Last Updated: February 18, 2022
II. INFORMATION COLLECTED BY OUR SITE AND/OR SERVICES.
Data Submitted by User or Visitor of Site and/or Services
When you use our Site or Services, you can (depending on the Services you use) submit information by way of the following:
- Typing-in data (such as when you type a message to send to us or another user, enter a search request, or complete a form);
- Uploading a document, image or other data file; or
- Authorizing us to retrieve and import information from you, another user or other third party on your behalf.
Engagement Tools and Engagement Data
Our Site also gathers information whenever you visit, log in or otherwise interact with us. As with other websites and interactive services, whenever you interact with our Site, your computer, mobile phone or tablet and its software (a “Device”) transmits a “request” to us. That request includes information received from your Device necessary for us to identify and appropriately route the information your Device is requesting. These “requests” and “replies” are present on all websites and Internet services. Therefore, whenever you:
- Visit and navigate through our Site or Services;
- Click on a link;
- Open a webpage or web form;
- Open a web-enabled email sent by us;
- Send a message via our interactive chat or instant message feature; or
- Otherwise take an action or interact with elements of our Site or its pages, content or features your Device is sending non-personal information to us.
Our Site also gathers information whenever you visit, log in or otherwise interact with us. In addition to managing the appropriate routing of information, we use so-called “cookies,” “web beacons,” “server logs” and other Engagement Tools (“Engagement Tools”) to enhance the quality of the service and content you receive. For example, we use Engagement Tools to:
- Save User preferences;
- Preserve session settings and activity;
- Help authenticate Users;
- Allow Users to auto-fill sign-in pages of websites they frequently visit;
- Tailor the delivery of ads and other content; and
- Analyze the performance of our Site, Services and various features and content.
Therefore, even if you do not register with us or submit any personal information on our Site, our Engagement Tools automatically receive information about your Device and the software running on it. We call such information Engagement Data (“Engagement Data”).
Engagement Data often includes elements such as the date and time a “request” is made, the model of the Device making the “request,” the type and version of operating system running on a Device, the browser making the request, routing information, IP address, geolocation, search terms a User enters, what URL a Device most recently visited, and, if a mobile application is used, an anonymous unique number. Engagement Data can also include Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement. Engagement Data can be combined with personal information. If so, we treat such combined information the same way we treat personal information.
You have the ability to control how certain Engagement Tools operate by modifying the settings on your Device or its software. Most browsers, for example, allow you to refuse accepting cookies, and many mobile Devices allow you to disable the sending of location information. In some cases, doing these things could diminish the performance of our Site and Services or render them inoperable. To learn more about Engagement Tools and how we use Engagement Data please see the section below entitled “How Information is Used.”
Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser “do not track” signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
Online Tracking By Third Parties
Third-party analytics and other service providers, such as Google Analytics, may set and access their own tracking technologies on your Device and they may otherwise collect or have access to information about you and track you over time and across third party websites. These service providers use tracking technologies to help us analyze how visitors use our Site and Services. We are not responsible for those third party technologies or activities arising out of them. However, some third parties may offer you certain choices regarding their practices.
For example, to learn about opting out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options. If you choose to opt out of the use of Google Analytics, Google will no longer collect and analyze information via cookies associated with your browser for these services. When you opt out, Google will place opt-out cookies on your browser. If you delete your cookies, change browsers, or change devices, you will need to repeat this opt-out process. Also, please note that this opt-out process will work only if your browser is set to accept all cookies. We may still use Google Analytics services to create promotions and apps within social networks after you opt out. These services do not rely on collecting and analyzing information via cookies. To learn more about your choices for these services, review the options your social network provides.
You can obtain information about which third parties have currently enabled cookies and how to opt-out of some of those cookies by visiting the Network Advertising Initiative’s website at https://optout.networkadvertising.org; or the Digital Advertising Alliance’s website at https://optout.aboutads.info. For more information on mobile-specific opt-out choices, please visit https://www.networkadvertising.org/mobile-choices.
Third Party Tools
We work with certain third parties who deploy their own Engagement Tools on our Site (“Third Party Tools”). In some instances they do so exclusively on our behalf. In other instances, they may retain and use the data they collect pursuant to publicly available privacy policies. These Third Party Tools are frequently deployed by companies providing online advertising services or analytics, but they may be deployed in other contexts as well, such as social media plug-ins. We treat personal and non-personal information that we receive from these Third Party Tools the same way we treat personal and non-personal information that we directly collect from our Site. We, however, do not control how these third parties manage the information they gather.
III. PERSONAL AND NON-PERSONAL INFORMATION.
Information you submit to us that identifies you or can be used to contact you (e.g., email or mailing address) is your “personal information.” We collect the following categories of personal information about you:
- Personal identifiers, including name, telephone number, address, and email.
- Other information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you, including signatures, call recordings, employment information, or education information.
When we combine non-personal information with personal information, or non-personal information with other non-personal information in a way that renders the combined information personal information, we treat that combined information the same way we treat personal information. When we combine personal information with information from third party sources, we also treat that combined information the same way we treat personal information.
How Information is Used
We use personal and non-personal information (including Engagement Data) for the following purposes:
- Operating, maintaining, managing and administering our Site or Services, such as providing customer support;
- Responding to questions and communications, which we retain in the ordinary course of business;
- Administrative announcements about features, functionality, terms or other aspects of our Site or Services; and, if applicable, informing about offers for services or products we believe may be of interest to you (see also “Service Emails and other Communications” sections below);
- Safeguarding and protecting our Site and Services, the information they safeguard, the rights of third parties and in response to legal process, in each case, as more fully described below in “The Importance of Protecting our Site, Services and the Information they Safeguard”;
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Debugging to identify and repair errors that impair existing intended functionality;
- Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
- Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider;
- Undertaking internal research for technological development and demonstration;
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business;
- Advancing a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction; and
We use non-personal information for the following purposes:
- Auditing, research, measurement and analysis in order to maintain, administer, enhance and protect our Site and Services, including analyzing usage trends and patterns and measuring the effectiveness of content, advertising, features or services;
- Creating new features and services;
- Contextual and cookie-based automated content delivery, such as tailored ads or search results;
- Conducting research and engaging in public service activities and services; and
We may also use non-personal information to prepare aggregate reports for current or future advertisers, sponsors or other partners to show trends about the general use of our Site and/or Services. Such reports may include age, gender, geographic, demographic or other general User information, but do not include personal information.
IV. CONSENTS AND AUTHORIZATIONS.
V. SERVICE EMAILS AND OTHER COMMUNICATIONS.
Our Site and/or Services allow Users to communicate with others through our in-product instant messaging services, Service-branded emails, SMS and other electronic communication channels. Communications that are sent by or on behalf of a User are indicated as being “From” that User. Communications that are sent by us are indicated as being from us or one of our account or support specialists assigned to assist you. Either type of communications may be “real time” communications or communications triggered automatically upon the occurrence of certain events or dates – such as a repeated sign-in failure, an appointment reminder and the like.
Electronic messages received from Users and our administrative announcements are often transactional or relationship messages, such as appointment requests, reminders and cancellations and other Service notifications. You may not be able to opt out of receiving certain messages, although our Site and/or Services may provide a means to modify the frequency of receiving them. In cases in which we believe User emails are not primarily transactional or relationship messages, it will include the capability to opt-out of receiving further e-mails. If you sign-up to receive marketing announcements from us, such emails will include capability to opt-out of receiving such e-mails in the future.
On occasion, we will communicate marketing information, operational updates and other information to Users via electronic mail. Users agree that such transmissions are important means of communication between us and Users and shall not be considered junk faxes or unsolicited advertisements as defined by the Telephone Consumer Protection Act of 1991 or other applicable state or federal laws or regulation.
From time to time we ask Users to complete surveys or otherwise provide input to improve our operations or to assist other Users in making informed choices. The content of such surveys, therefore, should be presumed public. When we make such survey, we let Users know how their responses will be used. As with communities and public forums, we strongly advise Users to exercise care in selecting what information they share in a survey or similar communication, and strongly recommend against sharing any personal financial or other sensitive information that could directly or indirectly be traced to any individual, including yourself.
Our Site may deploy Engagement Tools (such as “cookies,” “web beacons” and “server logs”) on outbound emails to Users and others to collect Engagement Data, and we may use vendors to assist us in sending outbound emails to Users who may deploy Third Party Tools.
Emails and Other Communications
VI. SHARING OF INFORMATION.
We will not share personal information you submit except under the following circumstances:
- When you choose to share such information through our Site or Services. Under certain circumstances this may require a specialized consent before our Site or Services complete certain such transmissions;
- When you are otherwise notified at the time we collect such information or we otherwise have your express consent;
- When your account has been issued by an account administrator with administrative rights over your account, your account administrator will have access to your account information, including your personal information. Your account administrator may: (i) receive and retain your account information, (ii) change your account password, (iii) restrict your ability to submit, delete or edit information; (iv) suspend or terminate your account access, or (v) access or retain information you submit or otherwise stored as part of your account for any purposes required or permitted under applicable law;
- When we share such information with our current and future affiliates;
- When we use third party service providers. We may use third-party service providers to perform certain services on behalf of us, Site or the Services, such as: (a) to assist us in operations; (b) to manage a database of customer information; (c) hosting the Site or Service; (d) designing and/or operating the Site or Services’ features; (e) tracking the Site and Service’s activities and analytics; (f) enabling us to send you special offers or perform other administrative services; and (g) other services designed to assist us in maximizing our business potential. We may provide service providers with access to your Information to carry out the services they are performing for you or for us;
- When we protect our Site and Services, the information they safeguard, the rights of third parties and in response to legal process, as more fully described below in “The Importance of Protecting our Site, Services and the Information they Safeguard”;
- It is important for you to understand that other users who submit to, or receive from, our Site or Services personal information about you, may share that information with other persons, even without separately notifying you or seeking your consent; and
- When we are complying with your requests, directions, instructions, or other express authorization; and
We do not sell personally identifiable information, and we will not sell personally identifiable information except as described in this Policy or with your consent. If we ever decide to sell personally identifiable information, we will provide you with notice and a right to opt-out of such sale.
VII. THE IMPORTANCE OF PROTECTING OUR SITE, SERVICES AND THE INFORMATION THEY SAFEGUARD.
Our Site and many of our Services are protected by technical measures intended to safeguard the confidentiality, integrity and accessibility of sensitive information our Users store and share on our Site. Further, certain regulations require us to investigate potential or suspected threats on our Services or the confidentiality, integrity or availability of the information they safeguard. Accordingly, we may preserve, use and disclose information – including personal and non-personal information – when we have a good faith belief it is necessary or advisable to:
- To protect ourselves, you and third parties.
We endeavor to make security of our Site and Services and the information they collect, store, process and transmit a top priority. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the information we collect, we deploy a wide range of technical, physical and administrative safeguards, including: Secure Socket Layer (SSL) encryption, firewalls, system alerts and other information system security technologies; housing data in secure facilities that restrict physical and network access; and regular evaluation and enhancement of our information technology systems, facilities, and information collection, storage and processing practices. It is important to remember, however, that no system can guarantee 100% security at all times. Accordingly, we cannot guarantee the security of information stored on or transmitted to or from our Site and Services.
Steps You Can Take
If we learn of a security vulnerability or risk, we may attempt to notify you and provide information on protective measures you may take. There are, however, some precautions that you can proactively take to improve your system security and reduce the likelihood of unintended disclosure of personal information:
- Install malware detection programs that regularly scan your system and incoming traffic for malicious code – such as computer viruses, worms, Trojan Horses and spyware. Because viruses and malware are continuously created and modified, regular malware protection software typically requires frequent updates.
- Use a firewall to prevent unauthorized access to your Device.
- Because malware often targets vulnerabilities in existing operating systems, browsers, plug-ins and other programs, software vendors frequently update their products with security patches to guard against known or commonly exploited vulnerabilities. Vendors often try to alert their users and recommend immediate installation of these security patches.
- Use a strong password using a combination of letters and numbers that are not easily guessed. Do not share your password with others.
- If you use a shared Device, always close all active programs and log out before leaving it unattended.
- Avoid using a public wireless network, if possible. If you do use a public network, use the most restrictive wireless network settings on your Device.
- If you use file-sharing programs, be sure to restrict all other folders or directories to “no share.”
- Be very cautious with any email requesting you to share personal information. On websites, look for the lock symbol on or near your browser’s address bar which signifies a secure website before supplying personal information.
- When participating in one of our communities, blogs, forums, surveys or other open communication platforms, exercise care in selecting what information you share, particularly personal or financial information.
IX. CHILDREN UNDER 13.
Without limiting the generality of the foregoing, our Site and Services do allow Users above the age of 18 years old – such as parents and guardians – to submit personal information about others, including minors. Such Users assume full responsibility over their submission, use and transmission of such information.
X. UNITED STATES ONLY.
XI. THIRD PARTY SERVICES.
XII. CHANGES TO THIS POLICY.
XIII. VIEWING, UPDATING AND DEACTIVATING INFORMATION.
Our Site and Services aim to provide you with access to the personal information you submit and the means to update it. This can be accomplished by logging into our Site or Services or contacting us using the contact information below. Under certain circumstances, we may ask you to verify your identity before your request is processed. This will be done free of charge except where it would require a disproportionate effort. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
You should also be aware that we store indefinitely non-personal information, including Engagement Data and de-identified personal information, as well as all information that you have shared on any of our public forums, blogs, communities, surveys and the like.
9525 West Bryn Mawr Avenue, Suite 900
Rosemont, Illinois 60018
Telephone (866) 871-7741
XIV. California Privacy Rights
Under the California Consumer Privacy Act, California residents have the right to:
- Request that a business delete any personal information about the consumer which the business has collected from the consumer.
- Request that a business that collects personal information about the consumer disclose to the consumer, free of charge, the following:
- The categories of personal information that it has collected about that consumer.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom the business shares personal information.
- The specific pieces of personal information it has collected about that consumer.
- Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose disclose, free of charge, to the consumer:
- The categories of personal information that the business collected about the consumer.
- The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal was sold, by category or categories of personal information for each third party to whom the personal information was sold.
- The categories of personal information that the business disclosed about the consumer for a business purpose.
- Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.
You may submit such requests by contacting us at www.librasolutionsgroup.com/privacy-rights or call the toll-free number (866) 871-7741.
You may also designate an authorized agent to make such requests on your behalf by calling the toll-free number (866) 871-7741.
We will not discriminate against you because you exercise any of your California privacy rights.