosure of the Personal Information you submit to them. We are
not responsible for the content, privacy and security practices, and policies of third party sites or services
to which links or access are provided through our Sites and Apps. We encourage you to read the privacy
policies or statements of the other websites you visit.
Ⅱ. How We Use The Information We Collect
We may use the information we collect for non-marketing purposes including:
- your IP address, browser type, and operating system;
- the mobile device you use and its temporary or persistent unique device identifiers;
- pages you view within the Services;
- websites you visited before coming to the Services;
- video viewing history for videos you watch on the Services;
- emails from us that you open and/or forward;
- offers or links from us to which you connect; and
- information about products you purchase using the Services, including payment method, the date
and time of the transaction, items purchased, the purchase price, and other order or purchase
With your advance consent, we may use the Personal Information we collect for our own marketing
purposes including notifying you of special promotions, offers and events via push notifications, email and
other means, including text/SMS messaging, subject to compliance with applicable laws. We may also link
Personal Information (including your name, mobile phone number, and email address) with non-personal
information (including information automatically collected as described in this Policy) and use such
information for our own marketing purposes.
We may also use information in the aggregate to understand how our users as a group use the Services
provided on our Sites and Apps. We will not collect additional categories of Personal Information or use
the Personal Information we collect for materially different, unrelated or incompatible purposes without
providing you notice.
Ⅲ. How and With Whom We Share Your Information
For business purposes, we may share certain Personal Information we receive from and about you, and
about your transactions with us, with our affiliates and certain third parties, including our contractors,
service providers and other third parties we use to support our business. Doing so allows us to provide
the Services you request.
We may also share your Personal Information with the following third parties:
Employers and Potential Employers
Your Personal Information may be shared with our customers who use the Services to post job listings
using the Services or our customers who contract with us and use our vendor management platform to
assist with the processing of time and attendance data for their employees and contractors. Your Personal
Information may be shared with our customers’ employee management platforms as needed to process
payroll and benefits.
Third Party Service Providers
Your Personal Information may be shared with or collected by third party service providers who provide
us with services, including, but not limited to, facilitating mailing information and services, data hosting
or processing, and processing and fulfilling transaction. We require these third-party service providers to
exercise reasonable care to protect your Personal Information and restrict their use of your Personal
Information to the purposes for which it was provided to them.
information about your browsing activities over time and across different websites following your use of
the Services. For example, we use Google Analytics, as explained above.
Anonymous Information/Aggregated Information
We may freely use aggregated and anonymized information as allowed by law and share it with third
parties. Any anonymized information we provide to third parties does not identify you and is not
considered Personal Information, and, as such, is not subject to the terms of this Policy.
Sale of our Business; Bankruptcy
In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, we may
transfer or allow third parties to use information owned or controlled by us. We reserve the right, in
connection with these types of transactions, to transfer or assign your information and other information
we have collected to third parties or to authorize third parties to use any such information retained by us.
Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred
user information will be subject to this Policy. However, any information you submit or that is collected
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials or private parties to enforce and comply
with the law. To the extent permitted under applicable law, we may disclose any information about you
to government or law enforcement officials or private parties as we believe is necessary or appropriate to
investigate, respond to, and defend against legal claims, for legal process (including subpoenas), to protect
our property and rights or those of a third party, to protect us against liability, for the safety of the public
or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity,
to protect the security or integrity of the Services and any equipment used to make the Services available,
or to comply with applicable law.
Ⅳ. Access to Information and Your Choices
We provide you with the opportunity to access, update or delete certain information and to unsubscribe
or opt-out from certain communications. For example, you may exercise your choices as explained below.
Please be aware that, if you do not allow us to collect and use your personal information, we may not be
able to deliver certain products, services, promotions, and offerings to you. To protect your privacy and
security, we reserve the right to take reasonable steps to verify your identity before granting you account
access or making corrections to your information. You are responsible for maintaining the secrecy of your
unique password and account information at all times.
Account Management Options
You may access, correct or update certain personal information you have provided to us at any time by
accessing your user account. You may also choose to close your user account by accessing your profile
online. You may also choose how and whether to receive promotional or marketing communications from
us by exercising your choices by following instructions available on the Services or in communications sent
With your advance consent, you may receive mailings or emails from us with news or other information
on events, products, services, discounts, special promotions, upcoming events or other offers from us or
on our behalf. If at any time you wish to stop receiving emails, mailings, or other communications from us
please reply to any of our emails and type “unsubscribe” in the subject line or send us an email to
email@example.com and we will remove you from our mailing list. Please note that we may continue
to send transactional or account-related messages to you.
Alternatively, for email communications and text/SMS messages, you may opt out of receiving such
communications by following the unsubscribe instructions set forth in the messages you receive from us.
Your unsubscribe request or email preferences change will be processed promptly, though this process
may take several days. During that processing period, you may receive additional email or text/SMS
communications from us.
We will support your ability to access, correct, and delete your Personal Information. If we have obtained
your Personal Information from a other third party, we may confirm your request through them. For
assistance with exercising your choices, or if you have any questions about your choices, please contact
us at firstname.lastname@example.org.
We are committed to protecting the security of the Personal Information you provide to us and that we
collect about you. We maintain commercially reasonable safeguards to maintain the security and privacy
of Personal Information that you provide to us. Our safeguards vary based on the sensitivity of the
information that we collect and store.
Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent
risk in the use of email and the internet. Your information may be intercepted without our consent,
collected illegally and used by others without your consent. We cannot guarantee the security of any
information you disclose online, and you do so at your own risk. You are responsible for maintaining the
security of your account username and password. We recommend that you change your password
periodically. If you believe that your account username and/or password have been stolen or been made
known to others, it is your responsibility to immediately contact us at email@example.com and change
your password. We are not responsible if someone else accesses your account through information they
have obtained from you.
Ⅵ. Underage Persons
The Services are for use by persons who are at least 13 years of age. If you are younger than 13, you may
not access, attempt to access, or use the Services. We do not knowingly collect or allow the collection of
Personal Information via the Services from persons under the age of 13. If we learn that we have collected
the Personal Information of someone under the age of 13, we will take appropriate steps to delete this
information. If you are a parent or guardian of someone under the age of 13 and discover that your child
has submitted Personal Information, you may contact us at firstname.lastname@example.org and ask us to remove
your child’s Personal Information from our systems.
Ⅶ. Collection and Use of Personal Information of Employment Applicants
For Prolucent Opportunities
If you complete an application for employment with us or request information regarding such
opportunities, we may collect personal information that you provide (such as information contained in a
resume or cover letter) in connection with your request for information and/or to evaluate your
application for employment. We may also collect personal information about you from third parties to
supplement, update, or verify your information, and/or to process your application. Applicable law may
require that you authorize a third party to share your personal information with us before we can acquire
it. Failure to provide any requested information may negatively impact consideration of your employment
application. By applying to become an employee of Prolucent or its affiliates, you consent to our
collection, use, and disclosure of your personal information as described above, to the extent permitted
by applicable law.
For Users Applying for Third-Party Opportunities Using the Services
By creating a searchable resume through the Services, uploading a file resume on the Services, or
providing information in other application materials, you are requesting and authorizing us to make
available your resume and such information to third parties, in accordance with our Terms of Service. You
voluntarily choose what data is included on your resume and other application materials. When you
create a profile, your resume is set to searchable by default. This means that profile data and resume data
(searchable) may be available to third parties, such as potential employers. Data contained in your resume
and application materials is referred to as “Resume Data.” Data contained in your user profile is referred
to as “Profile Data.”
Please note employers who access your Resume Data while it is set to searchable visibility, or to whom
you apply with your not searchable resume, may choose to share your resume with additional parties. We
are not responsible for such sharing. Similarly, when you share your searchable resume directly with a
personalized link, we cannot control who sees your resume when you share that link.
Automated Processing of Your Personal Data
We perform automated processing of Personal Information to evaluate specific aspects relating to a user
and to analyze and predict a user’s preferences and interests. Where we perform this processing, we do
so either on the basis of user consent or performance of a contract, whereby such processing is necessary
for us to provide our services to job seekers and employers. For example, such processing allows us to
match job seekers with employers effectively, to provide job seekers with recommended jobs, and
invitations to take action on jobs that you may be interested in, to send particular job seeker applications
to an employer, to display search results, to send application status notifications on behalf of employers,
email@example.com to exercise your rights or contest any decision generated by said automated
Transfers of Information to Employers
We send job seeker Personal Information, Resume Data, and Profile Data to employers, including, on the
instruction of job seekers and employers. Such transfers are performed in the course of the job search,
application, and interview process. Information transferred to employers in this way is processed in
accordance with our Terms of Service and those of the employer. This transfer may include sending your
application and/or additional candidate information, such as your contact details, to other platforms that
process information for the employer, such as the employer’s applicant tracking system or scheduling
Employers agree to comply with all their responsibilities under applicable data protection rules with
respect to the collection, processing, and storage of Personal Information, as well as providing adequate
protection of all data subject rights provided for under all applicable data protection rules.
Transfers of Information to Job Seekers
We may send certain employer-related information to you, such as job ads, company pages, and other
information relating to potential employers and employment opportunities. This information may also
include the employer representative’s name, the employer’s city/state location, whether the employer
has taken or has chosen not to take an action with regard to the job seeker’s resume or application such
as opening, viewing, responding to or making a decision in regard to it, and whether the employer has
taken an action in regard to a job listing. As an employer, when you use the Services ) you agree that we
may provide this information to job seekers.
We retain personal information for as long as necessary to fulfill the purposes for which it is collected or
processed. We also retain information for related business purposes, security, legal compliance, and
disputes and claims handling as permitted by applicable law.
Ⅸ. International Users
The Sites and Apps are only intended for residents of the United States. If you are not a resident of the
United States, please do not provide us with any Personal Information.
Ⅹ. Changes to this Policy
to you after the effective date of the revision. Your continued access or use of the Services following any
amendments to the Policy constitutes your acceptance of the Policy as amended. It is your sole
responsibility to monitor our website for changes to the Policy.
Ⅺ. Contact Us
If you would like to review, update or correct your information or modify your communication
can contact us at: firstname.lastname@example.org.
Ⅻ. California and Nevada State Law Privacy Rights
If you are a California resident, this Section is provided pursuant to the California Consumer Privacy Act of
2018, Cal. Civ. Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), as modified by the
California Privacy Rights Act (the “CPRA”). Please read it carefully. This Section applies to our processing
of information that identifies, relates to, describes, is reasonably capable of being associated with, or
could reasonably be linked, directly or indirectly, with you or your household (“California Personal
Information”). For California residents to whom this Section applies, the provisions of this Section prevail
We have collected the following categories of California Personal Information within the last 12 months
from the sources listed below:
- validating your identity and managing your account with us;
- processing your transactions and providing our products and services to you;
- communicating with you for non-marketing purposes, including order processing and fulfillment
and about employment opportunities and job openings;
- sending you push notifications or e-mails to provide you with alerts and updates about your
account and our Services;
- conducting statistical or demographic analysis;
- complying with legal and regulatory requirements;
- customizing and improving your experience with the Services or our products;
- protecting and defending Prolucent and its affiliates against legal actions or claims;
- detecting and preventing fraud;
- debt collection;
- satisfying contractual obligations;
- cooperating with law enforcement or other government agencies for purposes of investigations,
national security, public safety or matters of public importance when we believe that disclosure
of Personal Information is necessary or appropriate to protect the public interest;
- improving customer service;
- providing you the features and functionalities associated with the Services;
- evaluating and considering your application for a job with us or our customers that use the
Serviecs to to post job listings;
- any other purposes for which we obtain your consent; and
- for other business purposes permitted under applicable law (collectively, “Non-Marketing
Please see the “Information We Collect” and other sections of this Policy to learn more about how we
collect these types of information we collect.
For each of the above categories, we use the California Personal Information for a variety of business
purposes such as:
- Identifiers, such as:
- First name, last name, job applicant account username and password, social security
number, drivers’ license or other state identification number, and other similar identifying
- Physical address(es), email address(es), telephone number(s), and emergency contact.
- Where applicable and in accordance with applicable law, your ethnicity, disability, military
status, or criminal history.
- Schools attended, degrees or certifications earned, grades, disciplinary records, or other
education records and information.
- Your current and former employers, job title(s), and position(s).
- Application information including what position you applied for, when you applied, and
how you applied.
- Unique personal identifier, and online identifier.
- Internet Protocol address, account name, or other similar identifiers.
- This category of information is collected from you, your devices, third parties (such as
linked sites), and public databases.
- Personal information described in Section 1798.80(e) (California customer records statute), such
as a name, address, and telephone number. This category of information is collected from you,
your devices, our affiliates, or other third parties such as our business partners.
- Characteristics of protected classifications under California or federal law such as age, gender,
race, ethnicity or national origin. While we do not request such information, we may collected it
from you if you voluntarily choose to provide it to us in resumes, cover letters, and other
application materials you submit using the Services.
- Internet or other similar network activity, including, but not limited to, browsing history, search
history, browser settings like language preference, and information regarding your interaction
with a website, application, or advertisement. This category of information is collected from you
and your devices.
- Geolocation data, including physical location or movements. This category of information is
collected from you and your devices.
- Sensory data, including electronic, visual, or similar information. This category of information,
such as photos, is collected from you and third parties (such as linked sites), or our service
- Resume Data and Profile Data.
- Inferences,such as a profile about a consumer’s preferences, characteristics, and behavior, drawn
from information we collect and insights we receive from third parties such as our marketing and
advertising partners and data analytics providers.
We may also use the information we collect for our own operational purposes, purposes for which we
provide you additional notice, or for purposes compatible with the context in which the California
Personal Information was collected.
Within the last 12 months, we have disclosed California Personal Information for our business purposes,
including with our customers who use the Services to post job listings. To learn more about the categories
of third parties with whom we share such information, please see the “How and With Whom We Share
Your Information” Section of this Policy.
We do not sell and, within the last 12 months, we have not sold, California Personal Information, including
California Personal Information of individuals under 16 years of age.
Your California Privacy Rights
If you are a California resident, you have certain rights related to your California Personal Information,
- Fulfilling your requests for services and information;
- Evaluate your application and resume and consider you for current and potential employment
opportunities with us or our customers;
- Schedule interviews and communicate with candidates about their applications;
- Comply with applicable laws, regulations, and legal process;
- Maintain records of our interactions and communications;
- Audits and reporting relating to particular transactions and interactions, including online
interactions, you may have with us or others on our behalf;
- Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal
activity, and prosecuting the same;
- Debugging to identify and repair errors in our systems;
- Short-term, transient use including contextual customization of ads;
- Providing services on our behalf or on behalf of another, including maintaining or servicing
accounts, providing customer service, fulfilling transactions, verifying identity information,
processing payments, and other services;
- Conducting internal research to develop and demonstrate technology;
- Conducting activity to verify, enhance, and maintain the quality or safety of services or devices
which we may own, control, or provide;
- Other business purposes described in the “How We Use The Information We Collect” Section of
- As permitted by law;
- To protect our rights, privacy, safety or property, or that of our employees or other parties; and
- For any other purposes with the consent of the California applicants
You may request to exercise these rights by:
- The right to request that we disclose to you:
- the specific pieces of California Personal Information we have collected;
- the categories of California Personal Information we have collected about you;
- the categories of sources from which the California Personal Information is collected;
- our business or commercial purpose for collecting or selling California Personal
- the categories of third parties with whom we share California Personal Information.
- The right to request that we delete California Personal Information about you.
Two Lincoln Centre, Suite 550
5420 LBJ Freeway
Dallas, Texas 75240
As required under applicable law, please note that we will take steps to verify your identity before granting
you access to information or acting on your request to exercise your rights. We may require you to provide
your first name, last name, and email address to verify your identity in response to exercising requests of
the above type. You will, therefore, need access to your email account to receive our communications
necessary to process your request. Please make sure to check your spam inbox to ensure these important
communications are not missed. We may limit our response to your exercise of the above rights as
permitted under applicable law. When you submit a request to exercise your rights above, we will use the
information you provide to process your request and to maintain a record of your request and our
response, as permitted under applicable law.
Under California law, you may designate an authorized agent to make a request on your behalf. You may
make such a designation by providing the agent with written permission to act on your behalf. We will
require the agent to provide proof of that written permission. As permitted by law, we may require you
to verify your own identity in response to a request, even if you choose to use an agent.
We may not discriminate against you because of your exercise of any of the above rights or any other
rights, subject to the rights and the obligations under the California Consumer Privacy Act, including by:
We will not discriminate against you for exercising your CCPA privacy rights.
California Job Applicants
In the context of job applications, we also collect information from you and third parties, including
business contact information such as company name, physical address email address, education
or other notices we provide. If you complete an application for employment with us or request
information regarding such opportunities, California Personal Information you provide to us (such as
information contained in a resume or cover letter) in connection with your request for information and/or
Do Not Track
California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides
that California residents are entitled to know how we respond to “Do Not Track” browser settings. We do
not currently take actions to respond to Do Not Track signals because a uniform technological standard
has not yet been developed.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter
603A may submit a request to this designated address: email@example.com. However, please know
we do not sell data triggering that statute's opt-out requirements.
ⅫⅠ. For EU Residents:
The General Data Protection Regulation (“GDPR”), particularly Articles 15 to 21, affords you a number of
rights as a data subject. We encourage you to read and learn about those rights on your own. However,
the following will help you to begin to understand those rights.
- Denying you goods or services;
- Charging different prices or rates for goods or services, including through the use of discounts,
loyalty programs, or other benefits or imposing penalties;
- Providing you a different level or quality of goods or services; or
- Suggesting that you will receive a different price or rate for goods or services or a different level
or quality of goods or services.
In addition, to the extent that we process any of your Personal Information on the basis of your consent,
you have the right to withdraw that consent at any time, without affecting the lawfulness of processing
that was based on your consent before its withdrawal.
If you are a natural person residing in the EU and at any time you believe we have violated one of your
rights listed above, or if you believe we are in violation of one or more of the provisions of the GDPR,
you have the right to lodge a complaint with a Data Protection Authority. More information about the
Data Protection Authorities can be found at https://ec.europa.eu/info/law/law-topic/dataprotection/reform/what-are-data-protection-authorities-dpas_en.
Information and Data Security
We have implemented an information and data security program that contains administrative, technical
and physical controls that are designed to reasonably safeguard Personal Information.
Transfer of Information, Transfers to Other Countries
We are headquartered in the United States of America. Personal Information may be accessed by or
transferred to the United States or to our controlled affiliates and data processors elsewhere in the
Information, we do so in compliance with applicable law. Additionally, we protect the privacy and
processed or stored.
Personal Information that we receive in the United States concerning persons in the European Union is
transferred subject to appropriate safeguards, including the European Union’s standard contractual
clauses for the transfer of personal data to third countries. A copy of these clauses is available upon
request, free of charge. To request a copy of the standard contractual clauses, please contact us using
- 1. The Right to Access: This allows you to request from us information about your Personal
Information, including what data we have and how and why it is being processed.
- 2. The Right to Rectification: In the event that some or all of the Personal Information that we
have concerning you is inaccurate, this gives you the right to have those inaccuracies rectified.
- 3. The Right to Erasure: In some cases, you may have the right to request that we erase your
Personal Information that we have in our possession.
- 4. The Right to Restriction of Processing: This gives you the right, in some circumstances, to have
us process your Personal Information only with your consent.
- 5. The Right to Object to Processing: Where we are processing your Personal Information on the
ground of its legitimate interests, or to carry out tasks in the public interest or to exercise official
authority, you have a right to object to the processing on grounds relating to your particular
situation. In cases where you object to our processing of your personal data for direct marketing
purposes, the processing will cease.
- 6. The Right to Data Portability: This allows you to request from us a copy of your Personal
Information that it has on file and to transfer that information to someone else without any interference from us. In some cases, you may be able to request that we transfer your Personal
Information directly to a third party on your behalf.