EFFECTIVE: October 2021
- The information we collect on or through our Services and how we collect it.
- How we use and process the information we collect.
If you have not done so already, please also review our Terms & Conditions (“Terms”), which apply to your use of the Sites. The Terms contain provisions that limit our liability to you and require you to resolve any dispute with us through final and binding arbitration on an individual basis and not as part of any class or representative action.
2. INFORMATION WE COLLECT
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked with a particular individual or household.
Depending on how you use our Services, we may collect the following categories of your Personal Information:
- Direct identifiers and contact data, such as your email address, telephone number, social media profile (if you link your account to our Services) and b. national ID or passport information;
- Demographic data, such as your gender, your date of birth and your zip code;
- Professional and employment-related data, such as your employer;
- Geolocation and other location data, including the precise location of your device and your location as that, may be captured through our security measures used at our offices;
- Internet and network activity data, such as your browsing activity, search history, IP address, and dates/times you access our Services (as further discussed in Section 3.b. below); and
- Profile information, such as your newsletter preferences.
We also collect non-identifiable data (such as browser type and device type) and aggregate data sets that show us group-level data and trends about our users and guests (“Non-Identifiable and Aggregate Information”). Non-Identifiable and Aggregate Information does not contain any individual-level data and cannot be used to identify you.
3. HOW WE COLLECT INFORMATION
Information that You Provide to Choice Financial Group, LLC: You may provide us with your direct identifiers and contact data and demographic information when you contact us for help or information, create an account to use one of our Services or otherwise voluntarily supply your Personal Information to us. We may collect information as otherwise described to you at the point of collection or pursuant to your consent.
Information that We Collect When You Use the Sites: When you use the Sites, we may automatically collect internet and network activity information about how you interact with the Sites, such as your (i) IP address; (ii) domain server; (iii) type of device(s) used to access the Sites; (iv) web browser(s) used to access the Sites; (v) statistics and information associated with the interaction between your browser or device and the Sites; and (vi) referring web page or other source through which you accessed the Sites.
Information Collected from Other Sources: Third parties that assist us with our business operations also collect your direct identifiers and contact information and internet activity information from you and share it with us. For example, we may purchase mailing lists and use email service providers that help us to more effectively administer our communications and marketing programs.
Information Collected from our Mobile App: The Choice Financial Group, LLC mobile app collects geolocation information. If your device is equipped with GPS or can connect with wireless access points or hot spots, or if your device is also a phone that communicates with cell towers or satellites, then your device is able to use these features to determine its precise geographic location. If you have consented using your device’s user interface, the geographic location of your device will be transmitted to our servers in real time any time that the App is running (even if you are not actively using the App or it is minimized on your device). Once you set your device to transmit its location information to us, your device will continue to transmit its location information to us (when it is open) until you set your device to no longer do so. You may at any time opt-out from further allowing us to have access to your device’s location information by accessing the App’s location settings on your device and setting your device not to share its location with us.
4. HOW WE USE, SHARE AND DISCLOSE INFORMATION
a. How We Use Information
We use each of the categories of Personal Information that we collect or that you provide to us to operate, maintain and enhance our Services, including:
To present our Services to you and to customize, improve, and develop content and functionality that helps us better serve your needs;
To operate our business and provide services and products requested by you;
For customer service and to troubleshoot problems;
To facilitate communication between Choice Financial Group, LLC and you;
To prevent, detect and investigate prohibited or illegal activities, such as claims of copyright infringement and security breaches;
To send emails and other communications that display content that we think will interest you, such as news about our products, services and promotions;
To generate statistical information about how users interact with our Services and conduct analyses to support, improve and enhance our Services;
To carry out our obligations and protect our rights arising from any contracts entered into between you and us, including our Terms & Conditions;
To protect the safety, security and legal rights of other users of our Services;
To fulfill any other purpose for which you provide information to us or to which you consent.
b. How We Share and Disclose Information
We may share and disclose each category of Personal Information:
With third party service providers that we retain to perform functions on our behalf, such as web hosting, data analyses, and promotion services providers, communication services providers, reservations, and property management providers and technology and data service providers, that have access to Personal Information needed to perform their functions;
To enforce our agreements with other users or third parties, including in connection with claims of copyright infringement;
To protect the safety and security of users and clients.
To comply with a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process; and
If we believe you have or are violating our Terms & Conditions or in order to protect or defend Choice Financial Group, LLC rights or property, even without a subpoena, warrant or other court order.
We and our business partners also may share and disclose Non-Identifiable and Aggregate Information for any purpose permitted by law.
5. ONLINE ADVERTISING, DATA COLLECTION AND “DO NOT TRACK”
a. Cookies & Other Data Collection Tools. “Data Collection Tools” means technology, such as cookies and web beacons, that collects information about your use of our Sites and potentially about your activities when you leave our Sites and visit other websites on the Internet.
b. Online Advertising. Our Sites use Data Collection Tools to help manage our online advertising program. These Data Collection Technologies are provided by us as well as our ad management partners and other third parties.
In addition, we and our ad management partners may use these Data Collection Tools to track the actions of users of our Sites, to measure statistics of our marketing efforts, to deliver advertisements on our Sites that may be more relevant to individual consumers and that will improve the consumer experience on our Sites, and to deliver advertisements to users of our Sites when they visit other third-party sites.
We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (“Principles”). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these principles can be found at www.aboutads.info.
c. Opting Out of Interest-Based Advertisements. If you want to “opt out” of receiving online interest-based advertisements, please follow the instructions at www.aboutads.info/choices, or www.networkadvertising.org/choices/. An “opt-out” Cookie will be placed on your device indicating that you do not want to receive interest-based advertisements. If you delete Cookies on your device generally, you will need to opt-out again.
Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our Sites. It means that the online ads that you do see will not be based on your particular interests.
In addition, please note that certain third parties that we do not control may use Data Collection Tools on Sites. When you “opt-out” of receiving interest-based advertisements through one of the links above, these Data Collection Tools may still collect information about your use of our Sites, including for analytics and fraud prevention as well as any other purpose permitted under the principles.
6. INFORMATION PROTECTION
Choice Financial Group, LLC has implemented safeguards intended to protect your information from unauthorized access and use. We also strive to ensure that our agents, contractors and business partners that have access to information in connection with providing services for Choice Financial Group, LLC protect your information. But, while we do work hard to protect your information, we cannot guarantee the privacy or security of your information. DISCLOSURE OF INFORMATION TO CHOICE FINANCIAL GROUP, LLC IS AT YOUR OWN RISK. We urge you to take every precaution to protect your information when you use the Internet or store information on your computer, tablet, or mobile device.
7. LINKS TO OTHER SERVICES
8. THESE SERVICES ARE NOT FOR USE BY CHILDREN
We do not knowingly collect information from minors. To use our Services, you must be the age of legal majority in your place of residence. By using our Services, you hereby represent that you are at least the age of legal majority in your place of residence. All information provided to Choice Financial Group, LLC is treated as if provided by an adult.
If we learn that a minor has submitted information about himself/herself to us, we delete it as soon as possible. If you believe that we have collected Personal Information from a minor, please contact us at firstname.lastname@example.org.
9. CALIFORNIA CONSUMER RIGHTS INFORMATION
If you are a resident of California, you may be entitled to the following privacy rights:
a. The right to know. You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information. Generally:
Within the preceding 12 months, we have collected the categories of Personal Information detailed in the “Information We Collect” section above.
We do not and will not sell your Personal Information.
We have not disclosed your Personal Information to third parties within the preceding 12 months.
b. The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintained about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.
d. The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our services.
You may exercise your right to know and your right to deletion twice a year free of charge. To exercise your right to know or your right to deletion, contact us at email@example.com or call us at 855-467-8733.
We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. If you have any policies with us, we will use our existing account authentication practices to verify your identity. If you do not have any policies with us, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses unless you initially provided the information for another purpose.
You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.
e. Shine the Light – Third Party Marketing: California Civil Code section 1798.83 law permits residents of California to opt-out of Choice Financial Group, LLC disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your personal information with third parties for marketing purposes at any time by submitting a request in writing to our contact address below or by emailing us at firstname.lastname@example.org. We honor all such opt-out requests and it is our policy not to share personal information with third parties for direct marketing purposes where you have submitted such a request. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.
Under California Civil Code Section 1789.3, we are required to provide California residents with the following specific consumer rights information:
i. Our Services are owned and/or operated by Choice Financial Group, LLC ,
ii. Unless otherwise expressly stated, our Services are provided without charge.
iii. To file a complaint regarding any of our services or to receive further information regarding use of the services, please send a letter to Choice Insurance Agency, 4664 S Blvd, Virginia Beach, Virginia 23452 or contact us via email at email@example.com (with “California Resident Request” as the Subject Line). You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at (916) 445-1254 or (800) 952-5210.
10. DESIGNATED COUNTRIES UNDER GENERAL DATA PROTECTION
Processing Purposes and Data Collection
Each specific basis for the processing your personal information is based upon the purpose for such information will be used as specified below:
c. Surveys: Completion of surveys is entirely voluntary. We process the information obtained from surveys based upon your consent and in furtherance of our business interests, including marketing, service improvements and analytics.
e. Direct Marketing and Promotions: We use your Personal Information to send you marketing messages and promotions on the basis of your consent.
Data Provider Rights
Data Provider has the following protections and rights upon request:
1. Access, Correction and Erasure Requests by Data Provider:
- ask us to confirm whether we are processing your Personal Information
- receive information on how your data is processed
- obtain a copy of your Personal Information
- request that we update or correct your Personal Information
- request that we delete Personal Information in certain circumstances
2. Right to Object to Processing: You have the right to request that Choice Financial Group, LLC cease processing of your Personal Information:
- for marketing activities, including profiling
- for statistical purposes
- where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your Personal Information for the establishment, exercise, or defense of a legal claim
3. Right to Restrict Processing: You have the right to request that Choice Financial Group, LLC limit the processing of your Personal Information:
- while Choice Financial Group, LLC is evaluating or in the process of responding to a request by you to update or correct your personal information
- where such processing is unlawful and you do not want Choice Financial Group, LLC to delete your data
- where Choice Financial Group, LLC no longer requires such data, but you want us to retain the data for the establishment, exercise, or defense of a legal claim
- where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request
4. Data Portability Requests: You have the right to request that we provide you or a third party that you designate with certain of your Personal Information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.
Submitting Requests: Your requests may be submitted in writing to firstname.lastname@example.org, or the Choice Financial Group, LLC ATTN: Marketing Department, 4664 S Blvd Virginia Beach, Virginia 23452. We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain Personal Information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requestor’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.
If you have concerns about our data practices or the exercise of your rights, you may contact Choice Financial Group, LLC at email@example.com.
Right to Withdraw Consent: You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing emails or contacting firstname.lastname@example.org.
To opt out or obtain a copy of theses clauses or additional information on transfers, you may send your request to email@example.com.
11. INFORMATION TRANSMISSION
12. EMAIL CONFIDENTIALITY NOTICE
This message, including attachments, is intended to be viewed only by the addressee. It may contain information that is privileged, confidential and/or exempt from disclosure under applicable law. No confidentiality or privilege is lost by any transmission error. This message may contain nonpublic personal information about consumers subject to the restrictions of the Gramm-Leach-Bliley Act and the Sarbanes-Oxley Act, and the Health Insurance Portability and Accountability Act. You may not directly or indirectly reuse or disclose such information for any purpose except as permitted by law. Any dissemination, distribution or copying of this message is strictly prohibited without our prior written permission. If you are not an intended recipient, or if you have received this message in error, please notify us immediately by return e-mail and permanently remove the original message and any copies from your computer and all back-up systems.
13. HOW TO CONTACT US