1. GENERAL

• (a) Consent. By accessing or using the Service or sharing information with LPS, you consent to the collection, use, disclosure, storage and processing of your information in accordance with: (i) this Privacy Policy, which may be updated from time to time; (ii) any related terms of use, end user license agreement or services agreement (collectively, “Service Terms”); and (iii) and as permitted or required by applicable law. If you do not consent to this Privacy Policy for any reason, please do not use the Service or share your information with us. Please note that this Privacy Policy applies only to the Service, and not to any other third party website linked to or from it, or any third party website in which LPS content or functionality is embedded. We do not control the privacy policies or practices of others.
• (b) International. Personal information collected by LPS may be stored and processed in your region, in the United States, and in any other country where LPS or its affiliates, subsidiaries, or service providers operate facilities. Furthermore, the Service may be hosted or operated in countries other than the country in which you reside. Those countries may have different data protection laws, rules and regulations from those that apply in your home country. By accessing or using the Service, you consent to the transfer, storage and processing of your information outside of your home country. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access to the Service. By sending us your information, you further consent to its storage within the United States. Please be aware that the governments, courts, and law enforcement, security or agencies of a particular jurisdiction may be able to obtain access to or disclosure of your information as permitted by the laws of that jurisdiction. LPS will retain your information as long as necessary for the purposes outlined in this Privacy Policy and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection or audit purposes, or as otherwise required by law.
• (c) Interpretation. For the purposes of this Privacy Policy, the words “such as,” “include,” “includes” and “including” shall be deemed to be followed by the words “without limitation.”

2. HOW LPS COLLECTS AND USES INFORMATION

• (a) Information That You Provide Directly. LPS may ask for certain information such as your name, physical address, email address, telephone number, password; your organization’s name, physical address, email address, telephone number, history and composition; and other information. LPS may retain any messages you send through the Service, and LPS may also retain other information you voluntarily provide to LPS. LPS uses this information to operate, maintain and provide to you the features and functions of the Service, and as further described below.
• (b) Survey Data. Some portions of the Service allow you to participate in surveys administered by LPS on behalf of clients it services (“Clients”) in which you may provide information about yourself and your organization, including the size of your organization and certain general financial details; the numbers or percentages of owners, management and staff who are women, minorities or veterans; and other information (“Survey Data”).
• (c) Information Collected or Received from Third Parties. LPS may receive information about you from third parties and will add it to our database of information. You should always review and, if necessary, adjust your privacy settings on third-party services before linking or connecting them to the Service. LPS may also collect information about you from LPS’s third-party business associates, publicly-available sources and LPS’s affiliates.
• (d) Analytics information. LPS may collect, measure and analyze traffic and usage trends for the Service, and LPS may use third-party analytics tools to help LPS (“Analytics Tools”). This allows LPS to understand, among other things, who is using the Service, how they are using it, and ways to improve the Service. Analytics Tools may use cookies and persistent device identifiers to collect and store information such as time of visit, pages visited, time spent on each page, IP address, and type of operating system used.
• (e) Cookies. When you access or use the Service, LPS may send one or more cookies (small text files containing a string of alphanumeric characters) to your computer that uniquely identify your browser and enhance your navigation within the Service. A cookie may also convey information to LPS about how you use the Service (such as the pages you view, the links you click and other actions you take), and allow LPS or LPS’s third-party business associates to track your usage of the Service. There are at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your device after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions for removal of cookies. A session cookie is temporary and is deleted after you close your browser. You can reset your web browser to refuse all cookies or to notify you when a cookie is being sent. However, some features of the Service may not function properly if cookies are disabled.
• (f) Log File. Log file information is automatically reported by your browser each time you access a web page. When you access or use the Service, LPS’s servers may automatically record certain log file information, such as your web request, internet protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links within the Service, domain names, landing pages, and pages viewed.
• (g) Clear GIFs/Web Beacons. Clear GIFs (also known as web beacons) allow for the tracking of a user’s response to an email or usage of a website in a manner that does not reveal personally-identifiable information. LPS may use clear GIFs or similar technologies to assess responses to emails and usage of the Service, such as tracking when emails are opened and which links are clicked by recipients. You can disable the ability of clear GIFs to capture information by blocking cookies.
• (h) Device Identifiers. When you access or use the Service using a mobile device, LPS may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (UUID). Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by LPS. A device identifier may convey information to LPS about how you browse and use the Service. A device identifier may remain persistently on your device to enhance your navigation within the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
• (i) Advertising Identifiers. Advertising identifiers are unique strings associated with your mobile device that are provided by the operating system. Advertising identifiers may be modified or disabled by users in the device operating system’s settings.
• (j) Location Data. When you access or use the Service, LPS may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (such as latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to LPS information about how you browse and use the Service. Some features of the site, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
• (k) Commercial Communications. LPS may use the information LPS collects or receives to communicate directly with you, such as sending you emails containing newsletters, promotions and special offers. LPS may also use the information to send you service-related notices (such as account verification, technical and security notices).
• (l) Use of Certain Service-Type Data. LPS may use the information described in this Section 2 to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (ii) provide custom, personalized content or information; (iii) monitor the effectiveness of the Service; (iv) monitor aggregate metrics, such as total number of visitors, traffic and demographic patterns; (v) diagnose or fix technology problems; (vi) provide advertising to your browser or device; and (vii) conduct research or surveys.
• (m) Use of Information with Your Consent. LPS may further use your information for any other purpose for which you provide consent.
• (n) Account Login. If you have an account with the Service and log in while you access or use the Service, the information described in this Section 2 may be collected and maintained in a manner that associates such information with your name or contact information.
• (o) Combining Information. LPS may combine any of the information that LPS collects from or about you, from one or multiple sources (including third-party sources), and use it in the manner described in this Privacy Policy. For example, LPS may combine information from or about you collected through one LPS product or service with information from or about you collected through another LPS product or service.
• (p) Other Uses of Your Information. We process your personal information with your consent or as needed to provide you Services. We may also use your personal information to comply with legal obligations, operate our business, protect the vital interests of you, our customers, or the public, or for other legitimate interests of LPS as described in this Privacy Policy. More specifically, we may use your personal information to: (1) Optimize and improve the Services - We continually try to improve the Service based on the information and feedback we receive from you, including by optimizing the content on the Service; (2) Personalize the user experience - We may use your information to measure engagement with the Service, and to understand how you and our other users interact with and use the Service and other resources we provide; (3) Improve customer service - Your information helps us to more effectively develop the Service and respond to your support needs; (4) Process transactions - We may use the information you provide about yourself to fulfill your requests. We do not share this information with outside parties except to the extent necessary to provide the Service and related activities; and (5) To send periodic emails - The email address you provide through our contact forms, will be used to send information and updates pertaining to the Service. It may also be used to respond to your inquiries or other requests. If you opt in to our mailing list, you may receive emails that include LPS news, updates, related product offerings and service information, and marketing material. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us via the contact information below.

3. HOW LPS MAY SHARE YOUR INFORMATION

• (a) Business Associates and Service Providers. LPS may share information about you with third-party business associates, agents, vendors and service providers that perform services on LPS’s behalf in connection with the Service. LPS may also share information about you with any of LPS’s affiliates for purposes consistent with this Privacy Policy.
• (b) Business Change. If LPS becomes involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of LPS’s business otherwise changes, LPS may share or transfer your information to a third party or parties in connection with such transaction or change in ownership, including as part of the due diligence process conducted by the parties to a potential transaction.
• (c) Necessary Disclosure: Regardless of the choices you make concerning your information and to the extent permitted or required by applicable law, LPS may disclose information about you to third parties to: (i) enforce or apply this Privacy Policy or the Service Terms; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect LPS’s rights, reputation, safety or property, or that of LPS’s users or others; (iv) protect against legal liability; (v) establish or exercise LPS’s rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; violation of the Service Terms; or as otherwise required by law.
• (d) Sharing Information. LPS may share certain service-type information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear GIFs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks) with LPS’s third-party business associates for the purposes described in the Section 2. LPS may also aggregate or otherwise strip data of all personally-identifying characteristics and share that aggregated, anonymized data with third parties.
• (e) Survey Data. LPS may publish, share, distribute or disclose personal information and/or Survey Data that has been aggregated with information from other users or otherwise de-identified in a manner that does not allow such data about you to be separated from the aggregate data and identified as originating from you, to third parties, including without limitation with Clients. Such information may help LPS for purposes of statistical analysis and benchmarking and/or to identify and analyze training, demographic, and psychographic trends and information, and report to third parties how many people saw, visited, or clicked on certain content, areas of the Service, ads, or other materials. We may also use such data for research purposes.
• (f) Sharing with Other LPS Services. Lenox Park Solutions may retain information collected from or about you through one LPS product or service and use it to pre-populate fields requesting similar information when you access or use another Lenox Park Solutions product or service. For example, LPS may retain certain Survey Data that you provide in one survey to pre-populate fields requesting similar information when you participate in other surveys, whether administered by the same or different Clients.

4. HOW LPS PROTECTS YOUR INFORMATION

LPS takes physical, technological and administrative measures to protect the personal information you provide through the Service against loss, theft, and unauthorized access, use, disclosure or modification. For example: (a) we transmit data over secured communication channels using SSL Login credentials; (b) personal information is stored by trusted third party providers (e.g. AWS); (c) all personal information is stored by trusted third party providers (e.g. AWS); and (d) all Service usage is restricted on a per-user basis on the principle of least privilege. However, LPS cannot ensure or warrant the security of any information you transmit to LPS or guarantee that information within the Service will not be accessed, disclosed, altered or destroyed. Communications sent to or from the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to LPS via email. We rely on AWS’ security programs to protect personal information while stored in their respective controlled facilities. For more information on AWS’ security practices and processes, please see https://aws.amazon.com/security/.

5. YOUR CHOICES ABOUT YOUR INFORMATION

• (a) Controlling Your Settings. You can limit your browser or mobile device from providing certain information by adjusting the settings in the browser, operating system or device. Please consult the documentation for the applicable browser, operating system or device for the controls available to you. You can also stop receiving promotional emails from LPS by following the unsubscribe instructions in those emails. Note that unsubscribe is not available for certain emails, such as those concerning your relationship or dealings with LPS.
• (b) Targeted Advertising. You can learn more about Google Analytics and your options for opting out of interest-based Google ads at https://adssettings.google.com. You can learn more about targeted ads and your choices to prevent third parties from delivering targeted ads to your browser or device by visiting http://optout.networkadvertising.org/ and http://optout.aboutads.info/. You should be aware that even if you opt out of targeted ads, you may still see ads within the Service, although the ads may not be tailored to your interests.
• (c) Do Not Track. At this time, LPS does not recognize “do not track” signals sent from web browsers. Third-party services that LPS uses may collect personal information about individual users and their activities over time and across different websites. In some cases, you may be able to disable tracking mechanisms, but doing so may disable certain features of the Service. To disable tracking, please consult the documentation for your browser, operating system or device. For some devices, it may not be possible to disable tracking mechanisms.

6. HOW LONG LPS KEEPS YOUR INFORMATION

LPS will retain your information as long as necessary for the purposes outlined in this Privacy Policy, and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection, or audit purposes, or as otherwise required by law.

7. CHILDREN'S PRIVACY

The Service is not directed to children and is intended for use by adults only. LPS do not knowingly collect personal information from individuals under 13 years of age. If you are under the age of 13, please do not use the Service or submit any personal information through the Service.

8. THIRD-PARTY SERVICES AND SERVICES

The Service may reference or provide links to other websites or resources. If you access any website or resources provided by a third party, this Privacy Policy will not apply. Your interactions with such websites and resources are subject to the privacy policies of the third parties that operate them. Please review those policies carefully to understand how those parties will treat your information.

9. ACCESSING AND UPDATING YOUR INFORMATION

To the extent provided by the law of your jurisdiction, you may (i) have the right to access certain personal information we maintain about you and request details about how we process it, (ii) request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, (iii) request that we update or correct inaccuracies in that information, (iv) object to our use of your personal information, (v) ask us to block or delete your personal information from our database, and (vi) request to download the information you have shared on the Services. You may make these requests and any other inquiries about this Privacy Policy by emailing privacy@lenoxparkinc.com or calling us at (888) 819-2330. Any such requests are subject to the protection of other individuals’ rights and applicable law. Additionally, to help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

9. YOUR CALIFORNIA PRIVACY RIGHTS

Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with LPS is primarily for personal, family or household purposes, you may request certain data regarding LPS’s disclosure, if any, of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to privacy@lenoxparkinc.com with “Request for California Privacy Information” in the subject line. You may make such a request up to once per calendar year. If applicable, LPS will provide to you via email a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately-preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal information sharing is covered by Section 1798.83’s requirements.

10. UPDATES TO THIS PRIVACY POLICY

LPS may update this policy from time to time, and the updated version of this policy will be effective upon posting. Please check this page to review the most up-to-date version of this policy. By continuing to use the Service after an updated version has been posted, you agree that the new policy will apply to you.

 

REVISED: 1/13/2021