Last updated: September 15, 2023
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE OUR SERVICES.
Squadra Solutions, LLC (also referred to herein as “we,” “us,” and “our”) takes data privacy and security seriously and believe in transparency.
INFORMATION WE MAY COLLECT
In the preceding 12 months, we may have collected information that could directly or indirectly identify you as an individual from you, your devices, your interactions with our Services, and/or from third party sources and may include the following (together, “personal data”), depending on the circumstances:1. Identifiers:
- Contact Information, such as your first and last name, email addresses, mailing addresses, telephone numbers, professional title and business name.
- Communications Data, such as information you provide through online web forms, when you contact us (or our channel partners) with questions, feedback, surveys, or otherwise choose to provide when you correspond with us online.
- Social Media Information, such as name, username, email address, or other profile information in connection with your social media account that we may collect if you connect with us through a third-party social network or other websites, such as LinkedIn. (each, a “Social Media Site”).
- Transaction Data, such as information about payments to and from you and other details of your interaction with the Services, and ordering or consuming histories.
- Marketing Data, such as your preferences for receiving communications about our activities, services, among others, and details about how you engage with our communications.
3. Internet or other similar activity; Inferences:
- Usage Data, such as the date and time of your access, your location, your Internet Protocol (IP) address or unique device identifier, your device type, your operating system, your browser type, and information about what pages you visit.
HOW WE MAY USE OR SHARE YOUR INFORMATION
1. How do we use the information: To the extent permitted by applicable law, we may use the information described above in connection with certain business or commercial purposes in the preceding 12 months, including:
- Provide you with services, products, content, and customer services;
- Maintain our regular business operations, such as maintain accounting records, analyze financial results, comply with internal audit requirements; or obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice;
- Improve and develop existing and/or new services;
- Maintain our databases and back-ups, including our communication records with you;
- Mitigate risks to the privacy and security of our Services, including fraud or phishing detection;
- Support and improve the Services, including evaluations of functionality and features;
- Communicate with you and respond to your feedback, requests, questions, or inquiries;
- Assess the success of our marketing campaigns and enhance our marketing efforts;
- Analyze the use of the Services and prepare aggregate traffic information;
- Recognize your devices and remember your preferences and interactions;
- Accomplish any other purpose related to and/or ancillary to any of the purposes described in this Policy, for which your information was provided to us;
- Accomplish other purposes described to you when you provide the information, for which you have consented, or for which we have a legal basis under the laws;
- Exercise or defend legal rights or claims; and
- Create, use, retain, or disclose de-identified or aggregated data, which upon aggregation and de-identification are no longer treated as personal data subject to this Policy.
2. How we may disclose or share the information: Where permitted by applicable law, we may disclose your personal data described above for business purposes in the following contexts:
- Third-Party Vendors or Channel Partners: We may share your personal data with other parties who perform functions on our behalf such as customer services, or who offer products and services specifically requested by you through e-commerce solutions, etc.
- Corporate Affiliates: We may share your personal data with our subsidiaries or affiliates, and with their respective officers, directors, employees.
- Acquisition and Similar Transactions: If we sell, transfer, or otherwise share some or all of our assets in connection with a merger, reorganization, liquidation, dissolution, bankruptcy, or sale of assets, we may transfer your personal data as a part of the assets transferred as a result of the transaction without your consent.
- In Response to Legal Process or Defending Legal Claims: We may disclose personal data as required by law, court orders, subpoena, or other legal process or if we reasonably believe such action is necessary to comply with the laws.
- Professional Advisors: We may share your personal data with our attorneys, accountants, and/or other fiduciaries and consultants that need access to your information to provide operational or other support on our behalf.
- With Your Consent or at Your Direction: We may ask, from time to time, if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy. We may disclose your information in this context with your permission or upon your direction.
We retain and use your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.
We take reasonable steps to delete the personal data we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, or (3) if you ask us to delete your personal data, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations.
We recognize the importance of safeguarding your personal data and we endeavor to maintain reasonable and appropriate physical, technical, and organizational safeguards, such as the implementation of reasonable security measures or protocols, designed to protect your personal data against accidental loss and unauthorized access, use, alteration, or disclosure, and to detect fraudulent identity verification activity and mitigate risks concerning your personal data.
While our security measures seek to protect your information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the Services. Please keep your password confidential. Do not share your password with anyone.
YOUR RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION
Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails, or by contacting us via the “Contact Us” details at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process.
Accuracy and Updating Your Information. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy. If you become aware of inaccurate personal data about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete Personal Data that you provide to us.
Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.
COOKIES AND SIMILAR TECHNOLOGIES
(A). First and Third-Party Cookies
A “cookie” is a small file created by a web server that can be stored on your device through our Services.
- Session vs. Persistent Cookies. “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you.
First-Party vs. Third Party Cookies. “First-party cookies” are set by the website you’re visiting, and they can only be read by that site. “Third-party cookies” are set by a party other than that website. You can block and control cookies using the information noted below. If you block all cookies, certain functionalities on the Services may not work.
(B). Other Similar Technologies
In addition, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.), HTML Local Storage, Social Widgets, or UTM Codes that can be used to collect data as users navigate through and interact with a website or emails. These similar technologies can be embedded in a web page or in an email to transmit information, which may include Personal data.
(C). What Cookies and Similar Technologies Are in Use and Why Do We Use Them?
Type of Cookies
Required cookies enable you to navigate the Services and use its features.
Functionality cookies allow the Services to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Services to personalize your visit.
These cookies collect information about how you use the Services, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Services functions and performs.
From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Services. We may also utilize Flash cookies for these purposes.
(D). Choices About Cookies
Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Services.
Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers (PLEASE NOTE: these third-party links are provided for your convenience, and we may not actively monitor the content of these links):
Adobe Flash Cookie
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Services are not directed to children aged 18 or younger, nor is information knowingly collected from children under the age of 18. No one under the age of 18 may access, browse, or use the Services or provide any information to or on the Services. If you are under 18, please do not use or provide any information on the Services (including, for example, your name, telephone number, or email address). If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 18, please contact us via the “Contact Us” details provided at the end of this Policy.
For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
To the extent you are a resident of certain U.S. states with comprehensive state privacy laws, you may be eligible for one or more of the following consumer rights where authorized by appliable U.S. state privacy laws. This Section provides an overview of these rights:
Right to Access. Subject to certain conditions set forth in the applicable U.S. state privacy laws, you have the right to know and see what personal data we have collected about you and receive a copy of such information in a portable format, purposes for which we collect your personal data, recipients of your personal data to whom we disclose or share, which in some states may include categories of personal data collected, categories of sources of collection, business or commercial purposes for data processing, and categories of 3rd parties with whom we disclose that information.
Right to Correct. Subject to certain exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we correct any inaccurate personal data that we have collected about you.
Right to Delete. Subject to certain exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we delete the personal data we have collected about you.
Right to Opt-Out. Subject to certain conditions set forth in the applicable state privacy laws, you have the right to opt out of targeted advertising, profiling, the sale or sharing of your personal data, to the extent such instances occur (as defined under applicable state laws). We do not have actual knowledge that we sell personal data of minors under 16 years of age.
Right to Non-Discrimination. You have the right not to be discriminated against for exercising any of your rights under the state privacy laws.
Right to Appeal. To the extent the applicable state privacy laws provide such rights, you may appeal our denial to act on your consumer rights under the applicable state privacy laws within a reasonable time. We will respond within designated period for responding to U.S. data subject requests and may exercise the right to extend this response period (to the extent authorized by applicable state privacy laws).
Right to Limit Use and Disclosure of Sensitive Personal Information. If any state privacy laws classify your information we collect as “sensitive personal information,” we use such data reasonably necessary to perform services. While this right is not applicable to how we collect or use your sensitive personal information, we provide this information as this is one of consumer rights provided under certain state privacy laws.
California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Services may make any changes to their information at any time via the “Contact Us” details at the end of this Policy.
If you have questions or concerns regarding this Section or would like to exercise your consumer rights (to the extent available under applicable U.S. state privacy laws), please use the “Contact Us” details at the end of this Policy.
OTHER IMPORTANT INFORMATION
Changes To This Policy. We may change this Policy at any time. You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Services, and from time to time, so that you are aware of any changes. Your continued use of the Services after the “Last Updated” date indicates your acceptance of the changes. All changes are effective on the date listed at the top of this page and will apply to all information that we have about you.
For more information, or if you have any questions or concerns regarding this Policy, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.
In Writing: Squadra Solutions, LLC
By Email: firstname.lastname@example.org