Privacy Policy

SCOPE

Your privacy is important to ClickSWITCH and we go to great lengths to protect it. This Privacy Policy applies to the online collection and sharing of personal and other information via the ClickSWITCH websites. This Statement does not apply to information collected in any other way, including offline, through other ClickSWITCH websites, or through other ClickSWITCH applications. ClickSWITCH may contain buttons or links to sites maintained by third parties. By including a link to third-party sites, ClickSWITCH does not endorse or recommend any products or services offered or information contained at the third-party sites. These third-party sites are not operated or controlled by ClickSWITCH and may have different privacy practices that provide less protection than the ClickSWITCH websites. If you decide to visit a third-party site via a link contained on the ClickSWITCH websites, you do so at your risk.

DEFINITIONS

In this Privacy Policy: “Personal Information” or “Personally Identifiable Information” means categories of information that identify you personally.

SUMMARY

What Information Is Collected?

We collect information about our users in the following ways: directly from the user (for example, when using our service or enrolling an account) and from our web server and application logs. The device or devices on which you use ClickSWITCH will determine, in part, the exact manner in which we collect information from you.

  • We may collect the following information:
    • Real name
    • Email Address
    • Physical Address
    • Social Security Number
    • Signature
    • Characteristics of protected classifications under California or federal law including age;
    • Audio, electronic, visual, thermal, olfactory, or similar information;
    • Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;
    • Other information relevant to customer surveys and/or offers; and
    • Any other information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
    • Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
  • We also allow our analytics provider or providers to collect usage information, through the use of cookies or other technologies, over the Internet from your device, including a unique identifier that ClickSWITCH or the analytics provider assigns to your device, certain device and technical information, and your Internet protocol address.
  • You have the ability to accept or decline cookies using your web browser settings. If you choose to not accept cookies from the ClickSWITCH websites, you may not be able to take full advantage of our features or to receive some of the services that our websites provide. To learn more about cookies and your ability to opt-out of certain advertising cookies, please visit the following websites: http://www.aboutads.info/choices or http://www.networkadvertising.org/choices.
  • We, or our third-party providers, may collect personal information about your online activities over time and across different websites when you use the ClickSWITCH websites.
  • The ClickSWITCH websites do not respond to web browser “Do Not Track” signals.

How Is Collected Information Used?

  • We use the information, including analytics information, primarily to provide you with a personalized Internet application experience that delivers the information, resources, and services that are most helpful to you and to ensure quality of service.
  • We may use the information for the following business purposes:
    • 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 that the personal information 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, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, or providing analytic services, or providing similar services;
    • 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 us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; and
    • Conducting any other legitimate business activities not otherwise prohibited by law.
  • We do not share your Personal Information, unless we say so in this Privacy Policy, or when we believe in good faith that the law requires it.

How Is My Personal Information Protected?

  • We have implemented certain appropriate security measures to help protect your personal information from accidental loss and from unauthorized access, use, or disclosure.
  • We store the information about you in a data center with restricted access and appropriate monitoring.
  • We use intrusion detection and virus protection software.
  • Despite these measures, we do not guarantee that unauthorized persons will always be unable to defeat our security measures.

Who Has Access to the Personal Information?

  • We will not rent or lease mailing lists, customer names or email addresses to others, and we will not make your Personal Information available to any unaffiliated parties, except our approved agents and contractors, or as otherwise described in this Privacy Policy.
  • We do not sell Personal Information, and we will not sell Personal Information except as described in this Privacy Policy or if we provide you with notice and a right to opt-out of such sale.
  • We rely on some of our affiliates for support of the products and services we offer; our affiliates are all required to preserve the confidentiality of any Personal Information they may access.
  • We will not disclose any Personal Information except as necessary to service your account, to enforce the terms of use, to meet our obligations to content and technology providers, or as permitted by law.
  • We do not sell the personal information of consumers, including consumers that are less than 16 years of age, unless the consumer (in the case of consumers between 13 and 16 years of age) or the consumer’s parent or guardian (in the case of consumers who are less than 13 years of age) has affirmatively authorized the sale of the consumer’s personal information.

What Privacy Rights Do California Residents Have?

  • 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 also designate an authorized agent to make such requests on your behalf by e-mailing us at infosec@clickswitch.com with either (1) written permission that the agent is authorized to submit requests on your behalf, provided that the authorized agent can verify his/her identity, or (2) a signed power of attorney that the agent is authorized to act on your behalf.
  • We will not discriminate against you if you choose to exercise any of your rights as described in this section.

How May I Request or Delete My Personal Information?

  • You may request a copy of the Personal Information we have stored pertaining to you or request us to delete your Personal Information at any time.
  • If you have any requests, questions or concerns related to this Policy and/or our practices, e-mail us at infosec@clickswitch.com, call us toll-free at 866-410-6761 or mail your request to ClickSWITCH, Attention Chief Compliance Officer, at 701 Washington Ave N #300, Minneapolis, MN 55401.

What About Changes to this Privacy Policy?

  • We reserve the right to change this Privacy Policy at any time without notice to you.
  • Any changes will be effective immediately upon the posting of the revised Privacy Policy, as indicated by the “Last Updated” date located at the end of this Privacy Policy.
  • Your use of the ClickSWITCH websites indicates your consent to the Privacy Policy posted at the time of use.

Policy Last Updated: November 17, 2020