Effective Date: December 30, 2019
- Collection of Information
- Use of Information
- Sharing of Information
- Social Sharing Features
- Data Privacy Officer
- Internet Technologies Used
- Children’s Privacy
- Links from our Services to Other Websites
- Your Choices
- Third Party Analytics and Services
- Your California Privacy Rights
- Changes to this Policy
- Contact Us
Collection of Information
We collect information when, for example, you use our website or mobile features, submit requests for information through us, or register for applications we support or promotions, events and newsletters we sponsor (together, “Services“) or otherwise provide us information about yourself. The type of information we collect may include:
- Information we may collect includes your name, postal and e-mail address, phone number, social media username(s), and any information you may share about your background, interests, and preferences. Examples of the information you may share with us include your age, gender, occupation, and education level.
- Transaction information we may collect includes, as applicable, the information you include on the lead forms you submit, the schools or programs you request information about, and your lead submission or application use history, if any.
- Login credentials, if any, we may collect include your user name, password, and other authentication data elements.
- Specifically in respect to our Attain™ application, school-, course- and study-specific information supported by the application, including by way of example, course and study schedules, attendance history and goal-related information, as well as location data (if allowed) and such additional data as you may affirmatively permit us to maintain.
Use of Information
The information we collect is generally used to provide you with the Services, personalize them to you and maintain and improve their quality, monitor and analyze your use, and understand your needs so that we can serve you better. From users who are required to login to gain access to particular features or Services, including our Attain application, we may collect and use usernames, passwords, and other login credentials to verify user authorization. We may also use your information to contact you about changes, additions, and updates to Service features and opportunities, as well as to provide any notices required by applicable law. If you prefer not to receive communications from us, we make it easy for you to let us know. You can contact us at any time via the process noted in Contact Us below to request an update to or removal of your personal information on file or modification of our use of your information (see Your Choices and, for California residents, Your California Privacy Rights, below).
Tracking Options and California Do Not Track Disclosures: Certain parts of our sites require cookies, and we may use them to deliver more relevant advertising and to link data collected across other devices you may use. You can adjust your settings to limit tracking or decline cookies, but as a result you may not be able to use certain features of our sites or take full advantage of all of our offerings. Please refer to your device or browser settings for more information on how to delete or decline cookies and control your tracking preferences. Our sites do not respond to do not track signals from most browsers.
Sharing of Information
We may share certain personal information you provide us outside of the ASD family. For example:
- We may permit certain trusted third parties to track usage and analyze data such as the source address of a page request, the related IP address or domain name, the date and time of the page request, the referring website (if any) and other parameters in the URL. This is collected in order to better understand our Service usage and enhance performance of our Services. We may also use third parties to host or operate various Service features, deploy emails, analyze data, provide search results and enable links among other things.
- We may also provide access to data that include your personal information in connection with a contemplated or actual banking, capitalization, insuring, sale or other strategic initiative or transaction affecting title in or ownership of all or part of our business or assets, including for the purposes of determining whether to proceed with the transaction or fulfilling any records or other reporting requirements to relevant third parties. In the event of any such transaction, our title in and/or possession of your personal information, among other things, may be transferred or assigned.
- We also may share your information when you specifically ask or authorize us to do so, for example, when you submit a request for more information about a particular school or program, when you use and are engaged on our Attain platform, or when we conclude disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, to enforce our agreements and policies, and where circumstances otherwise warrant doing so.
Social Sharing Features
We take robust technical and organizational measures to secure, administer and store your personal information to protect against its loss, misuse or alteration while under our control to reduce the risks of loss, unauthorized access, disclosure, and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls, and information access authorization controls. That said, data transmission over the Internet is not 100% secure. Although we use robust measures, which in no event are less than industry standard security measures, we do not guarantee against the loss, misuse or alteration of any information during its delivery or under our control. We thus urge you to always take care how you handle and disclose your personal information over the Internet. If you suspect that the security of your personal data has been compromised, please report your concerns to us via the process noted in the Contact Us section below. And of course, we will also notify the affected users and authorities as required by applicable law of a security incident without undue delay after becoming aware of the security incident.
Data Privacy Officer
We collect, process and store the personal information you provide us on servers located in the United States of America. In all cases, you are engaging with All Star Directories, Inc. We have appointed a data privacy officer who may be contacted via the contact information noted in the Contact Us section below to address your data privacy needs and answer related questions.
Internet Technologies Used
We are very sensitive to the issue of children’s privacy. Our Services are neither developed for, nor directed at, children under the age of consent according to applicable federal and state laws. If you believe your child has provided us with personal information, or otherwise registered with one of our Services and would like to have this information removed, please contact our data privacy officer via the process noted in the Contact Us section below for assistance.
Links from Our Services to Other Websites
Our Services may contain links to third-party owned or operated websites. When you access these external websites, the providers of the websites may have access to certain information about you. Please be aware that once you have left our Services, we are not responsible for the privacy practices or the content of any websites we do not control directly, and the collection, use, and disclosure of information about you by these entities will be subject to the privacy policies of those other websites.
Your Information. You have certain choices about how we use your personal information to communicate with you, to send you relevant information, how we provide you with Services, and whether you want to continue as a user of our Services.
You are responsible for providing truthful and accurate personal information when requesting a particular Service offering, if any, that requires such information. Please keep in mind that once you submit a Service request, you may not be able to change or remove the information once it has been processed and delivered to an intended destination that is beyond our control.
We will honor any regulatory right you might have to access, modify or delete your personal information. To request access, please contact us following the instructions in the Contact Us section below. Where you have a regulatory right to request access or request the modification or deletion of your personal information, we can still withhold that access or decline to modify or erase your personal information in accordance with applicable law.
Service Communications. You may opt out of receiving commercial communications from ASD by following the instructions in those communications or by contacting ASD at email@example.com. If you opt out of receiving commercial communications, we may still send you non-promotional emails that, for example, relate to your account or to Service alerts.
Location Information. You also have the ability to turn location-based services, if any, on and off by adjusting the settings of your Internet browser or mobile device, or by following the standard uninstall process and removing all ASD applications, if any, from your mobile device. Please note that should you elect to modify a location-based Service or remove an ASD application such as the Attain application, we will not be able to provide you the applicable Service.
Third Party Analytics
Your California Privacy Rights
Information We Collect
Our sites 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, all of which the CCPA defines as “personal information.” In particular, we collected the categories of personal information specified in Collection of Information above from consumers within the last twelve (12) months. We collected this personal information from you when as well as automatically when you use and interact with our Services, all as described in the Collection of Information and Internet Technologies Used sections above.
Use and Sharing of Personal Information
We may use, disclose or sell the personal information we collect for one or more of the business purposes set forth in the Use of Information, Sharing of Information and Social Sharing Features sections above. You may opt out from our further use or sale of your personal information (subject to certain exceptions) as described in the Opt Out section below.
Your Rights and Choices
The CCPA provides California consumers 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 we 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, we will disclose to you the following information if and to the extent it is available:
- The categories of personal information we have 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 disclosures, identifying the personal information categories that each category of recipient purchased; and
- Business purpose disclosures, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights. You have the right to request that we delete any of your personal information that we have in the immediately preceding 12-month period collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, 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 providers 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 Service features to identify and repair errors that impair existing functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with any applicable legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
You may only make a verifiable consumer request for access or data portability twice within any 12 consecutive-month period. The verifiable consumer request must:
- Provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person.
- Describe your request with sufficient detail to allow 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. 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 forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you in writing of the reason we need more time and the applicable extension period. 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. If applicable, our response will also explain the reasons we cannot comply with a request. 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 requests unless it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our sites and interacting with our Services. We will only use personal information provided in an opt-out request to review, verify and comply with the request.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as provided in the Contact Us section below.
All Star Directories, Inc.
101 Stewart Street, Suite 500
Seattle, WA 98101
Attention: Data Privacy Officer