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Privacy Policy

Last Updated/Effective Date: 8/16/2023

Diverzify Intermediate, LLC, its affiliates and its subsidiaries (“Diverzify,” “we,” “us,” or “our”), respects your privacy. This Privacy Notice describes the processing of Personal Information (defined below) that is provided, collected, or shared on the sites, or other platforms that link to this Privacy Notice (collectively, the “Site”), or that is otherwise provided to, or collected by, us in connection with the products and services we offer (our “Services”). It also describes your choices about the collection, sharing, and use of your Personal Information.

We may modify this Privacy Notice at any time. All changes will be effective immediately upon posting to the Site. Material changes will be posted on the Site or otherwise communicated to you.

  1. Personal Information We Collect

We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

The types of Personal Information we may collect may include:

  • Contact Information – If you submit an inquiry, submit an online form, or otherwise provide information on our Site, we may collect your contact information. This may include your name, email address, phone number, and demographic information.
  • Commercial and Financial Information – If you make any purchases through our Site, we may collect your financial information, including your name, postal and e-mail address, and payment information. We will also collect information about your purchases and other commercial information.
  • Location Data – While navigating our Site, your mobile device or browser may share your location data, both through WiFi and GPS. We may collect this information based on the settings of your phone and browser.
  • Usage Information – When you use our Site, our servers may automatically record information, including your Internet Protocol address (IP Address), browser type, referring URLs (e.g., the site you visited before coming to our Site), domain names associated with your internet service provider, information on your interaction with the Site, and other such information.
  • Professional or Employment-Related Information – If you apply for employment, we may collect your employment and work history, as well as other Personal Information related to your potential employment. This may include your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
  • Communication Information – We may collect the contents of your communications with us, which includes any audio, electronic, visual information, or any data in any files uploaded, whether via e-mail, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect. Where permitted by applicable law, we may collect and maintain records or communications with our agents, representatives, or employees via e-mail, social media, or similar functionality.
  1. How We Collect Your Personal Information
  • We May Collect Your Personal Information Directly From You – For example, if you register for an account, use the Site, submit an inquiry, request information from us, or purchase our Services.
  • We May Also Collect Personal Information From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.
  • Through Online Tracking Technologies – We and our service providers may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use the Site.  We process the Personal Information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Site, to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in.

Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available, or some functionality may be limited or unavailable.  Please review the help pages of your browser or mobile device for assistance with changing your settings.

Some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the Site and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy notice of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.

Online Behavioral Advertising.  We use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including this Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites, and may be sent to you via email.

We use Google Ads to serve ads across various websites. Google uses Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.

  1. How We Use Personal Information

To the extent permitted by applicable law, we may use Personal Information to:

  • operate the Site and provide support to our business functions;
  • fulfill customer requests, such as to register for an account or complete customer purchases;
  • protect against criminal activity, claims and other liabilities;
  • send you information about our company, services, and promotions;
  • respond to reviews, comments, or other feedback provided to us;
  • support and personalize the Site and our advertising efforts;
  • protect the security and integrity of the Site;
  • provide customer support;
  • benchmarking, data analysis, audits, developing new products, enhancing the Site, facilitating product, software and applications development, improving the Site or our services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
  • meeting our contractual requirements;
  • complying with applicable legal or regulatory requirements and our policies;
  • responding to inquiries related to employment opportunities;
  • marketing, advertising, and providing the Site and our services; and
  • any other lawful purpose for which the Personal Information is collected.
  1. Sharing of Personal Information

We may share your Personal Information in the following circumstances:

  • To Service providers – When we hire a service provider to help operate the Site or our business, we may give access to Personal Information as necessary to perform the service on our behalf.  This may include service providers that operate our Site, send our communications, or run our promotions.
  • For Legal Obligations – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Diverzifyits users, or the public against harm.
  • In the Case of a Merger or Sale – If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.
  1. How Long Do We Keep Your Personal Information

We will retain your Personal Information for as long as appropriate, in our judgment, to fulfill the purposes for which it has been collected, as outlined in this Privacy Notice, or any longer retention period required by law.  If you are a California resident, please see the section below titled Notice to California Residents for additional information about how long we retain your Personal Information.

  1. How We Protect Your Personal Information

We use commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information.

  1. Your Choices and Controls

Depending on where you live, you may have the following rights with respect to your Personal Information.

  • Access: You may have the right to know what Personal Information we have collected about you and to access such data.
  • Data portability: You may have the right to receive a copy of your information in a portable and readily usable format.
  • Deletion: You may have the right to delete your Personal Information that we have obtained, subject to certain exceptions.
  • Correction: You may have the right to correct inaccuracies in your Personal Information.
  • Opt out of certain processing: You may have the right to opt out of the processing of your information for purposes of (a) targeted advertising, (b), the sale of your Personal Information; or (c) profiling in furtherance of decisions that produce legal or similarly significant effect concerning you.

To exercise any of these rights available to you, see Section 12 below.

To opt out of marketing emails, please email us at dataprivacy@diverzify.com or by following the instructions included in the email. Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.  Additionally, if you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our Services to you.

  1. International Use of the Site

This Site is hosted in the United States. As a result, the Personal Information that we collect and generate about you may be transferred, stored, or accessed in a destination outside of your country which may have less strict, or no, data protection laws, when compared to the laws in your country. Any transfers of Personal Information outside your local country will be conducted in compliance with the international data transfer restrictions that apply under applicable data protection laws.

  1. Children’s Privacy

We do not knowingly target our Services to collect or solicit any Personal Information from children under the age of 16.  If we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at [dataprivacy@diverzify.com] or contact us using the information listed in Section 14.

  1. Links to Third-Party Websites

We are not responsible for the practices employed by any websites or services linked to or from the Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s Privacy Notice.

  1. Notice to California Residents

This Section applies to our collection and use of Personal Information if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” has the definition set forth in the CCPA.

This Section describes (1) the categories of Personal Information collected and disclosed by us, (2) your privacy rights under the CCPA, and (3) how to exercise your rights.

Diverzify makes the following disclosures regarding the Personal Information Diverzify has collected within the 12-month period preceding the Effective Date of this Privacy Notice:

Sources of Personal Information

We collect Personal Information from the categories of sources detailed in Section 2 above: (a) directly from you; (b) data collected automatically through tracking technologies; and (c) third parties.

Use of Personal Information

We collect Personal Information for the business and commercial purposes detailed in Section 3 above.

Disclosure of Personal Information

The categories of third parties to which we disclose Personal Information for a business or commercial purpose or to whom we sell or share Personal Information are summarized in the chart below.  We do not knowingly sell or share Personal Information.

Categories of CA Personal Information We Collect Categories of Third Parties to Which We Disclose Personal Information for a Business or Commercial Purpose Categories of Third Parties to Which We May Sell or Share Personal Information
Identifiers Service providers; affiliates We may sell or share your Personal Information
Personal information, as defined in the California customer records law Service providers; affiliates We may sell or share your Personal Information
Commercial Information Service providers; affiliates We may sell or share your Personal Information
Internet or other similar network activity Service providers; affiliates We may sell or share your Personal Information
Geolocation data Service providers; affiliates We may sell or share your Personal Information
Audio, electronic, visual, thermal, olfactory, or similar information Service providers; affiliates We may sell or share your Personal Information
Inferences drawn from other Personal Information Service providers; affiliates We may sell or share your Personal Information
Professional or employment-related information Service providers; affiliates We may sell or share your Personal Information
Sensitive Personal Information Service providers; affiliates We may sell or share your Personal Information

 

Data Retention: We will retain each category of your Personal Information for as long as appropriate to fulfill the purposes described in the “How We Use Personal Information” section above, unless otherwise required by applicable laws. We consider the following criteria to determine how long we will retain your Personal Information including whether: we need your Personal Information to provide you with the Services you requested; we continue to have a business relationship with you; you have requested information or Services from us; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or recordkeeping policies and obligations dictate that we retain your Personal Information; we have an interest in providing you with information about our Services; and we have another business purpose for retaining your Personal Information.

If you are a resident of California, you may have the following rights:

 

Privacy Right Description 
Notice  The right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access The right to know what Personal Information we have collected about you, including (a) the categories of Personal Information; (b) the categories of sources from which the Personal Information was collected; (c) the business or commercial purpose for collecting, selling, or sharing Personal Information; (d) the categories of third parties to whom the business discloses Personal Information; and (e) the specific pieces of Personal Information we have collected about you.
Data Portability You may have the right to receive a copy of your Personal Information in a portable and readily usable format.
Deletion   The right to have your Personal Information deleted. Note, however, that we may not always be able to comply with your request to delete for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Correction You have the right to request that we correct any incorrect Personal Information that we collect or retain about you, subject to certain exceptions.
Automated Decision Making We may engage in automated decision making. You may have the right to request information about the logic involved in automated decision-making and a description of the likely outcome of processes, and the right to opt out.
To Opt Out of Sales or Sharing of Personal Information  We do not sell or share your Personal Information. However, if we did, you would have the right to opt out of the sale or sharing of your Personal Information by clicking the “Do Not Share My Personal Information” link found at the footer of our Site.
Limit Use of Sensitive Personal Information We do not use or disclose Sensitive Personal Information other than to provide our service. However, if we used or disclosed Sensitive Personal Information for other purposes, you would have the right to limit certain uses of Sensitive Personal Information.

 

Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.

You may only make a request for access or data portability twice within a 12-month period. The 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.

Other California Privacy Rights. Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us using the information in the Contact Us section below. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

  1. Exercising Your Individual Privacy Rights

You will not be discriminated against by virtue of your exercise of the rights listed in this Privacy Notice which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

To exercise any of the privacy rights afforded to you under applicable data protection law, please submit a request to us by one of the following methods:

  • E-mailing us at dataprivacy@diverzify.com
  • Calling us at (800) 444-6281

Verification: We must verify your identity before fulfilling your requests.  If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.

We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your 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 cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.

We may deny certain requests, or only fulfill some in part, as permitted or required by law.  For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes.

Upon request, this Privacy Notice is available in an alternative downloadable format to consumers with disabilities.
Appeals: If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

  1. Changes to this Privacy Notice

Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We may provide you with an updated Privacy Notice if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to the Site.

  1. Contact Us

If you have any questions about our practices or this Privacy Notice, please contact us at . You may also write to us at:

Diverzify Intermediate, LLC
865 W. Irving Park Road
Itasca, Illinois 60143
Attn: Compliance