Effective: April 1, 2020
We commit to:
• Communicate our privacy practices in a manner that is easily accessible and clearly describes your choices;
• Offer you choices about how we may use your information for marketing purposes;
• Secure your information through the use of reasonable security measures; and
How We Collect Information
Examples of the categories of information that may be collected include personal information, demographic information, behavioral information, and indirect information. Sometimes we collect combinations of these types of information:
1. Personal Information. Is information that can be used to identify you or any other individual to whom the information may relate. This is information which you are prompted to provide to us. Examples of Personal Information are your name, address, phone number(s) and email address, employment status or other unique information about you which you provide to us during the registration process or through the course of communicating with us. We may collect this same information about other persons when you provide it to us.
2. Demographic Information. Is information that may or may not be unique to you in the sense that it refers to selected population characteristics. Examples of demographic information are your zip code, mobile phone carrier, age, gender, salary range, education, marital status, occupation, military service, industry of employment, personal and online interests.
3. Behavioral Information. Is information which is automatically collected when you use the Platform. Examples of behavior information are the areas of the Platform that you visit, what services you access, information about your computer hardware and software, including your IP address, geographic location, browser preference, operating system type, domain names, times that you access the internet, and other websites you have visited.
4. Third-Party Information. Is information we acquire from a third-party which may include personal, demographic, behavioral and indirect information. This may also include, but is not limited to, first party cookies, third-party cookies, anonymous cookies, persistent identifiers, email opt-in records and search engine keywords. We may also receive information third parties derive from government entities which publicly post your information. We have no access or control over these cookies and other tracking devices used by third parties including advertisers and networks, internet service providers, data analytics providers or social networks and platforms and we have no responsibility or liability for the policies and practices of these parties.
5. No Information Collected from Children. We do not knowingly collect information from anyone under the age of 16. If we obtain actual knowledge that we have collected Personal Information about a person under the age of 16, that information will be immediately deleted from the database.
How we Use Information
We will use and share the information collected with third parties and service providers to:
• Provide, maintain and improve the Platform;
• Provide and deliver the services you request, process transactions and send you related information, including confirmations, notifications, and invoices,
• Send you technical notices, updates, security alerts and support and administrative messages;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about products, services, offers, promotions, and rewards offered by us and others, and provide news and other information we think may be of interest to you;
• Monitor and analyze trends, usage and activities in connection with the Platform;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of us and others;
• Personalize and improve the Platform and provide advertisements, content or features that match user interests;
• Process and deliver contest entries and rewards;
• Link or combine with information we get from others to help understand your interests and provide you with better service and/or more targeted advertisements;
• Create business and marketing reports, and to show you more relevant advertising, whether through our own services and Platforms, or on third-party services and websites;
• Advertising agencies, advertising networks, and other companies who place ads on our Platform, may use their own cookies, web beacons, and other technology, to collect information about you and we do not control the use of such technology and have no responsibility for the use of such technology to gather information about you; and
• Carry out any other purpose for which the information was collected.
• Advertise to you directly and indirectly through partner networks, including appending and/or merging information for the purpose of advertising to you on our service as well as other services such as Facebook or Google.
We and our service providers may transfer your personal information to, or store or access it in, other countries where the laws may not provide levels of protection for your personal information equivalent to the protection provided by the laws of your home country.
Sharing of Information
We will not share your information except in the following circumstances or as otherwise specified in this Policy:
• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf, including providing you with the products and services you request, interact with, and to which you subscribe;
• In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect our property or rights or the safety of our employees, our customers, or other individuals;
• 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;
• With our affiliated entities for their own and/or their clients’ marketing activities.
Your profile information and any information you post in any public area of the Platform or submit for publication will be publicly available. This includes, for example, information contained in any quizzes or comments you post. Information about your achievements may also be publicly shared, such as through our leaderboard page.
Our Platform and email messages sometimes contain hypertext links to websites owned by third parties. We are not responsible for the privacy practices or the content of such other websites. These links are provided for your convenience and reference only. We do not operate or control any information, software, products or services available on these third-party websites. The inclusion of a link on our Platform does not imply any endorsement of the services, products or website, or its sponsoring organization
1. Right to Know About Personal Information Collected, Disclosed, or Sold
(a) You have the right to request that we disclose to you what categories and specific pieces of personal information we have collected. Personal information does not include: (a) publicly available information from government records; (b) de-identified or aggregated consumer information; (c) information excluded from the scope of the California Consumer Privacy Act (“CCPA”); and (d) personal Information covered by certain sector-specific privacy laws
(b) You may submit a verifiable consumer request to obtain the specific personal information we have collected about you either through our California Resident Portal form or you may email us at firstname.lastname@example.org.
(c) Upon receiving your information, the CCPA requires that we verify that you are the same consumer with whom we have the information in our systems. To verify your identity, we may require that you fill out the portal form in its entirety and/or verify your identity by clicking on a link we will send to the email address we have for you in our system.
(d) Personal information has been collected from the following categories of sources:
• Information collected directly and indirectly from your activity on our Platform and your interactions or communications with us. This includes your Personal Information provided by you in connection with obtaining a certain product or service offered by us or one of our network providers or advertisers.
• Information you provide us when you enter promotions or contests offered by us or our clients including networks and advertisers.
• Information you provide us through surveys, customer service correspondence, and general feedback.
• Analytics companies who provide demographic information such as gender, zip code, or any information that is not tied to your Personal Information. In addition, we may receive information about you from other online or offline sources, including third parties from whom we validate consumer self-reported information, and verify information we already have about you. This helps us to update, expand and analyze our records and provide products and services that may be of interest to you.
• We also collect information provided by service providers and other third parties as set out herein, our advertisers, ad networks and third-party technology companies.
(e) We disclose or share personal information for the following purposes:
• To obtain the services or products you have registered for on our Platform.
• To allow a third-party to market their products or services to you.
• To provide you with information, products or services that you request from us or resolve consumer concerns or request to opt-out of marketing.
• To provide you with notices concerning our products or services, or events or news, that may be of interest to you.
• To improve our Platform, products and services, and present its contents to you including testing, research, analysis and product development.
• To personalize your Platform experience and deliver content, product and service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law).
• To maintain the safety, security, and integrity of our Platform as well as products and services, databases and other technology assets, and business.
• To respond to government or law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a corporate restructuring, reorganization, dissolution, or other sale or transfer of some or all of our business or assets.
• As described to you when collecting your Personal Information or as otherwise set forth in CCPA.
(f) We disclose Personal Information to our Service Providers and the following categories of third parties:
• Our affiliated entities.
• Data aggregators.
• Ad networks.
• Third parties in connection with products or services we and/or third parties provide to you.
2. Right to Request Deletion of Personal Information.
(a) You have a right to request the deletion of your Personal Information if we have collected or maintained it in the past 12 months.
(b) You may submit a verifiable consumer request to delete your information by fully filling out the request form or contact us by email at or by telephone (605) 412-3174.
(c) Once we receive and confirm your verifiable consumer request, we will disclose to you the categories of Personal Information we collected about you and the categories of sources for the Personal Information we collected about you.
(d) This policy has disclosed our business or commercial purpose for collecting or selling that Personal Information and the categories of third parties with whom we shared that Personal Information.
3. Right to Opt-Out of the Sale of Personal Information. You have the right to opt-out of any sale of your Personal Information by us. If you are requesting a product or service, this is an exemption from this right, and we will process your request. However, you have the right to cease all further sale of your Personal Information.
4. Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights. You have a right not to receive discriminatory treatment by us for the exercise of these privacy rights conferred by the CCPA. As such, we will not deny you goods or services, charge you different prices or rates for goods or services, or deny you discounts or other benefits; nor will we provide you a different level or quality of goods or services or recommend a different level or quality of goods or services.
5. Authorized Agent. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.
6. Limitations on Requests. You may only make a verifiable consumer request for access twice within a twelve (12) month period. The verifiable consumer request must: (a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or your authorized agent; (b) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to you; (c) we cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you; (d) making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
7. Response Time and Response Format. We make every effort to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons why we cannot comply with a request, if applicable. We will provide our response in a manner that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance to you.
8. Changes to California Resident Privacy Notice. We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will enforce the terms of the new policy going forward. You will receive no other notice than an updated posting on this page. Please check back each time you use or visit our Platform.
How We Protect Your Information
We take our responsibility to secure the information we collect and maintain seriously. We use reasonable security, including technical, physical and administrative controls, to secure the information we collect and maintain. However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose information. You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorized interception of your personal information. You are responsible for the security of your information that you transmit to us or view, download, or otherwise access when using unencrypted, public or otherwise unsecured networks. For more information on things you can do to help protect the privacy of your own information, visit www.OnGuardOnline.gov.
Contact Information. If you have any questions or comments about this Privacy Statement, please do not hesitate to contact us at:
West Capital, LLC
401 East 8th Street
Suite 214 #1388
Sioux Falls, SD 57103
By Phone: (605) 412-3174