This Privacy Notice for
127 Digital Solutions ("we," "us," or
"our"), describes how and why we might access, collect, store, use,
and/or share ("process") your personal information when you use our services
("Services"), including when you:
Use 127 Digital
Solutions. 127 Digital Solutions provides a CRM platform and
AI-powered automation services for small businesses. Our services include branded CRM
access, marketing automation workflows, AI tools, appointment booking systems, and ongoing
technical support.
Engage with us in other related ways, including any sales,
marketing, or events
Questions or
concerns? Reading this Privacy Notice will help you understand your privacy rights
and choices. We are responsible for making decisions about how your personal information is
processed. If you do not agree with our policies and practices, please do not use our
Services. If you still have any questions or concerns,
please contact us at [email protected].
SUMMARY OF KEY
POINTS
This summary
provides key points from our Privacy Notice, but you can find out more details about any of
these topics by clicking the link following each key point or by using our
table of
contents below to find the section you are looking
for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending
on how you interact with us and the Services, the choices you make, and the products and
features you use. Learn more about personal information you disclose to
us.
Do we process any sensitive personal
information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or
ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when
necessary with your consent or as otherwise permitted by applicable law. Learn more about
sensitive information we
process.
Do we collect any information from third
parties?We may collect information from public
databases, marketing partners, social media platforms, and other outside sources. Learn more
about information collected
from other sources.
How do we process your information? We
process your information to provide, improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply with law. We may also process your
information for other purposes with your consent. We process your information only when we
have a valid legal reason to do so. Learn more about how we process your
information.
In what situations and with which types of parties
do we share personal information? We may share information in specific situations
and with specific categories of third parties. Learn more about when and with whom we share your personal
information.
How do we keep your information safe? We
have adequate organizational and technical processes and procedures in place to
protect your personal information. However, no electronic transmission over the internet or
information storage technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security and improperly collect, access, steal, or
modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where
you are located geographically, the applicable privacy law may mean you have certain rights
regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The
easiest way to exercise your rights is by submitting a
data subject access request, or by contacting us. We will consider and act upon any
request in accordance with applicable data protection laws.
In
Short:We collect personal
information that you provide to
us.
We collect personal information that you voluntarily provide to
us when you register on the Services, express an interest in obtaining information about us or our
products and Services, when you participate in activities on the Services, or otherwise when you
contact us.
Personal Information Provided
by You. The personal information that we collect depends on the context of your
interactions with us and the Services, the choices you make, and the products and features you
use. The personal information we collect may include the following:
names
phone
numbers
email
addresses
job
titles
passwords
usernames
contact
preferences
contact or authentication
data
billing
addresses
debit/credit card
numbers
Sensitive Information.When necessary, with your consent or as otherwise permitted
by applicable law, we process the following categories of sensitive information:
financial
data
Payment Data. We may collect data
necessary to process your payment if you choose to make purchases, such as your payment
instrument number, and the security code associated with your payment instrument. All payment
data is handled and stored byStripe. You may find their privacy notice link(s) here:https://stripe.com/privacy.
Payments are processed securely
through third-party payment providers. We do not store your payment card details on our
servers.
All personal information that you provide to us
must be true, complete, and accurate, and you must notify us of any changes to such personal
information.
Information
automatically collected
In
Short:Some information — such
as your Internet Protocol (IP) address and/or browser and device characteristics — is collected
automatically when you visit our
Services.
We automatically collect certain information when you visit, use,
or navigate the Services. This information does not reveal your specific identity (like your name
or contact information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences, referring URLs,
device name, country, location, information about how and when you use our Services, and
other technical information. This information is primarily needed to maintain the security and
operation of our Services, and for our internal analytics and reporting
purposes.
Like many businesses, we also collect
information through cookies and similar technologies.
The information we collect
includes:
Log and Usage Data. Log and usage data is
service-related, diagnostic, usage, and performance information our servers automatically
collect when you access or use our Services and which we record in log files. Depending on
how you interact with us, this log data may include your IP address, device information, browser
type, and settings and information about your activity in the Services(such as the date/time stamps associated with your usage, pages and files
viewed, searches, and other actions you take such as which features you use), device event
information (such as system activity, error reports (sometimes called "crash dumps"),
and hardware settings).
Device Data. We collect device data such as
information about your computer, phone, tablet, or other device you use to access the Services.
Depending on the device used, this device data may include information such as your IP
address (or proxy server), device and application identification numbers, location, browser type,
hardware model, Internet service provider and/or mobile carrier, operating system, and system
configuration information.
Location Data. We collect location data such as
information about your device's location, which can be either precise or imprecise. How much
information we collect depends on the type and settings of the device you use to access the
Services. For example, we may use GPS and other technologies to collect geolocation data that
tells us your current location (based on your IP address). You can opt out of allowing us to
collect this information either by refusing access to the information or by disabling your Location
setting on your device. However, if you choose to opt out, you may not be able to use certain
aspects of the Services.
In Short: We
may collect limited data from public databases, marketing partners, and other outside
sources.
In order to enhance our ability to provide relevant marketing,
offers, and services to you and update our records, we may obtain information about you from
other sources, such as public databases, joint marketing partners, affiliate programs, data
providers,and from other third parties. This information includes mailing addresses, job titles,
email addresses, phone numbers, intent data (or user behavior data),
Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles,
for purposes of targeted advertising and event promotion.<
/span>
2. HOW DO
WE PROCESS YOUR INFORMATION?
In Short: We process your
information to provide, improve, and administer our Services, communicate with you, for security
and fraud prevention, and to comply with law. We process
the personal information for the following purposes listed below. We may also process your information for other
purposes only with your prior explicit
consent.
We process your personal information for a variety of
reasons, depending on how you interact with our Services, including:
To facilitate account creation and authentication and
otherwise manage user accounts. We may process your information so you can create
and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user.
We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users.
We may process your information to respond to your inquiries and solve any potential
issues you might have with the requested service.
To send administrative information to you.
We may process your information to send you details about our products and services,
changes to our terms and policies, and other similar information.
To fulfill and
manage your orders. We may process your information to fulfill and
manage your orders, payments, returns, and exchanges made through the
Services.
To request feedback.
We may process your information when necessary to request feedback and to contact
you about your use of our Services.
To send you marketing and promotional
communications. We may process the personal information you send to us for our
marketing purposes, if this is in accordance with your marketing preferences. You can opt out of
our marketing emails at any time. For more information, see "WHAT
ARE YOUR PRIVACY RIGHTS?" below.
To protect our
Services. We may process your information as part of our efforts to keep our Services
safe and secure, including fraud monitoring and prevention.
To identify usage
trends. We may process information about how you use our Services to better
understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and
promotional campaigns. We may process your information to better understand how to
provide marketing and promotional campaigns that are most relevant to you.
To save or protect an
individual's vital interest. We may process your information when necessary to save or
protect an individual’s vital interest, such as to prevent harm.
Cold Outreach and Lead
Generation.Using publicly available
data to identify and contact potential clients.
AI Automation Improvement.Analyzing user data to enhance and personalize AI-powered tools and
workflows.
Service Security and Fraud
Prevention.Monitoring data to detect
and prevent unauthorized access and fraudulent activity.
Service Updates and Administrative
Communication.Sending notifications
about changes, maintenance, or important information regarding
services.
3. WHAT LEGAL BASES DO WE RELY
ON TO PROCESS YOUR INFORMATION?
In Short: We
only process your personal information when we believe it is necessary and we have a valid
legal reason (i.e., legal basis) to do so under applicable law, like with
your consent, to comply with laws, to provide you with services to enter into or fulfill our
contractual obligations, to protect your rights, or to fulfill our
legitimate business interests.
If you are located in the EU or UK, this section
applies to you.
The General Data
Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely
on in order to process your personal information. As such, we may rely on the following legal
bases to process your personal information:
Consent. We may process your information if
you have given us permission (i.e., consent) to use your personal information for a
specific purpose. You can withdraw your consent at any time. Learn more about
withdrawing your
consent.
Performance of a
Contract. We may process your personal information when we believe it is necessary
to fulfill our
contractual obligations to you, including providing our Services or at your request prior to
entering into a contract with you.
Legitimate
Interests. We may process your information when we believe it is reasonably
necessary to achieve our legitimate business interests and those interests do not outweigh your
interests and fundamental rights and freedoms. For example, we may process your personal
information for some of the purposes described in order to:
Send users information about
special offers and discounts on our products and services
Analyze how our
Services are used so we can improve them to engage and retain users
Understand how our users use
our products and services so we can improve user experience
Grow our
client base by offering relevant AI automation and CRM
services.
Provide
better, more effective services that meet client needs.
Protect
our platform, clients, and data from harm.
Keep
clients informed and ensure smooth service delivery.
Legal
Obligations. We may process your information where we believe it is necessary for
compliance with our legal obligations, such as to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal rights, or disclose your information as evidence
in litigation in which we are involved.
Vital Interests.
We may process your information where we believe it is necessary to protect your vital interests
or the vital interests of a third party, such as situations involving potential threats to the safety of
any person.
If you are located in Canada, this section applies to
you.
We may process your information if you have given us specific permission (i.e., express
consent) to use your personal information for a specific purpose, or in situations where your
permission can be inferred (i.e., implied consent). You can withdraw
your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process
your information without your consent, including, for example:
If collection is clearly in the
interests of an individual and consent cannot be obtained in a timely
way
For investigations and fraud detection and prevention
For business transactions
provided certain conditions are met
If it is contained in a witness
statement and the collection is necessary to assess, process, or settle an insurance
claim
For identifying injured, ill, or
deceased persons and communicating with next of kin
If
we have reasonable grounds to believe an individual has been, is, or may be victim of financial
abuse
If it is reasonable to expect
collection and use with consent would compromise the availability or the accuracy of the
information and the collection is reasonable for purposes related to investigating a breach of an
agreement or a contravention of the laws of Canada or a province
If
disclosure is required to comply with a subpoena, warrant, court order, or rules of the court
relating to the production of records
If it was produced by an individual in the course of their
employment, business, or profession and the collection is consistent with the purposes for which
the information was produced
If
the collection is solely for journalistic, artistic, or literary purposes
If
the information is publicly available and is specified by the regulations
We may
disclose de-identified information for approved research or statistics projects, subject to ethics
oversight and confidentiality commitments
4. WHEN AND
WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We
may share information in specific situations described in this section and/or with the following
categories of third parties.
Vendors, Consultants, and Other Third-Party Service
Providers. We may share your data with third-party vendors, service providers,
contractors, or agents ("third
parties") who perform services for us or
on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are
designed to help safeguard your personal information. This means that they cannot do anything
with your personal information unless we have instructed them to do it. They will also not share
your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the
period we instruct.
The categories of third parties we may share personal information with
are as follows:
AI
Platforms
Cloud Computing
Services
Communication & Collaboration
Tools
Data Analytics
Services
Data Storage Service
Providers
Finance & Accounting
Tools
Payment
Processors
Performance Monitoring
Tools
Website Hosting Service
Providers
Sales & Marketing
Tools
We also may need to share your personal information in the
following situations:
Business Transfers. We may share or
transfer your information in connection with, or during negotiations of, any merger, sale of
company assets, financing, or acquisition of all or a portion of our business to another
company.
When we use Google Maps Platform APIs.
We may share your information with certain Google Maps Platform APIs (e.g., Google Maps
API, Places API). We use certain Google Maps Platform APIs to retrieve certain
information when you make location-specific requests. This includes:contact information; and other similar information. A full list of what we use
information for can be found in this section and in the previous section titled "HOW DO WE PROCESS YOUR
INFORMATION?" Google Maps
uses GPS, Wi-Fi, and cell towers to estimate your location. GPS is accurate to about 20 meters,
while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors.
This data helps Google Maps provide directions, but it is not always perfectly precise. The Google Maps
Platform APIs that we use store and access cookies and other information on your devices. If
you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein,
and Norway) or the United Kingdom, please take a look at our Cookie Notice.
Business
Partners. We may share your information with our business partners to offer you
certain products, services, or promotions.
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div style="line-height: 1.5;">
5. DO WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?
In Short: We
may use cookies and other tracking technologies to collect and store your
information.
We may
use cookies and similar tracking technologies (like web beacons and pixels) to gather
information when you interact with our Services. Some online tracking technologies help us
maintain the security of our Services and your
account, prevent crashes, fix bugs, save your
preferences, and assist with basic site functions.
We also permit third parties and service providers to use online
tracking technologies on our Services for analytics and advertising, including to help manage
and display advertisements, to tailor advertisements to your interests, or to send abandoned
shopping cart reminders (depending on your communication preferences). The third parties and
service providers use their technology to provide advertising about products and services
tailored to your interests which may appear either on our Services or on other
websites.
To the extent these online tracking technologies are deemed to
be a "sale"/"sharing" (which includes targeted advertising, as defined under
the applicable laws) under applicable US state laws, you can opt out of these online tracking
technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE
SPECIFIC PRIVACY RIGHTS?"
Specific information about how we use such technologies and
how you can refuse certain cookies is set out in our Cookie Notice.
Google
Analytics
We may share your
information with Google Analytics to track and analyze the use
of the Services. The Google Analytics Advertising
Features that we may use include: Remarketing with Google
Analytics, Google Display Network Impressions Reporting and Google Analytics Demographics
and Interests Reporting. To opt out of
being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features
through Ads
Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of
Google, please visit the Google
Privacy & Terms page.
6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED
PRODUCTS?
In
Short: We offer products,
features, or tools powered by artificial intelligence, machine learning, or similar
technologies.
As part of our Services, we offer products, features, or tools
powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools
are designed to enhance your experience and provide you with innovative solutions. The terms
in this Privacy Notice govern your use of the AI Products within our Services.
Use of AI Technologies
We provide the AI Products through third-party
service providers ("AI Service Providers"), including ElevenLabs, OpenAI and multiple others. As outlined in this Privacy Notice, your input, output, and
personal information will be shared with and processed by these AI Service Providers to enable
your use of our AI Products for purposes outlined in "WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?" You must not
use the AI Products in any way that violates the terms or policies of any AI Service
Provider.
Our AI Products
Our AI Products are designed for the following
functions:
AI
automation
AI applications
AI
bots
AI deployment
AI
development
AI document
generation
AI insights
Natural language
processing
Text analysis
Image
generation
Video generation
How We Process Your Data Using
AI
All personal information processed using our AI Products is
handled in line with our Privacy Notice and our agreement with third parties. This ensures high
security and safeguards your personal information throughout the process, giving you peace of
mind about your data's safety.
How to Opt
Out
We believe in giving you the power to decide how your data is
used. To opt out, you can:
Log in to your account settings and
update your user account
Contact us using the contact
information provided
7. IS YOUR INFORMATION
TRANSFERRED
INTERNATIONALLY?
In Short: We
may transfer, store, and process your information in countries other than your
own.
Our servers are located in the United
States. If you are accessing our Services from outside the United
States, please be aware that your information may be transferred to,
stored by, and processed by us in our facilities and in the facilities of the third parties with whom
we may share your personal information (see "WHEN
AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?" above), in the United
States, and other
countries.
If you are a resident in the European Economic Area (EEA),
United Kingdom (UK), or Switzerland, then these countries may not necessarily have data
protection laws or other similar laws as comprehensive as those in your country. However, we
will take all necessary measures to protect your personal information in accordance with this
Privacy Notice and applicable law.
European Commission's Standard Contractual
Clauses:
We have
implemented measures to protect your personal information, including by using the European
Commission's Standard Contractual Clauses for transfers of personal information between our
group companies and between us and our third-party providers. These clauses require all
recipients to protect all personal information that they process originating from the EEA or UK in
accordance with European data protection laws and regulations.Our Standard Contractual Clauses
can be provided upon request.We have implemented similar
appropriate safeguards with our third-party service providers and partners and further details
can be provided upon request.
8. HOW LONG DO WE KEEP YOUR
INFORMATION?
In Short: We
keep your information for as long as necessary to fulfill the
purposes outlined in this Privacy Notice unless otherwise required by
law.
We will
only keep your personal information for as long as it is necessary for the purposes set out in this
Privacy Notice, unless a longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in
this notice will require us keeping your personal information for longer than twelve (12) months past the
termination of the user's account.
When we have no ongoing legitimate business need to process
your personal information, we will either delete or anonymize such
information, or, if this is not possible (for example, because your personal information has been
stored in backup archives), then we will securely store your personal information and isolate it
from any further processing until deletion is possible.
9. HOW DO
WE KEEP YOUR INFORMATION
SAFE?
In Short: We aim to protect
your personal information through a system of organizational
and technical security measures.
We have implemented appropriate and reasonable technical
and organizational security measures designed to protect the security of
any personal information we process. However, despite our safeguards and efforts to secure
your information, no electronic transmission over the Internet or information storage technology
can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information. Although we will do our best to
protect your personal information, transmission of personal information to and from our Services
is at your own risk. You should only access the Services within a secure environment.
10. DO WE COLLECT INFORMATION FROM
MINORS?
In Short: We
do not knowingly collect data from or market to children
under 18 years of age or the equivalent age as specified
by law in your jurisdiction.
We do not knowingly collect, solicit data from, or market to
children under 18 years of age or the equivalent age as
specified by law in your jurisdiction, nor do we
knowingly sell such personal information. By using the Services, you represent that you are at
least 18 or the equivalent age as specified by law in your
jurisdiction or that you are the parent or guardian
of such a minor and consent to such minor dependent’s use of the Services. If we learn that
personal information from users less than 18 years of age
or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and
take reasonable measures to promptly delete such data from our records. If you become aware
of any data we may have collected from children under age 18 or the equivalent age as specified by law in your
jurisdiction, please contact us at [email protected].
11. WHAT ARE YOUR PRIVACY
RIGHTS?
In Short:Depending on your state of residence in the US or in some regions, such as the
European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control
over your personal information.You may review,
change, or terminate your account at any time, depending on your country, province, or state of
residence.
In some regions (like the
EEA, UK, Switzerland, and Canada), you have certain
rights under applicable data protection laws. These may include the right (i) to request access
and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to
restrict the processing of your personal information; (iv) if applicable, to data portability; and (v)
not to be subject to automated decision-making. If a
decision that produces legal or similarly significant effects is made solely by automated means,
we will inform you, explain the main factors, and offer a simple way to request human
review. In certain circumstances, you may also
have the right to object to the processing of your personal information. You can make such a
request by contacting us by using the contact details provided in the section "HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with
applicable data protection laws.
Withdrawing your
consent: If we are relying on your consent to process your personal
information, which may be express and/or implied
consent depending on the applicable law, you
have the right to withdraw your consent at any time. You can withdraw your consent at any time
by contacting us by using the contact details provided in the section "HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?" below or
updating your preferences.
However, please note that this will not affect the lawfulness of
the processing before its withdrawal nor, when applicable
law allows, will it affect the processing of your
personal information conducted in reliance on lawful processing grounds other than
consent.
Opting out of marketing and promotional
communications:You can unsubscribe from our marketing and
promotional communications at any time by clicking on
the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting
us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?" below. You will then be removed from the marketing
lists. However, we may still communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of your account, to respond to
service requests, or for other non-marketing purposes.
No mobile information will be shared with third parties or
affiliates for marketing or promotional purposes. Information sharing to subcontractors in support
services, such as customer service, is permitted. All other use case categories exclude text
messaging originator opt-in data and consent; this information will not be shared with third
parties.
Account
Information
If you would at any time like to review or change the information in your
account or terminate your account, you can:
Log in to your account settings and update your user
account.
Contact us using the contact information
provided.
Upon your request to terminate
your account, we will deactivate or delete your account and information from our active
databases. However, we may retain some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our legal terms and/or comply with applicable
legal requirements.
Cookies and similar
technologies: Most Web browsers are set to accept cookies by default. If you
prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If
you choose to remove cookies or reject cookies, this could affect certain features or services of
our Services.
If you have questions or comments about your privacy rights, you may
email us at [email protected].
12.
CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers and some mobile operating
systems and mobile applications include a Do-Not-Track ("DNT") feature
or setting you can activate to signal your privacy preference not to have data about your online
browsing activities monitored and collected. At this stage, no uniform technology standard for
recognizing
and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser
signals or any other mechanism that automatically communicates your choice not to be tracked
online. If a standard for online tracking is adopted that we must follow in the future, we will
inform you about that practice in a revised version of this Privacy
Notice.
California law requires us to let you know how we respond to
web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or
honoring
DNT signals, we do not respond to them at this time.
13. DO
UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In Short: If
you are a resident of California, Colorado, Connecticut,
Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New
Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details
about the personal information we maintain about you and how we have processed it, correct
inaccuracies, get a copy of, or delete your personal information. You may also have the right to
withdraw your consent to our processing of your personal information. These rights may be
limited in some circumstances by applicable law. More information is provided
below.
Categories of
Personal Information We Collect
The table below shows the categories of personal information
we have collected in the past twelve (12) months. The table includes illustrative examples of
each category and does not reflect the personal information we collect from you. For a
comprehensive inventory of all personal information we process, please refer to the section "WHAT
INFORMATION DO WE COLLECT?"
Category
Examples
Collected
<
/thead>
A. Identifiers
Contact
details, such as real name, alias, postal address, telephone or mobile contact number, unique
personal identifier, online identifier, Internet Protocol address, email address, and account
name
YES
B. Personal information as defined in the California Customer
Records statute
Name, contact information, education,
employment, employment history, and financial
information
YES
C. Protected classification characteristics under state or federal
law
Gender, age, date of birth, race and ethnicity, national origin,
marital status, and other demographic data
YES
D. Commercial information
Transaction information, purchase history, financial details, and
payment information
YES
E. Biometric information
Fingerprints and
voiceprints
NO
F. Internet or other similar network
activity
Browsing history, search history, online behavior,
interest data, and interactions with our and other websites, applications, systems, and
advertisements
YES
G. Geolocation data
Device
location
YES
H. Audio, electronic, sensory, or similar
information
Images and audio, video or call recordings created in
connection with our business activities
YES
I. Professional or employment-related
information
Business contact details in order to provide you our Services at
a business level or job title, work history, and professional qualifications if you apply for a job
with us
YES
J. Education Information
Student
records and directory information
NO
K. Inferences drawn from collected personal
information
Inferences drawn from any of the collected personal information
listed above to create a profile or summary about, for example, an individual’s preferences and
characteristics
YES
L. Sensitive personal Information
Account login information and financial information including
account access details
YES
We only collect sensitive personal information, as
defined by applicable privacy laws or the purposes allowed by law or with your consent.
Sensitive personal information may be used, or disclosed to a service provider or contractor, for
additional, specified purposes. You may have the right to limit the use or disclosure of your
sensitive personal information. We do not collect or
process sensitive personal information for the purpose of inferring characteristics about
you.
We may also collect other personal information outside of these
categories through instances where you interact with us in person, online, or by phone or mail in
the context of:
Receiving help through our customer support channels;
Participation in customer
surveys or contests; and
Facilitation in the delivery of our
Services and to respond to your inquiries.
We will use and retain the collected personal information as
needed to provide the Services or for:
Category A - 12 months after account termination
Category B - 12 Months after Account Termination
Category C - 12 Months after account
termination
Category D - As
long as the user has an account with us
Category F - 1
year
Category G - 6
months
Category H - 6
months
Category I - As
long as the user has an account with us
We collect
and share your personal information through:
Targeting cookies/Marketing cookies
Social media cookies
Beacons/Pixels/Tags
Click redirects: GoHighLevel tracking
links,Bitly links,UTM campaign URLs and Email or SMS
campaign redirect links.
Will your information be shared with anyone
else?
We may
disclose your personal information with our service providers pursuant to a written contract
between us and each service provider. Learn more about how we disclose personal information
to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?"
We may use your personal information for our own business
purposes, such as for undertaking internal research for technological development and
demonstration. This is not considered to be "selling" of your personal information.
We have not sold or shared any
personal information to third parties for a business or commercial purpose in the preceding
twelve (12) months. We have disclosed the following categories of
personal information to third parties for a business or commercial purpose in the preceding
twelve (12) months:
You have rights under certain US state data protection laws.
However, these rights are not absolute, and in certain cases, we may decline your request as
permitted by law. These rights include:
Right to know
whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with
us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for
targeted advertising (or sharing as defined under
California’s privacy law), the sale of personal
data, or profiling in furtherance of decisions that produce legal or similarly significant effects
("profiling")
Depending upon the state where you live, you may also have
the following rights:
Right to
access the categories of personal data being processed (as permitted by applicable law,
including the privacy law in Minnesota)
Right to
obtain a list of the categories of third parties to which we have disclosed personal data (as
permitted by applicable law, including the privacy law in
California, Delaware, and Maryland)
Right to
obtain a list of specific third parties to which we have disclosed personal data (as permitted by
applicable law, including the privacy law in Minnesota and
Oregon)
Right to
review, understand, question, and correct how personal data has been profiled (as permitted by
applicable law, including the privacy law in Minnesota)
Right to
limit use and disclosure of sensitive personal data (as permitted by applicable law, including the
privacy law in California)
Right to
opt out of the collection of sensitive data and personal data collected through the operation of a
voice or facial recognition feature (as permitted by applicable law, including the privacy law in
Florida)
How to Exercise Your
Rights
To exercise these rights, you can contact us by submitting a data subject access
request, by
emailing us at [email protected], by calling
toll-free at +1 313-631-3707, or by referring
to the contact details at the bottom of this document.
Under certain US state data protection laws, you
can designate an authorized agent to make a request on your behalf. We may deny
a request from an authorized agent that does not submit proof that they have been
validly authorized to act on your behalf in accordance with applicable
laws.
Request
Verification
Upon receiving your
request, we will need to verify your identity to determine you are the same person about whom
we have the information in our system. We will only use personal information provided in your
request to verify your identity or authority to make the request. However, if we cannot verify your
identity from the information already maintained by us, we may request that you provide
additional information for the purposes of verifying your identity and for security or
fraud-prevention purposes.
If you submit the request through an authorized
agent, we may need to collect additional information to verify your identity before processing
your request and the agent will need to provide a written and signed permission from you to
submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to
take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will
inform you in writing of any action taken or not taken in response to the appeal, including a
written explanation of the reasons for the decisions. If your appeal is denied, you may submit a
complaint to your state attorney general.
California "Shine
The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to
request and obtain from us, once a year and free of charge, information about categories of
personal information (if any) we disclosed to third parties for direct marketing purposes and the
names and addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like to make
such a request, please submit your request in writing to us by using the contact details provided
in the section "HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?"
14. DO WE MAKE UPDATES TO
THIS NOTICE?
In Short: Yes, we will
update this notice as necessary to stay compliant with relevant
laws.
We may
update this Privacy Notice from time to time. The updated version will be indicated by an
updated "Revised" date at the top of this Privacy Notice. If we make
material changes to this Privacy Notice, we may notify you either by prominently posting a
notice of such changes or by directly sending you a notification. We encourage you to review
this Privacy Notice frequently to be informed of how we are protecting your
information.
15. HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
If you have questions or comments about this
notice, you may email us at [email protected] or contact us by post
at:
127 Digital
Solutions
344 N Old
Woodward
Birmingham, MI48009
United States
16. HOW CAN
YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
Based on the applicable
laws of your country or state of residence in the US, you may have the right to request access to the personal information we
collect from you, details about how we have processed it, correct inaccuracies, or delete your
personal information. You may also have the right to withdraw your consent to our processing of your personal
information. These rights may be limited in some circumstances by applicable law. To request to
review, update, or delete your personal information, please fill out and submit a data subject access request.
