Effective date: May 26th, 2021
PROmanagerepo, LLC places great importance on safeguarding your privacy. We kindly request that you carefully review this Privacy Policy to understand how we handle your personal information. By utilizing or accessing our Services in any manner, you acknowledge and accept the practices and policies outlined below. Furthermore, you hereby provide your consent for us to collect, utilize, and share your information as described in this Privacy Policy.
Please note that your use of the Services is always subject to our Terms of Use, which incorporates this Privacy Policy. Any terms mentioned in this Policy without explicit definitions can be found in the Terms of Use.
To obtain a physical copy of this Privacy Policy, please click here. In case you have a disability, you can request an alternative format of this Privacy Policy by contacting us through any of the provided methods in the Contact Information section below.
What this Privacy Policy Covers
This Privacy Policy pertains to the manner in which we handle Personal Data collected when you utilize or access our Services. The term “Personal Data” encompasses any information that can identify or pertain to a specific individual, including data referred to as “personally identifiable information” or “personal information” as defined by relevant data privacy laws, rules, or regulations. Please note that this Privacy Policy does not extend to the practices of companies that we do not own or control, nor does it encompass individuals whom we do not manage.
Categories of Personal Data We Collect
The Personal Data categories, which we have collected and continue to collect in the previous 12 months, are outlined in the chart provided in this section. It includes:
- Category of Personal Data
- Personal Data We Collect
- Source(s) of Personal Data
- Categories of Third Parties with whom we share this Personal Data for business purposes:
Profile Information
· First and last name
· Email
· Photo
· IP address
· Vehicle Metadata
You
· Service Providers
· Affiliates
· Acquirers
· Selected Recipients Authorized By You
Other Personal Identifiers
· Unique User ID
· IP address
You
· Service Providers
· Affiliates
· Acquirers
Payment Information
· Bank Information
Third Party
· Service Providers
· Affiliates
· Acquirers
· Selected Recipients Authorized By You
Deposit Account Information
· Paypal or other bank deposit instructions
You
· Service Providers
· Affiliates
· Acquirers
IRS Form W-9 Information
· Information in the IRS Form W-9
You
· IRS
· Service Providers
· Affiliates
· Acquirers
Sources of Personal Data (Column 3)
We collect Personal Data about you from the following categories of sources:
· “You”
o When you provide such information directly to us.
o When your usage of our Services leads to the automatic collection of Personal Data about you (refer to the subsection titled “Information Collected Automatically” below)..
· “Third Parties”
o Third parties that provide us with Personal Data about you. Third Parties that share your Personal Data with us include:
§ For instance, analytics service providers can be employed to examine your interactions and engagement with the Services, while third-party entities can assist us in delivering customer support or processing payments.
Information Collected Automatically
The Services utilize cookies and comparable technologies, such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively referred to as “Cookies”), to allow our servers to identify your web browser and provide us with information about your visits and usage of our Services. This enables us to analyze trends, gain insights about our user base, and enhance the operation and functionality of our Services. Cookies are small pieces of data, typically text files, that are stored on your computer, tablet, phone, or similar device when you access our Services using that device. Additionally, we may enhance the data we collect from you by incorporating information obtained from third parties, including those who have placed their own Cookies on your device(s). It is important to note that, currently, the Services do not support “Do Not Track” requests sent from a browser.
How We Use Your Personal Data
We process Personal Data in order to operate, enhance, comprehend, and customize our Services. We utilize Personal Data for the following objectives:
- To fulfill the purpose for which you provided the information to us.
- To communicate with you regarding the Services, including Service announcements, updates, or offers.
- To offer support and assistance for the Services.
- To establish and manage your Account or other user profiles.
- To personalize website content and communications based on your preferences.
- To carry out transactions.
- To address user inquiries and fulfill user requests.
- To enhance and develop the Services, including testing, research, analysis, and product development.
- To prevent and deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of our Services.
- To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- For any other business purpose stated during the collection of your Personal Data or as otherwise specified in relevant data privacy laws, such as the Consumer Privacy Act (the “CCPA”).
We assure you that we will not gather any additional categories of Personal Data or utilize the Personal Data we have collected for significantly different, unrelated, or incompatible purposes without notifying you in advance.
As mentioned in the aforementioned list, we may get in touch with you if you have provided us with the necessary means to do so. For instance, if you have shared your email address with us, we may send you promotional email offers or contact you via email regarding your usage of our Services. Additionally, we may receive confirmation when you open an email from us, which aids us in enhancing our Services. If you prefer not to receive any communications from us, kindly express your choice by sending an email to [email protected].
How We Share Your Personal Data
Categories of Third Parties with Whom We Share Personal Data (Column 4)
We disclose your Personal Data as indicated in the chart above to the following categories of service providers and other parties:
“Service Providers”
We collaborate with external entities to ensure the smooth functioning of our Services. These entities encompass payment processors, providers specializing in security and fraud prevention, hosting and other technology and communications providers, analytics providers, as well as staff augmentation and contract personnel.
“Acquirors”
Parties that obtain your Personal Data through an acquisition or other change of control are referred to here. In the event of a merger, acquisition, bankruptcy, or any other transaction where a third party takes over our business (either wholly or partially), your Personal Data may be transferred to that third party.
“Selected Recipients”
We disclose your Personal Data to third parties as per your instructions, which include:
- Other users (when you publicly post information or when it is necessary to complete a transaction that you initiated or authorized through the Services).
- Third-party business partners that you connect with through the Services.
- Other parties authorized by you.
Sharing Personal Data for Business Purposes.
We share your Personal Data with service providers and other parties for various business purposes, which include but are not limited to the following:
- Conducting audits related to ongoing interactions and concurrent transactions, such as ensuring compliance with specified standards.
- Detecting security incidents, safeguarding against malicious, deceptive, fraudulent, or illegal activities, and taking legal action against those responsible for such activities.
- Debugging to identify and rectify errors that may hinder the intended functionality.
- Temporarily and briefly utilizing Personal Data that is not utilized by any other party to create a consumer profile or modify your consumer experience beyond the current interaction.
- Carrying out services on our behalf, which may involve managing or servicing accounts, providing customer support, processing transactions, verifying customer information, or handling payments.
Data Security and Retention
We are committed to safeguarding your Personal Data by implementing appropriate physical, technical, organizational, and administrative security measures. These measures are tailored to the specific type of Personal Data and the manner in which we process it. For instance, our Services utilize industry-standard Secure Sockets Layer (SSL) technology to encrypt any Personal Data you provide to us. To further enhance the security of your data, it is important that you carefully choose and protect your password and/or other sign-on credentials. Additionally, you should restrict access to your computer or device and browser, and always sign out after accessing your account. While we strive to ensure the security of your account and other data stored in our records, it is important to note that no method of data transmission or storage over the Internet is entirely foolproof. Therefore, we cannot guarantee the absolute security of any data shared with us. Unless expressly required by law, we shall not be held responsible for any theft, destruction, loss, or accidental disclosure of your information or content.
We store your Personal Data for the duration of your active account with us or as required to offer our Services. In certain situations, we may retain Personal Data for a longer period if it is necessary to fulfill our legal obligations, settle disputes, recover outstanding fees, or as permitted or mandated by applicable laws, rules, or regulations. Additionally, we may retain information in an anonymous or aggregated format if it cannot personally identify you.
Personal Data of Children
According to our Terms of Use, we have a strict policy of not intentionally gathering or requesting Personal Data from children under the age of 13. If you are under 13 years old, we kindly request that you refrain from registering or utilizing our Services, as well as abstain from sharing any Personal Data with us. In the event that we discover we have unintentionally collected Personal Data from a child under 13 years old, we will promptly delete that information. If you suspect that a child under 13 years old has provided Personal Data to us, please reach out to us at [email protected].
Access
You are entitled to inquire about specific details regarding our acquisition and utilization of your Personal Data within the last 12 months. In return, we will furnish you with the subsequent information:
- The classifications of Personal Data that we have gathered pertaining to you.
- The origins or channels through which the aforementioned Personal Data was obtained.
- The business or commercial objective behind the collection or sale of your Personal Data.
- The classifications of external parties with whom we have shared your Personal Data.
- The precise components of Personal Data that we have amassed concerning you.
If, within the last 12 months, we have shared your Personal Data with any third parties for business purposes, we will specify the types of Personal Data that were shared with each category of third-party recipient. In the event that we have sold your Personal Data during the past 12 months, we will disclose the categories of Personal Data that were sold to each category of third-party recipient.
Deletion
You are entitled to ask us to erase the Personal Data we have gathered about you. However, please note that there are certain exceptions to this right under the CCPA. For instance, we may need to keep your Personal Data in order to offer you our Services or fulfill a transaction or request you have made. If your deletion request falls under one of these exceptions, we may have to decline it.
Exercising Your Rights
In order to exercise the aforementioned rights, it is necessary for you to submit a request that fulfills two requirements. Firstly, the request must provide adequate information for us to verify your identity as the individual for whom we have collected Personal Data. Secondly, the request should provide a detailed description of your specific inquiry, enabling us to comprehend, assess, and address it accordingly. Only requests that satisfy both of these criteria will be deemed as “Valid Requests.” Please note that any requests failing to meet these criteria may not receive a response. Rest assured that we will solely utilize the Personal Data provided in a Valid Request for the purpose of verifying your identity and fulfilling your request. It is important to note that an account is not required to submit a Valid Request.
We are committed to addressing your Valid Request within 45 days from the date of receiving it. Rest assured, there will be no charge for submitting a Valid Request, unless it is deemed excessive, repetitive, or manifestly unfounded. In the event that a fee is applicable to your Valid Request, we will inform you of the fee and provide a detailed explanation before proceeding with your request.
You may submit a Valid Request using the following methods:
· Phone: +1 (303) 578-8628
· Email: [email protected]
· Submit a form at this address: Union Tower, 165 S Union Blvd, Lakewood, CO 80228
An individual, known as an “Authorized Agent,” can be authorized to act on your behalf and exercise your rights. In order to do so, you are required to grant written permission to your Authorized Agent, and we reserve the right to ask for a copy of this written permission from your Authorized Agent when they submit a request on your behalf.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We assure you that we will not engage in any form of discrimination if you choose to exercise your rights under the CCPA. This means that we will not refuse to provide you with our products or services, impose different prices or rates on you, or offer you a lower quality of goods and services if you exercise your rights under the CCPA. However, it is important to note that we may have different tiers of our Services in accordance with applicable data privacy laws, including the CCPA. These tiers may have varying prices, rates, or levels of quality based on the value of the Personal Data that we receive from you.
Other State Law Privacy Rights
Resident Rights
According to Civil Code Sections 1798.83-1798.84, residents have the right to reach out to us to stop the sharing of Personal Data with third parties for their direct marketing purposes. To make such a request, please get in touch with us at [email protected].
Your web browser might provide a “Do Not Track” feature that enables you to inform website operators and online service providers that you do not want them to track specific online activities of yours across different websites and over time. However, our Services currently do not support Do Not Track requests.
Changes to this Privacy Policy
We are continuously striving to enhance our Services, which may require us to update this Privacy Policy periodically. However, we will ensure that you are informed about any such changes by placing a notice on the PROmanagerepo, LLC website, sending you an email, or using other appropriate means. It is important to note that even if you have chosen not to receive legal notice emails from us (or if you have not provided us with your email address), these legal notices will still govern your use of the Services, and it is your responsibility to read and comprehend them. By using the Services after any modifications to the Privacy Policy have been published, you indicate your agreement to all of the changes. The use of the information we collect is subject to the Privacy Policy in effect at the time the information is collected.
Contact Information:
If you require any further information or have any inquiries regarding this Privacy Policy, the methods by which we gather and utilize your Personal Data, or your options and entitlements concerning such gathering and utilization, please feel free to reach out to us at the following address:.
· Phone: +1 (303) 578-8628
· Email: [email protected]
· Address: Union Tower, 165 S Union Blvd, Lakewood, CO 80228