Marketing Solutions 911
Privacy Policy
What we do (and don't do) with your
information...
PRIVACY POLICY
Last updated September 06, 2023
This
privacy notice for Marketing Solutions 911, LLC ("we,"
"us," or "our"), describes how and why we
might collect, store, use, and/or share ("process") your
information when you use our services ("Services"), such as
when you:
Questions
or concerns? Reading this privacy notice will help you understand your
privacy rights and choices. 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 ivan@marketingsolutions911.com.
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 in section 1 of this document.
Do we
process any sensitive personal information? We do not process
sensitive personal information.
Do we receive
any information from third parties? We do not receive
any information from third parties.
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
section 2 of this document.
In
what situations and with which parties do we share personal information? We
may share information in specific situations and with specific third
parties. Learn more about when and with whom we share your personal information in
section 4 of this document.
How do
we keep your information safe? We
have 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 in
section 7 of this document.
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 in
section 9 of this document.
How do
you exercise your rights? The easiest way to exercise your
rights is by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.
1. WHAT
INFORMATION DO WE COLLECT?
Personal
information you disclose to us
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:
Sensitive
Information. We do not process sensitive information.
Payment
Data. We may collect data necessary to process your payment
if you make purchases, such as your payment instrument number, and the security
code associated with your payment instrument. All payment data is stored
by Stripe, Paypal and Authorize.net. You may find their
privacy notice link(s) here: https://stripe.com/privacy, https://www.paypal.com/us/legalhub/privacy-full and https://www.authorize.net/about-us/dpa.html.
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:
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 may also process your information for
other purposes with your consent.
We
process your personal information for a variety of reasons, depending on how
you interact with our Services, including:
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:
Send users information about special offers and discounts
on our products and services
Develop and display personalized and relevant
advertising content for our users
Analyze how our Services are used so we can improve
them to engage and retain users
Support our marketing activities
Diagnose problems and/or prevent fraudulent activities
Understand how our users use our products and services so
we can improve user experience
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:
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 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 third parties we may share
personal information with are as follows:
Facebook
account, Instagram account, Google account, WordPress
account, LinkedIn account, PayPal account, Stripe
account and Twitter account
LiveChat and MyLiveChat
Facebook
Remarketing, Facebook Custom Audience, Google Ads
Remarketing , LinkedIn Website Retargeting and Google
Analytics Remarketing
Facebook
advertising, Instagram advertising, LinkedIn
advertising and Pinterest advertising
WordPress.com
Searchie.io
We also may
need to share your personal information in the following situations:
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
access or store information. Specific information about how we use such
technologies and how you can refuse certain cookies is set out in our Cookie
Notice.
6. 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 six (6) 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.
7. 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.
8. DO WE
COLLECT INFORMATION FROM MINORS?
In
Short: We do not knowingly collect data from or market
to children under 18 years of age.
We do
not knowingly solicit data from or market to children under 18 years of age. By
using the Services, you represent that you are at least 18 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 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, please contact us at ivan@marketingsolutions911.com.
9. WHAT
ARE YOUR PRIVACY RIGHTS?
In
Short: 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.
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; (vi) if applicable, to data portability; and (vii) not to
be subject to automated decision-making. 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.
If you
are located in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you
are located in Switzerland, you may contact the Federal
Data Protection and Information Commissioner.
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.
Account
Information
If you
would at any time like to review or change the information in your account or
terminate your account, you can:
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. You may also opt
out of interest-based advertising by advertisers on
our Services.
If you
have questions or comments about your privacy rights, you may email us at ivan@marketingsolutions911.com.
10.
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.
11. DO
CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In
Short: Yes, if you are a resident of California, you are granted specific
rights regarding access to your personal information.
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 using the contact information
provided below.
If you
are under 18 years of age, reside in California, and have a registered account
with Services, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please contact
us using the contact information provided below and include the email address
associated with your account and a statement that you reside in California. We
will make sure the data is not publicly displayed on the Services, but please
be aware that the data may not be completely or comprehensively removed from
all our systems (e.g., backups, etc.).
CCPA
Privacy Notice
The
California Code of Regulations defines a "resident" as:
(1)
every individual who is in the State of California for other than a temporary
or transitory purpose and
(2)
every individual who is domiciled in the State of California who is outside the
State of California for a temporary or transitory purpose
All
other individuals are defined as "non-residents."
If
this definition of "resident" applies to you, we must
adhere to certain rights and obligations regarding your personal information.
What
categories of personal information do we collect?
We
have collected the following categories of personal information in the past
twelve (12) months:
Category |
Examples |
Collected |
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 categories listed in the California Customer Records
statute |
Name,
contact information, education, employment, employment history, and financial
information |
YES |
C.
Protected classification characteristics under California or federal law |
Gender
and date of birth |
NO |
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 |
NO |
H.
Audio, electronic, visual, thermal, olfactory, or similar information |
Images
and audio, video or call recordings created in connection with our business
activities |
NO |
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 |
NO |
J.
Education Information |
Student
records and directory information |
NO |
K.
Inferences drawn from other 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 |
NO |
L.
Sensitive Personal Information |
NO |
We
will use and retain the collected personal information as needed to provide the
Services or for:
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:
How do
we use and share your personal information?
More
information about our data collection and sharing practices can be found in
this privacy notice.
You
may contact us by email at ivan@marketingsolutions911.com, or by
referring to the contact details at the bottom of this document.
If you
are using an authorized agent to exercise your right to opt out we
may deny a request if the authorized agent does not submit proof that
they have been validly authorized to act on your behalf.
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. Each service provider is
a for-profit entity that processes the information on our behalf, following the
same strict privacy protection obligations mandated by the CCPA.
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:
The
categories of third parties to whom we disclosed personal information for a
business or commercial purpose can be found under "Section 4 - WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".
Your
rights with respect to your personal data
Right
to request deletion of the data Request to delete
You
can ask for the deletion of your personal information. If you ask us to delete
your personal information, we will respect your request and delete your
personal information, subject to certain exceptions provided by law, such as
(but not limited to) the exercise by another consumer of his or her right to
free speech, our compliance requirements resulting from a legal obligation, or
any processing that may be required to protect against illegal activities.
Right
to be informed Request to know
Depending
on the circumstances, you have a right to know:
In
accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or
to re-identify individual data to verify a consumer request.
Right
to Non-Discrimination for the Exercise of a Consumer s Privacy Rights
We
will not discriminate against you if you exercise your privacy rights.
Right
to Limit Use and Disclosure of Sensitive Personal Information
We do
not process consumer's sensitive personal information.
Verification
process
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. These
verification efforts require us to ask you to provide information so that we
can match it with information you have previously provided us. For instance,
depending on the type of request you submit, we may ask you to provide certain
information so that we can match the information you provide with the
information we already have on file, or we may contact you through a
communication method (e.g., phone or email) that you have previously
provided to us. We may also use other verification methods as the circumstances
dictate.
We
will only use personal information provided in your request to verify your
identity or authority to make the request. To the extent possible, we will
avoid requesting additional information from you for the purposes of
verification. 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. We will delete such additionally provided
information as soon as we finish verifying you.
Other
privacy rights
To
exercise these rights, you can contact us by email at ivan@marketingsolutions911.com,
or by referring to the contact details at the bottom of this document. If you
have a complaint about how we handle your data, we would like to hear from you.
12. DO
VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In
Short: Yes, if you are a resident of Virginia, you may be
granted specific rights regarding access to and use of your personal
information.
Virginia
CDPA Privacy Notice
Under
the Virginia Consumer Data Protection Act (CDPA):
"Consumer" means
a natural person who is a resident of the Commonwealth acting only in an
individual or household context. It does not include a natural person acting in
a commercial or employment context.
"Personal
data" means any information that is linked or reasonably linkable to
an identified or identifiable natural person. "Personal
data" does not include de-identified data or publicly available
information.
"Sale
of personal data" means the exchange of personal data for monetary
consideration.
If
this definition "consumer" applies to you, we must adhere
to certain rights and obligations regarding your personal data.
The
information we collect, use, and disclose about you will vary depending on how
you interact with us and our Services. To find out more, please see the
following sections:
Your
rights with respect to your personal data
We
have not sold any personal data to third parties for business or commercial
purposes. We will not sell personal data in the future belonging to website
visitors, users, and other consumers.
Exercise
your rights provided under the Virginia CDPA
More
information about our data collection and sharing practices can be found in
this privacy notice.
You
may contact us by email at ivan@marketingsolutions911.com, or by referring
to the contact details at the bottom of this document.
If you
are using an authorized agent to exercise your rights, we may deny a
request if the authorized agent does not submit proof that they have
been validly authorized to act on your behalf.
Verification
process
We may
request that you provide additional information reasonably necessary to verify
you and your consumer's request. If you submit the request through
an authorized agent, we may need to collect additional information to
verify your identity before processing your request.
Upon
receiving your request, we will respond without undue delay, but in all cases,
within forty-five (45) days of receipt. The response period may be extended
once by forty-five (45) additional days when reasonably necessary. We will
inform you of any such extension within the initial 45-day response period,
together with the reason for the extension.
Right
to appeal
If we
decline to take action regarding your request, we will inform you of our
decision and reasoning behind it. If you wish to appeal
our decision, please email us at ivan@marketingsolutions911.com. Within
sixty (60) days of receipt of an appeal, 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 if denied, you may
contact the Attorney General to submit a complaint.
13. 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 and the updated
version will be effective as soon as it is accessible. 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.
14. HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?
If you
have questions or comments about this notice, you may contact our Data
Protection Officer (DPO), Ivan Divino, by email at ivan@marketingsolutions911.com, by
phone at 5634513948, or contact us by post at:
Marketing
Solutions 911, LLC
Ivan
Divino
350
Shrewsbury Ln
Dubuque,
IA 52003
United
States
15. HOW
CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You
have the right to request access to the personal information we collect from
you, change that information, or delete it. To request to review, update,
or delete your personal information, please contact us at ivan@marketingsolutions911.com
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