Data Privacy Notice
Last updated March 2020
This is the Data Privacy Notice (“Privacy Notice”) of OnPoint Global, LLC and certain of its affiliate and subsidiary entities (“OnPoint” or the “Company”). We maintain several websites to provide our products and services to you. Click HERE to see a list of our websites. These websites may ask for and collect your personal information in order to provide you with our services, enhance your experience, and provide you with other relevant information about our offerings. This Privacy Notice applies to activities the Company engages in on its websites and activities that are offline or unrelated to its websites, as applicable. We are providing this notice to explain our information practices and the choices you can make about the way your information is collected and used.
This Privacy Notice sets forth the principles that govern our treatment of personal information. We expect all employees and those with whom we share personal information to adhere to this Privacy Notice.
The Company is committed to protecting the information that our customers, employees, suppliers, and others have entrusted to us.
This Privacy Notice applies to all personal information collected by OnPoint, relating to all customers, employees, suppliers, and others who do business with the Company.
PERSONAL INFORMATION WE COLLECT AND USE
Personal Information You Provide
We only collect personal information that you provide to us, or that we are authorized to obtain by you or by law. The types of personal information we collect from you will depend on how you are interacting with us using our website and services. For example, we may collect different information from you when you purchase concierge services from us, or if you ask us a question. Depending on how you interact with our websites, we may have collected the following categories of personal information from you within the past 12 months:
- Identifiers, such as your name, postal address, Internet Protocol address, email address, Social Security number, driver’s license number, or other similar identifiers.
- Personal Information Subject to Cal. Civ. Code § 1798.80(e), including your name, address, telephone number, car insurance information, driver’s license or state identification card number, car insurance policy number, credit or debit card number and security code. Some personal information included in this category may overlap with other categories.
- Protected Classifications, including your age and date of birth.
- Online Activity, including information on your interaction with a website, application, or advertisement, your Internet Protocol (IP) address, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We do not knowingly collect any personal information from individuals under 18 years of age, and therefore do not use or disclose it to third parties.
HOW WE MAY USE PERSONAL INFORMATION
Your privacy is important to us. We collect and use information we need to do our business, including providing you with the services and experiences you expect from us. When we collect and use your information, we take your privacy and security very seriously.
We collect personal information to provide services to you. We will use the information provided by you or on your behalf to provide the requested services, such as our different concierge assistance services. Specifically, we may use your personal information for the following purposes:
- To respond to your questions, requests, or communications, including any feedback or requests relating to our products and services;
- To provide you with services or further information about your service, including but not limited to concierge assistance services and information about your services;
- To operate, evaluate, and improve our business, including improving and personalizing the experience for you and others, to complete and maintain records of transactions with individual customers following use of services;
- Data Analytics to audit, research, and conduct analysis in order to maintain and improve our services and to protect people who use our services;
- For safety and security, by making sure third parties protect your information, monitoring the technical functioning and security of our network;
- For legal and compliance, including complying with applicable laws, regulations, and legal obligations; and
- To protect the rights or property of the Company, its employees, and people who use its services.
COOKIES AND SIMILAR TECHNOLOGIES
A “cookie” is a small text file that websites send to your computer or device other Internet-connected device to identify your browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
We use these automated technologies to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner includes information on your interaction with a website, application, or advertisement, your Internet Protocol (IP) address, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. Our websites use first-party cookies (served directly by our website domain when you visit our websites) and third-party cookies (served by a third-party website when you visit our websites and our marketing partners’ websites).
Behavioral Tracking/Third Party Cookies
We allow third party vendors and advertisers to set their own cookies on and through our websites. We have no control over the practices of those third parties and are not responsible for their technology or tracking. We encourage you to review the policies of such persons or entities on their websites.
We use third-party analytics services on our websites, including Google Analytics. To learn more about Google Analytics, visit: https://policies.google.com/technologies/partner-sites.
We use AdWords Remarketing through Google which connects the activity on our websites with the AdWords advertising network and the DoubleClick cookie to serve you with relevant advertising material when you leave our websites. That cookie collects information about your browsing history. To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en.
Your Internet browser may let you restrict or disable certain types of cookies. Without cookies, you may not be able to use all of the options on our websites.
Some web browsers allow you to turn on Do Not Track (“DNT”), which sends signals to websites you visit, telling those sites that you do not want your online activities to be tracked. Our websites currently are not designed to respond to DNT signals received from web browsers.
Sometimes we use technology to collect the information that your browser uses to auto-fill. We use this to tell you if there is a mistake in registration or if the registration cannot be submitted. You can stop this technology by turning it off in your browser, and you will still be able to use all of the options on our websites.
HOW WE SHARE PERSONAL INFORMATION
We may share information about you to third parties as indicated below:
Affiliates: We may share your personal information with our affiliates and subsidiaries if we need to. If we share your information, we will share only the information that is necessary and we will take reasonable steps to make sure that third parties take prudent steps to protect your information.
Service Providers, Suppliers, Agents, and Business Partners: Other companies sometimes provide certain services to us or on our behalf (e.g., maintenance, IT support, human resources, analysis, development, security). Unless we tell you differently or as described elsewhere in this Privacy Notice, our service providers are not permitted to use your information except to assist us.
Compliance with Legal Obligations: We may need to disclose certain information to auditors, government authorities, law enforcement, regulatory agencies, our legal counsel, third party litigants and their counsel, or other authorized individuals in order to comply with laws that apply to us, or other legal obligations such as contractual requirements.
Changes in Business Structure/Ownership: We may disclose or transfer your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of the Company’s business, assets, or ownership interest (including any bankruptcy or similar proceedings).
We have not sold, shared or monetized any categories of personal information within the past 12 months.
Information We Disclose for a Business Purpose
In addition to the purposes described in this notice, we may use personal information listed below for business purposes.
- To provide you with products or services, including customer service, processing orders or transactions, verifying consumer information, and processing payments, use the following categories of information: identifiers, personal information subject to Cal. Civ. Code § 1798.80(e), protected classifications, and online activity.
- To improve our website, including responding to inquiries and improving functionality, we use the following categories of information: identifiers and online activity.
- To comply with your requests, including sending your information to third parties if you ask us to do so: identifiers, personal information subject to Cal. Civ. Code § 1798.80(e), protected classifications, and online activity.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We strive to take appropriate security measures to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are allowed to access personal information, and they may only access it for permitted business functions. We also use technology to protect your information, including encrypting sensitive personal information that is transferred to or from our systems.
While we cannot guarantee that loss, misuse, or alteration will never occur, we use reasonable efforts to prevent it. Please keep in mind that no method of storage or transmission over the Internet is completely secure, so your use of our services and provision of information to us is at your own risk.
Our websites may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those websites linked to our websites are not covered by this Privacy Notice. We are not responsible for the privacy policies of other websites to which our websites link.
CALIFORNIA PRIVACY NOTICE
Your Rights and Choices
For all personal information that we collect about you, you may have the following rights or choices that we will accommodate where your requests meet legal and regulatory requirements and do not risk making our other data less secure or changing our other data. You may also designate an authorized agent to make a request on your behalf.
Access, Erase: You may have the right to know what information is being collected about you, to access your personal information, to receive a copy of your information, and to know whether your personal information is disclosed and to whom. You also may request that we erase your information. If you have questions about your information or want to ask us to erase your information, please contact us using the methods in the Contact Us section below.
Data Portability: If you would like to request that we provide a copy of your information to you, please contact us using the methods in the Contact Us section below.
Non-Discrimination: You have the right not to receive discriminatory treatment by the Company because you exercise your privacy rights. If you have any questions, please contact us using the methods in the Contact Us section below.
How to Make a Request: If you would like to make a request, please click <<HERE>>, or select the “California Privacy R. Request” link on the bottom of any of our web pages.
Responding to Requests: Your request will be evaluated to determine whether the requested change meets legal regulatory requirements and does not risk making our other data less secure or changing our other data.
Verifying Your Identity: To protect you and your information, we may ask you to confirm certain information before we honor your request. For example, we may ask you to confirm your full birth date, physical address, telephone number, or email address, or to confirm what website you visited and when you last interacted with our websites. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us.
2019 Requests – In 2019, we did not receive any of the above requests.
CHANGES TO THIS NOTICE
We reserve the right to modify or change this Privacy Notice at any time. When we make a material change to this Privacy Notice, we will inform you by posting a prominent notice on the home page of our website or changing the date on this page noting when the Privacy Notice was last updated.
For questions regarding this Privacy Notice or to submit any of the requests mentioned above relating to your personal information, contact us using any of the following options: