Please review the entire Policy to learn the types of User information SM gathers, how SM uses that User information, what User information is disclosed and to what third parties, and how SM safeguards User information.
Note to California Residents: California residents should review this Policy and the Additional Privacy Information For California Users section below, which contains information about California residents’ rights regarding Personal Information under the California Consumer Privacy Act of 2018 (“CCPA”).
This Policy applies to the Site and all products and services offered by SM. This Policy does not apply to any websites managed, maintained, and/or hosted by third parties not directly affiliated with SM that you may visit, e.g., via a link or plug-in provided through the Website or on a website maintained by any third party. SM does not control the privacy policies of other websites to which we may provide hyperlinks. We encourage you to learn more about the online privacy and data security policies of third party websites directly from such third parties, as their policies may differ from ours.
By submitting your information to us and by using this Site, you indicate that you have read, understood and consent to the Policy. You also indicate that you consent to SM’s use of your information as described in the Policy. If you do not consent, you should not use or access our Site. Your continued use of the Site following the posting of changes to this Policy indicates your acceptance of those changes.
Information We Collect:
SM collects and uses certain information from and about you, that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device, either voluntarily when you submit such information to us or automatically when you access or interact with our Site, as described below:
Personal information includes, but is not limited to, your full name, email address, mailing address, phone number, and any other information that could be used to personally identify you. Users can refuse to supply personal information, except that it may prevent them from engaging in certain Site related activities.
In the last twelve months, the personal information we have collected falls into the below categories:
Identifiers such as your name, postal address, phone number, online identifiers (like your username), email address, account name, national provider identification number, and IP address;
Personal Information Categories Listed In The California Customer Records Statute, such as your, employment history, credit card number or other financial information;
Internet Activity such as details of your visits to our Website and access and use of our App, information about your computer or mobile device, including your IP address and unique device identifier;
Geolocation Data about your physical location while using our Website or App;
Professional or Employment Information such as your employment history and current employer;
Inferential Information about your preferences and other interests.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information but is not considered personal information as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Policy.
How We Collect Your Information
We may collect personal information from Users in a variety of ways. This includes:
Information you Voluntarily Provide to Us
You may give us your personal information voluntarily when you visit our site, contact us, fill out a form, request information, and in connection with other activities, services, features or resources we make available.
Information We Collect Automatically When You Use Our Services
Usage data. We may also collect usage data about Users automatically whenever they interact with our Site. Usage data may include information such as the manufacturer and model of your device; your Internet Service Provider (ISP); your device’s Internet Protocol (“IP”) address (or other device identifier), browser type, and operating system; referring/exit pages; clickstream data; Website access times and dates, pages of the Website that you visit, the time spent on those pages, and information you search for on the Website; and other statistics.
Usage data is collected automatically by the Website’s servers and software. For example, because the Website automatically collects Usage Data for all Users that visit the Website, your Website session will be tracked. Some Web browsers may be configured to send Do Not Track signals to websites, or users may use similar mechanisms, to indicate a user’s preference that certain web technologies not be used to track the user’s online activity. The Website does not accept or process such Do Not Track signals or similar mechanisms.
Information We Collect From Third Parties
We may collect personal information from various third parties, including those listed below. The collection, use, and disclosure of personal information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the User. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.
Third Party Service Providers. We collect personal information from service providers including where we operate accounts on third-party platforms, such as call center and email platforms, payment processing, and social media platforms.
Third Party Advertising Partners. We collect personal information received from third party advertising partners, including partners who host and manage various advertisements and online forms where you can request additional information.
Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on Google Analytics, visit https://support.google.com/analytics.
Third Party Cookies. We may engage third-party service providers, including Google and Facebook, to serve ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies tags to track your online activities in order to deliver targeted advertising based on your interests.
How We Use Your Information:
SM, Inc uses the information we collect for the following purposes:
To administer and improve our Site (We continually strive to improve our website offerings based on the information and feedback we receive from you.)
To respond to correspondence from you
To provide additional information to users who have requested such through any of our various contact and/or registration forms
To provide SM’s products and services or process transactions that you have requested or agreed to receive
To provide you with additional information on products and services that SM offers
To market or advertise SM’s products and services to you
For internal business purposes such as complying with our internal policies
To analyze how our services or products are being accessed and used
To protect our interests, including establishing, exercising and defending legal rights and claims
As necessary to comply with legal requirements
How We Share Your Information
SM shares the information we collect, which is described above, in the following ways:
Business Partners, Vendors, and Affiliates
We may employ third party companies and individuals to perform certain business services on behalf of us and may disclose personal information to them as needed for them to perform such business services. These business services include, but are not limited, to any of the following: to facilitate the Website; to process a payment, to provide the Website or portions of the Website on our behalf; to perform related services, including without limitation, maintenance services, database management, web analytics, marketing services, and improvement of the features or functionality; or to assist us in analyzing how the Website is being used.
Information You Instruct Us to Share. You may be presented with an option to have us send certain information to third parties or give them access to it. If you choose to do so, your personal information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.
In the event that we, or any portion of our assets, are acquired or we undergo another transaction in our business, your information may be transferred to the acquiring company or other entity surviving such transaction.
We may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we reasonably believe may aid a law enforcement investigation into unlawful activity. In addition, we reserve the right to release your information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies, or the release of your information may protect the rights, property, or safety of us or another person.
Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
Sale of Information
Like most companies, we allow certain third party advertising partners to place tracking technology such as cookies and pixels on our websites. This technology allows these advertising partners to receive information about your activities on our website, which is then associated with your browser or device. These companies may use this data to serve you more relevant ads as you browse the internet. Under some state laws, sharing data for online advertising may be considered a “sale” of information. Except for this limited sharing, we do not sell any of your information.
Access From Outside the United States
Our Site is directed at users in the United States. If you are not a resident of the United States, please do not use this Site.
How We Protect Your Information
We employ appropriate data collection, storage and processing practices and security measures, including reasonable administrative, technical, and physical safeguards, to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. For example, sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable and, therefore, we cannot guarantee that your information will remain secure.
We are committed to protecting the privacy of children. The Site is intended for adult use only and is not directed towards children, minors, or anyone under the age of 16. Users must be at least thirteen (13) years of age to access and use the Website. Any access to or use of the Website by anyone under the age of thirteen (13) is unauthorized, unlicensed, and in violation of the Agreement. By using the Website, you represent and warrant that you are thirteen (13) years of age or older. In addition, if you are under the age of 13, you are not authorized to provide us with any personal information. If the parent or guardian of a child under 13 believes that the child has provided us with any personal information, the parent or guardian of that child should contact us at the email address below and ask to have this Personal Information deleted from our files.
Additional Privacy Information For California Users
The California Consumer Privacy Act of 2018 (“CCPA”) provides consumers (California residents) with specific rights regarding their “Personal Information”. This section describes your CCPA rights and how to exercise those rights.
This section applies only to California residents and to “Personal Information” as that term is defined under the CCPA. Certain information falls outside of the scope of the CCPA, including, for example, “Protected Health Information” that is collected by a “Covered Entity” or “Business Associate” governed by the Health Insurance Portability and Accountability Act of 1996.
Access to Specific Information and Data Portability Rights:
You have the right to request that SM 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 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 SM 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, 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.).
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 a legal 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 either:
Emailing us at info@SMMGRP.com
Contact us at 561.781.0660
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 forty-five (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. 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 usable 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.
Personal Information Sales Opt-Out and Opt-In Rights
To exercise the Right to You have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-Out”). Users who opt-in to Personal Information sales may opt-out of future sales at any time.
To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request by emailing us at firstname.lastname@example.org.
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 contacting SM at the email address or phone number provided in this notice.
You do not need to create an account with us to exercise your Right to Opt-Out. We will only use Personal Information provided in an opt-out request to review and comply with the request.
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.
Other California Privacy Rights
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 send an email to email@example.com.
Please check back periodically as this Policy may change from time to time. SM has the discretion to update this Policy at any time without prior notice to you to reflect changes in our information practices or relevant laws. We will notify you of any material changes by posting the new Policy on the Website. We will indicate at the top of the Policy when it was last updated. The User information SM gathers is and will be subject to the Policy in effect at the time the information is gathered. If you do not agree with any changes to the Policy, you should not access or use the Website. You acknowledge and agree that it is your responsibility to review this Policy periodically and become aware of modifications.
If you have any questions about this Policy, the practices of this Site, or your dealings with this Site, please contact us at: firstname.lastname@example.org