All communications regarding this policy should be directed to firstname.lastname@example.org
1. Information we collect.
Log data: When you visit our Site, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.
Device data: We may also collect data about the device you’re using to access our Site. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
Personal information: In the course of providing services to you, we may ask for personal information, such as your name, email address, date of birth, phone number, mailing address, and payment information.
2. Legal bases for processing.
We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so. These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:
it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services to you, and to protect our legal rights and interests;
you give us consent to do so for a specific purpose (for example, you might consent to us sending you a newsletter); or
we need to process your data to comply with a legal obligation.
- Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).
- We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. If necessary, we may retain your personal information in order to comply with a legal obligation.
Membersy takes the security of your personal information very seriously. We take precautions to ensure that the information we collect is secure and inaccessible to anyone outside of our organization. We use the following access safeguards to prevent unauthorized access to information stored on or transmitted by our systems:
internal access controls (so only limited personnel have access to your information);
training personnel on relevant security and compliance policies;
regularly backing up servers that store visitor information to protect against loss; and
securing information using security technologies like secure socket layer (SSL), encryption, firewalls, and secure passwords.
4. Collection and use of information..
We may collect, hold, use and disclose information for the following purposes (and personal information will not be further processed in a manner that is incompatible with these purposes):
to fulfill your requests for information, products and/or services;
to enable you to customize or personalize your experience of our Site;
to enable you to access and use our Site, associated applications and associated social media platforms;
to contact and communicate with you;
for internal recordkeeping and administrative purposes;
for analytics, market research and business development, including to operate and improve our Site and associated applications;
for advertising and marketing, including to customize the advertising and content you see, send you promotional information about our products and services and information about third parties that we consider may be of interest to you; and
to comply with our legal obligations and resolve any disputes that we may have.
We limit access to your personal information within our company to employees who we believe reasonably need to come into contact with that information in order to provide products or services to you or in order to do their jobs. Any information collected by Membersy is stored using security procedures and practices that we believe are appropriate to the nature of the information.
5. Disclosure of personal information to third parties.
We may disclose personal information to the following in accordance with applicable law:
third party service providers for the purpose of enabling them to provide their services, including IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
our employees, contractors and/or related entities; and
courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights.
6. Your rights and controlling your personal information.
Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our Site or products and services.
Access and data portability: You may request a copy of the personal information that we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Notification of data breaches: We will comply with laws applicable to us with respect to any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact one or more regulatory bodies or data protection authorities as may be appropriate.
Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us directly or opt-out using the opt-out facilities provided in the communication.
7. Business transfers.
In the event that we sell, divest or transfer the company (including any shares in the company) or any combination of its products, services, assets and/or businesses, your information may be among the data sold or transferred in the course of this type of transaction. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information in accordance with this policy.
8. Limits of our policy.
Our Site may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
9. Changes to this policy.
Information We Collect
Our Websites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the Websites collected the following categories of personal information from our consumers within the last 12 months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Membersy obtains the personal information listed above from the following categories of sources:
Directly from you (e.g., from forms you complete or products and services you purchase)
Indirectly from you (e.g., from observing your actions on our Websites)
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To send you up-to-date information regarding our products and your memberships.
To develop, maintain, provide, and personalize our Websites, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and resolve grievances, address your concerns, and monitor our own response system.
To help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Websites, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Membersy’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Membersy about users of our Websites is among the assets transferred.
Membersy will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice via updates to this privacy notice (the “Notice”).
Sharing Personal Information
Membersy may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
Contractors and ervice providers.
Subsidiaries and affiliates.
Third parties with whom we partner to offer products and services to you.
Regulatory agencies, when required.
Disclosures of Personal Information for a Business Purpose
In the preceding 12 months, Membersy has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
Contractors and service providers.
Subsidiaries and affiliates.
Third parties with whom we partner to offer products and services to you.
Regulatory agencies, when required.
Sales of Personal Information
Membersy does not sell your personal information. In the preceding 12 months, Membersy has not sold personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Membersy disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Membersy delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Comply with a legal or regulatory obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
- Phone: (877) 545-4188 (M-F, 8am-6pm CST)
- Email: email@example.com; or
811 Barton Springs Road, Suite 750
Austin, TX 78704
Attention: Member Services
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. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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. 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.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 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 prior to the 45-day expiration.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. We will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
The “Shine the Light” Law
In addition to your rights under the CCPA, California Civil Code Section 1798.83, or the “Shine the Light” law, permits any of our users who are California residents to request and receive, once a year, a notice describing the categories of personal customer information we share with unaffiliated third parties for their direct marketing purposes. The notice will identify the categories of information shared, the third parties and affiliates with which it was shared, and their names and addresses. If you are a California resident and would like a copy of the notice that the law requires, please submit a written request to: firstname.lastname@example.org . In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty days for a response.
Changes to Our Privacy Notice
Membersy reserves the right to amend this Notice at our discretion and at any time. When we make changes to this privacy Notice, we will post the updated Notice on the Websites and update the Notice’s effective date. Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Notice, the ways in which Membersy collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:
- Phone: (877) 545-4188 (M-F, 8am-6pm CST)
- Email: email@example.com
811 Barton Springs Road, Suite 750
Austin, TX 78704