I. Overview
Captured Technologies, LLC (“Captured Technologies, LLC”) recognizes and respects the privacy of users of ConversaMedia.com (the “Website”). The following privacy policy, as modified from time to time by us as described below (the “Policy”), tells you about the information that Captured Technologies, LLC collects through the Website and how we use the information we may collect. If you access the Website, you are consenting to the information collection and use practices described in this Policy, as modified from time to time by us.
II. Updates
Captured Technologies, LLC reserves the right to make changes to this Policy at any time, and will post any revised Policy on this page. You will know we have changed the Policy when you see a new updated date at the top of this Policy. Captured Technologies, LLC will not notify its Website users of any such changes by e-mail or other personal contact. We encourage you to check the date of this Policy whenever you visit this Website so that you will know when you need to review the Policy for modifications. Please note that this Policy applies to all information collected online by Captured Technologies, LLC.
III. Collection and Use of Information
Personal information means information that can be used to identify and contact you, including but not limited to your name, postal delivery address, e-mail address, payment method (e.g., credit card or debit card) and telephone number, as well as other information when such information is combined with your personal information. When you register or use certain services available on our Website, we ask you to supply us with certain personal information so that we can provide, enhance and personalize our services and marketing efforts. For similar reasons, we may supplement the personal information you provide with publicly available information about you. We use this personal information to process your registration, your payments, and to communicate with you on these and other topics. We may also use your e-mail address to send you newsletters, promotional announcements, and consumer surveys.We keep track of your interactions with us, including but not limited to your site activity, payment history and correspondence as well as any other related activity. We use this information for such purposes as personalizing the site to better reflect particular interests, tracking your level of activity, helping us quickly and efficiently respond to inquiries and requests and otherwise enhancing our service offering for our customers. We also provide analyses of our users in the aggregate to prospective partners, advertisers and other third parties. We may also disclose and otherwise use, on an anonymous basis, site habits, commentary, reviews and other non-personal information about customers. While using the Website, you will have opportunities to post comments or other personal information in forums, such as the blog, marketplace, or the other forms. Please understand that when you post such information, it is made public and is not subject to this policy. Please refer to the Website’s Terms of Service, for more information regarding obligations associated with the posting of User Content on the Website.
IV. Cookies and Other Technology
As you browse the Website, cookies may placed on your computer’s hard drive. (Cookies are small pieces of data that are sent to your browser from a Web server and stored on your hard drive for record keeping purposes.) In general, cookies can make the Web more useful by storing information about your preferences on a particular site. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. If your browser is set to not accept cookies, you may not be able to use particular services on the Website. In addition to cookies, we may use other technologies, including pixel tags, to gather information on how our users interact with our Website and to otherwise help us efficiently operate and monitor our site and service. These technologies, show us, for example, popular pages, conversion rates, click-throughs and other information that can be used to improve, operate and monitor our site and our service.
V. Disclosure of Personal Information
We use other companies, agents or contractors to perform services on our behalf. For example, we have partnered with other companies to personalize our Web pages, process credit card transactions, collect debts, analyze and enhance data, including customers’ interaction with our site, and process consumer surveys. In the course of providing such services, these other companies may have access to your personal information. These companies are not permitted to use your personal information except for the purpose of providing the services we request of them. In addition, we often partner with third party companies, agents or contractors in order to offer joint promotions, advertisements, programs and marketing campaigns in which we believe our users may be interested. These companies are not permitted to use your personal information except for the purpose of participating in the partnership arrangement for which Captured Technologies, LLC engages them. Captured Technologies, LLC also reserves the right to disclose personal information when we reasonably believe disclosure is required by law, if we reasonably believe disclosure is necessary to establish or exercise legal rights, or in situations involving potential threats to physical safety. In the event that Captured Technologies, LLC is acquired by or merged with a third party, we reserve the right, to sell or otherwise transfer the personal information we have collected as part of that transaction provided that such third party continues to honor our privacy policy. NOTWITHSTANDING ANYTHING SET FORTH HEREIN TO THE CONTRARY, Captured Technologies, LLC RESERVES THE RIGHT TO USE YOUR PERSONAL INFORMATION (EXCLUSIVE OF ANY CREDIT CARD INFORMATION PROVIDED, IF ANY) FOR ANY LEGALLY PERMISSIBLE PURPOSE, IN Captured Technologies, LLC’S SOLE DISCRETION. Captured Technologies, LLC may use your personal information to provide promotional offers to individuals by means of email advertising, text/short message services, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.
VI. Security
You are responsible for maintaining the confidentiality of your account information and for restricting access to your computer or mobile device through which you access our Website account. Users of public or shared computers or unprotected mobile devices should log out at the completion of each visit to the Website. Unfortunately, no security system can be guaranteed to be 100% secure. Accordingly, we cannot guarantee the security of your personal information and cannot assume liability for improper access to it. By using this Website, or providing personal information to us through any means, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of this site.
VII. Privacy Notice-California
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Captured Technologies, LLC and its affiliates (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, households and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the chart below depicts the categories of personal information relating to consumers we have collected within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data | Physical location or movements. | YES |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
Personal information does not include:
- • Publicly available information from government records
- • De-identified or aggregated consumer information
- • Information excluded from the CCPA’s scope, like:
We obtain the categories of personal information listed above from the following categories of sources:
- • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us. • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them. • Directly and indirectly from activity on our website (www.ConversaMedia.com). For example, from submissions through our website portal or website usage details collected automatically. • From third-parties that interact with us in connection with the services we perform. For example, from affiliate marketers who place ads and forward activity to us or from credit reporting agencies (“CRA”). • Information that is publicly available online or elsewhere and • Employees and job applicants
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us assist you in debt settlement activities. • To provide you with information, products or services that you request from us. • To provide you with email alerts, newsletters and other notices concerning our products or services, or events or news, that may be of interest to you. • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections. • To assist you in identifying appropriate resources if we cannot serve you for any of a number of reasons including, but not limited to, inability to operate in the state of request or lack of eligible debt • To provide a third party with qualified leads for a program that they may administer • To improve our website and present its contents to you. • For testing, research, analysis and product development. • To conduct audit, compliance or other legal work associated with our business. • To perform financial reporting and accounting and other general business administration • To assess third party vendors and services providers • As necessary or appropriate to protect the rights, property or safety of us, our customers or others. • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Category A: Identifiers. Category B: California Customer Records personal information categories. Category G: Geolocation data Category F: Internet or other similar network activity. Category K: Inferences drawn from other personal information We disclose your personal information for a business purpose to the following categories of third parties:
- • Our affiliates. • Service providers. • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. We may also disclose your personal information to a third party for a commercial purpose. When we disclose personal information for a commercial purpose, which may include providing your information to a provider which can assist you, we have a compensatory relationship which requires the recipient to abide by data privacy regulations and not use it for any purpose except as described.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a commercial purpose: Category A: Identifiers. Category B: California Customer Records personal information categories. Category D: Commercial information We disclose your personal information for a commercial purpose to the following categories of third parties:
- • Our affiliates • Corporate credit facility lenders • Service providers • Vendors • Other third parties including marketers
Changes to this Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you here, by means of a notice on our homepage and/or any other acceptable means.
Contact Information
If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: ccpa@ConversaMedia.com
Contact
If you have questions concerning your account, please contact Customer Service. If you have questions concerning this privacy policy, please email info@ConversaMedia.com. Our counsel's address is 506 S Spring St #13308 SMB#30798 Los Angeles, CA 90013, Attention: Captured Technologies, LLC Counsel.
Effective 1/2020