We respect your privacy and are committed to protecting it through our compliance with this privacy policy ("Policy"). This Policy describes the types of information we may collect from you or that you may provide ("Personal Information") on the securecpg.com website ("Website" or "Service") and any of its related products and services (collectively, "Services"), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.
This Policy is a legally binding agreement between you ("User", "you" or "your") and SecureCPG Inc. ("SecureCPG", "we", "us" or "our"). If you are entering into this Policy on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this Policy, in which case the terms "User", "you" or "your" shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this Policy, you must not accept this Policy and may not access and use the Website and Services. By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy applies to information SecureCPG collects through the Website and Services, as well as other information provided to us online or offline by third parties; however, it does not apply to information collected from our employees, contractors, or vendors, nor the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
By accessing or using the Services, you consent to this Policy. If you do not agree with this Policy, please do not access or use the Services. Information gathered through the Services may be transferred, used, and stored in the United States or in other countries where our service providers or we are located. If you use the Services, you agree to the transfer, use, and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Services or SecureCPG are deemed to occur in the United States, where our servers are located.
You can access and use parts of the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website, you may be asked to provide certain Personal Information (for example, your name and e-mail address).
We receive and store any Personal Information you knowingly provide to us when you create an account, make a purchase, or fill any forms on the Website. When required, this information may include the following:
Some of the information we collect is directly from you via the Website and Services. However, we may also collect Personal Information about you from other sources such as social media platforms and our joint partners.
We also collect non-Personal Information relating to the Services, that is, information that does not personally identify an individual ("Non-Personal Information"). The Non-Personal Information we collect includes how you interact with the Services, information generally collected or "logged" by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using the Services.
Examples of the Non-Personal Information we collect are:
You can choose not to provide us with your Personal Information (subject to the controls offered by your personal device's operating system), but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us.
We will not use Non-Personal Information to try to identify you, and if we associate any Non-Personal Information with information that personally identifies you, then we will treat it as Personal Information. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather Personal Information and Non-Personal Information.
Information collected by the Services may be collected by us or one of the third parties we utilize in providing the Website and Services (as further described below).
We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child's Personal Information from our Services.
We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
We act as a data controller and a data processor when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Website and Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information.
We act in the capacity of a data processor in situations when you submit Personal Information through the Website and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller.
In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act; (ii) provision of information is necessary for the performance of this Policy with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
In case of Services requiring payment, you may need to provide your credit card details or other payment account information, which will be used solely for processing payments. We use third-party payment processors ("Payment Processors") to assist us in processing your payment information securely.
Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over a SSL secured communication channel and is encrypted and protected with digital signatures, and the Website and Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.
Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. Therefore, Personal Information received by a Payment Processors may be used for its own purposes, including compliance with legal and audit obligations. The Payment Processors' use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.
We may disclose your Personal Information to third parties as described below.
We may disclose Personal Information to provide the Website, Services, or when you authorize or instruct us to do so, for example, when you use the Services to submit content or profile information.
Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your Personal Information and Non-Personal Information with our affiliates, contracted companies, and service providers (collectively, "Service Providers") we rely upon to assist in the operation of the Website and Services available to you (such as processing of payments, provision of data storage, hosting of our Website, marketing of our products and services, and conducting audits) and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.
We may also disclose Personal Information and Non-Personal Information to Online Tool Providers. By "Online Tool Provider" we mean a licensor of software that we include in, or use with, the Services, including an API or SDK, that provides a specialized function or service to us and that requires the transmission of Personal Information and/or Non-Personal Information to the Online Tool Provider. Online Tool Providers may have the right to use Personal Information and Non-Personal Information about you for their own business purposes. Use and disclosure of Personal Information and Non-Personal Information by an Online Tool Provider is described in its privacy policy.
We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Website or Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements, an enforceable governmental request subpoena or similar legal process, (c) protect the rights, property or safety of us, our users or other third parties, (d) submit insurance claims, cooperate with insurance investigations, and fulfil insurance subrogation activities, (e) prevent a crime or protect national security, or (f) detect, prevent or otherwise address fraud, security or technical issues.
Finally, we reserve the right to transfer information (including your Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the Services, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example, via email or by posting notice on our website.
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, as long as your user account remains active, to enforce our Policy, resolve disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted.
Consumers residing in California are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act ("CCPA"). If you are a California resident, this section applies to you.
In addition to the rights as explained in this Policy, California residents who provide Personal Information as defined in the statute to obtain Services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the categories and specific pieces of Personal Information we have collected and disclosed.
Furthermore, California residents have the right to request deletion of their Personal Information or opt-out of the sale of their Personal Information which may include selling, disclosing, or transferring Personal Information to another business or a third party for monetary or other valuable consideration. To do so, simply contact us. We will not discriminate against you if you exercise your rights under the CCPA.
Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.
You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
Our Website and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity such as how often Users visit our Website and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the performance and improve our Website and Services.
You may request access to your Personal Information by sending an email to russ@securecpg.com. We will try to locate and provide you with your Personal Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. But, in either case, we may need to retain it for legal reasons or for legitimate business purposes. You may also remove any content that you post to the Website or Services using the deletion or removal options within the Website or Services. However, we (and you) are not able to control information that you have already shared with other users or made available to third parties through the Website or Services.
If you need further assistance with removing any content you posted through the Website or Services, you can email us at russ@securecpg.com. Removal of your posted content may not ensure complete or comprehensive removal from our computer systems.
We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. We may also require you to verify your identity to our satisfaction before providing you with access to Personal Information.
Please be aware that if you request us to delete your Personal Information, you may not be able to continue to use the Website or Services. Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. Please note that it may take up to ten (10) business days for your opt-out request to be processed. However, even if you opt out of marketing e-mails, you will continue to receive essential transactional emails, such as notices about your account and confirmations of transactions you have requested.
We may engage in affiliate marketing and have affiliate links present on the Website and Services for the purpose of being able to offer you related or additional products and services. If you click on an affiliate link, a cookie will be placed on your browser to track any sales for purposes of commissions.
The Website and Services contain links to other third-party sites, services, apps or resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy or security practices or policies of such third parties. Accordingly, we encourage you to be aware when you leave the Website and Services and to read the privacy and security policies and terms of service of such third parties so that you understand how they may collect, use, share and protect your information.
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.
We restrict access to Personal Information in our possession to our employees, Service Providers, and Online Tool Providers who need to know that information in order to operate, develop, improve or support our Website and Services.
We reserve the right to modify or update this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the top of this page. You can always check the "Last Updated" date at the top of this document to see when the Policy was last changed. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
IF YOU DO NOT AGREE TO CHANGES TO THIS POLICY, YOU MUST STOP USING THE SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES (WHICH IS THE "LAST UPDATED" DATE OF THIS POLICY).
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.
If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:
https://securecpg.com/contact-us/
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.