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Eff. January 24, 2024(“Effective Date”)
OWNER AND DATA CONTROLLER
OOTB LABS, INC. d/b/a ENSOLVERS
2875 NE 191st Ste, Ste 801
Aventura, Florida 33180
United States
DATAPROTECTION OFFICER: [CTO], privacy@ensolvers.com.
OOTB Labs, Inc. d/b/a Ensolvers and Hirelens (collectively “we”, “us” or “our”) value individual privacy and want to give visitors(“you” or “users”) of our website(s),including without limitation http://ensolvers.com and https://hirelens.ai (collectively“Website”) the opportunity to know whatinformation we collect about them and how we collect, use, disclose and storeinformation in association with the Website, mobile site, mobile application,social media channel (e.g., Facebook, Twitter, or Instagram), or other digitalplatform owned and/or operated by us, now or in the future (collectively andindividually, the“Digital Services”) and in association with us.
This Policyexplains:
• Which information about you we collect.
• Purposes of using your personal information and legal basis.
• Retention of your personal information.
• Disclosures of personal information.
• Where is your personal information stored and which are your access rights.
• Additional Disclosures for California Residents.
• Contact us.
1. Acceptance of this Privacy Policy
By using, visiting or participating in the activities and interactions with our DIgital Services, you agree to the terms and conditions of this Privacy Policy. If you do not accept this Privacy Policy, you are not authorized to use, visit or participate in the activities nor interact with our Digital Services and must discontinue using, visiting or participating in the activities and interactions immediately.
2. Information about you we collect.
a. Information collected automatically when you visit our Website:
When navigating our Website and accessing or using our Digital Services, we will collect and store Cookies, which are small text files placed in your computer’s browser to store certain preferences and information, which may enhance your browsing experience on our Website. If you would like more information, please visit our Cookie Policy at: https://www.ensolvers.com/cookie-policy.
Cookies may be used to personalize your website experience, such as recognizing you by name when you return. We do not use Cookies to track or collect personal identification information from website users. If you want instructions to change Cookie settings, visit your web browser “help” setting, described in more detail in our Cookie Policy. If you reject Cookies, you may access our Website and Digital Services, but some features or functions may be limited, and we may not be able to provide you with the most convenient experience.
And like many companies, we may use third-parties to serve advertisements on our behalf across the Internet. These advertising providers may use Cookies to collect information about your visits to and interactions with our Digital Services and may collect information about your online activities over time and across various online services. They use this information to provide you with ads on our Digital Services and third-party websites based on your inferred interests and the content you have viewed on the Digital Services. If you would like more information about this practice or how to opt out of interest-based advertising from certain companies, please visit aboutcookies.org.
Beacons
Small graphic images or other web programming code called “web beacons” (also known as “pixel tags,” “1x1 GIFs,” or “clear GIFs”) may be included in Website and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, to monitor how users navigate the Website, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection or other lawful purposes.
b) Information is collected when you volunteer to identify yourself, and provide requested information:
You may choose to write to us, or fill out certain forms or online data requests, which provide your name, telephone number, facsimile number, electronic-mail address, physical address, place or employment, job title or function, financial information, demographic information, survey responses, and related information that you provide us. We may also require you to create an account in order to access certain features in our Digital Services. Thus, you may need to create a username and password. If you reject the creation of an account, some features will be unavailable to you.
3. Purposes of using your personal information and legal basis.
We use the information collected from you to: (i) to respond to your inquiries; (ii) consider your request or application, (iii) send you appropriate information in regards to news, events, job openings and related information you subscribed to, (iv) for direct marketing purposes, including to send you newsletters, client alerts and information we think may interest you, (v) to bill you for products or services you request or verify your background or credit with your authorization or when permitted without your authorization, (vi) to communicate with you about Digital Services, us or our services. We may also use such data for market and consumer studies about product types, demographics and consumer preferences.
We are entitled to use your personal information based on (i) our legitimate interest such as for research and development, to market and promote our services, to protect and defend our legal rights and interests and to safeguard the Website and/or Digital Services, to the extent that your interests or your fundamental rights are not overridden; (ii) your consent to do so for a specific purpose; or (iii) to process your data to comply with a legal obligation. We may also collect and process your personal information to detect, prevent, and respond to fraud; violations of our policies or Terms of Use; or detect, prevent and respond to other misuse of the Digital Services, or violations of law. We also may anonymize your personal information in such a way that you may not reasonably be re-identified and may use this anonymized information for any other legitimate business, financial or legal purpose.
4. Retention of your personal information.
We will keep your personal information for as long as necessary to fulfill the purposes forwhich it was collected or as necessary to comply with our legal needs,investigations or obligations, resolve disputes, and maintain appropriatebusiness records. Once the purpose has been fulfilled your personal informationmay be retained and held if requested by authorized law enforcement orgovernmental authorities until their status of limitations have expired. Generally we retain your data no longer thanapproximately twelve (12) months.
5. Disclosures of personal information.
We may share your personal information in the following ways: (i) with affiliated companies; (ii) with our trusted business service providers and representatives (who agree to maintain the confidentiality, integrity and availability of your personal information wherever reasonably possible) in order to operate the Digital Services and Website; (iii) to provide you with the products, services and information you requested (iv) as we deem reasonably necessary to reply to law enforcement or governmental valid legal process requests or as required by law (such as a search warrant, subpoena, duces tecum or court order) and in connection with legal or regulatory proceedings whether we are a party to such proceedings or not; (v) when there is a corporate transaction, such as in the event of a merger, acquisition or transfer of control of some or all of our assets, or (vi) during emergencies when safety is at risk.
And like many companies, we may use third parties to serve advertisements on our behalf across the Internet, as described in our Cookie Policy, and we may share de-identified information in reports on user demographics and traffic patterns. We may also use or partner with third-party platforms, such as social media channels, to offer certain services. When you use these third-party platforms, over which we have no control, the terms, conditions and policies of those third parties govern your interactions with them.
6. What are your rights over your data and what are your responsibilities.
You have certain rights about your Personal Information that identifies you, subject to applicable law. For example, you may have the following rights:
Right to request access to and to check what Personal Information we keep about you;
Right to request copies of your Personal Information;
Right to update and correct inaccuracies in your Personal Information;
Right to have your Personal Information deleted;
Right to request restriction of the collection, processing, or use your Personal Information;
Right to request data portability (to receive your Personal Information in a usable electronic format and send it to a third party);
Right to opt-out of sales;
Right to opt in for sensitive data processing;
Right against automated decision making;
Private right of action;
Right to lodge a complaint with a supervisory authority; and In some cases, the right to object to our processing of your Personal Information and to withdraw your consent to our processing of your Personal Information.
Should you wish to exercise such rights, please contact us at the following electronic mail address: privacy@ensolvers.com. You may also opt out of receiving marketing communications by emailing us at privacy@ensolvers.com or taking advantage of the opt-out mechanism included in our communications. It may take us a week or so to apply our request(s).
When you request the deletion of your information, object or withdraw your consent to the processing of your information, we may not be able to supply all the features of the Website to you. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to the Website from our servers.
You are responsible for securing and maintaining the privacy of your login information and password(s) and verifying that your Personal Information is accurate and current. We are not responsible for the privacy or security of any information on the Website that you or others make publicly available or what others do with information you share with them. Please think carefully before deciding what information you share, including Personal Information, in connection with your use of the Website. Be aware that certain Personal Information and other information in connection with your use of the Website may be stored on your personal or commercial/employer’s device (even if we do not collect that information). You are solely responsible for maintaining the security of your device from unauthorized access.
7. Where is your personal information stored and how is it stored.
All of the information collected by us through the Website is stored on our secured, affiliate or business partner servers, to protect against unauthorized use and access. We have implemented commercially reasonable administrative, physical and technical security measures to protect the Website and the information about you we collect or receive. We conduct periodic formal risk assessments on the privacy and security of our website and processes and procedures. From time to time, we review and consider updates for our security purposes. Please be aware that despite our ongoing efforts, no website or security measure is perfectly impenetrable or at risk of attack.
USERS RESIDING OUTSIDE OF THE UNITED STATES AND CONSENT TO TRANSFER
The Site is operated in the United States. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to and processed in the United States. By using the Site or providing us with any information, including Personal Informations, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. When transferring Personal Information, we put in place appropriate safeguards to ensure your Personal Information remains adequately protected and is treated in accordance with our Privacy Policy and applicable law.
8. Links to other websites.
Our Digital Services may have links to third-parties’ websites. These linked sites may not be under our control, and we are not responsible for the terms, conditions, policies (including privacy practices) and content of any website we do not control. Such links are provided as convenience to you. The inclusion of a link does not imply endorsement of the linked website by us. If you supply personal information through a linked website, that transaction will occur on the third-party’s website and the Personal Information you supply will be collected by, and controlled by the third-party, not us. We recommend you familiarize yourself with the privacy practices and terms of use of any such third-party website(s).
9. Children.
We do not knowingly collect personal identifying information from children under the age of thirteen (13). No information we collect from children known to be under the age of 13 is used for any marketing or promotional purposes. Such information is used, if at all, solely to supply services. We will give out personal information about children to the extent such is stored, if required by law, for example, to comply with a court order or subpoena or to protect the safety and security of visitors and our premises. We never knowingly sell children’s personal information.
10. Payment Processing.
We may use Stripe, Inc. (“Stripe”) for account payment processing, which is a type of service that allows our Website to access Personal Information from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorization by the User. This service allows this Website to connect with the User’s account on Stripe, provided by Stripe. Stripe processing the following personal data: email address, first name, last name, billing address, payment information, financial information, purchase history, tracker data, usage data and username and various types of data described in Stripe’s privacy policy for its services: https://stripe.com/gb/privacy. Stripe processes personal data in the United Sates, including the following categories of information according to California law: identifiers; internet or other electronic network activity information.
This processing constitutes: a sale and constitutes targeted advertising according to the state laws described in the US Privacy Statement section below: CCPA, CPA, CTDPA and UCPA.
11. Changes to the PrivacyPolicy.
This Privacy Policy is not a contract, nor does it otherwise create any legal rights or obligations. Rather, this Privacy Policy merely reflects guidelines of our intended business practices. From time to time, we may change this Privacy Policy and will notify you of material changes by posting the changed or modified Privacy Policy on our Website. We may also supply notice to you in other ways, in our discretion, such as through the contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy on our Website unless otherwise specified. Thereafter, your continued use of the Website after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will constitute your consent to those changes. Rest assured, however, that unless we obtain your consent, any changes will not alter how we handle previously collected information.
12. GDPR Privacy Statement.
This section of the Policy applies to you only if you are a European Union (“EU”) consumers as defined by the EU General Data Protection Regulation 2016/679 (“GDPR”) and the Data Protection Act of 2018 (which supplements GDPR). GDPR is, an EU law that requires businesses to disclose their policies regarding the collection of, use, storage and deletion of user data (Personal Information) while also providing privacy rights to EU consumers.
In this section the following terms are defined as follows:
“Personal data” means any information which relates to a living, identifiable person. It can include names, addresses, telephone numbers, email addresses, etc., but it is wider than that and includes any other information relating to that person or a combination of information which, if put together, means that the person can be identified.
“Special category data” means personal data about a person’s race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation.
“Processing” covers all activities relating to the use of personal data by an organization, from its collection through to its storage and disposal and everything in between.
“Data subject” means the person whose personal data is being processed.
“Data controller” means the organization which is responsible for processing data and ensuring that personal data is processed in accordance with data protection law.
We are the data controller for any personal data that we process in relation to you or we may be a joint data controller with other organizations, or we may be processing data about you on behalf of another organization to whom we serve, but when this is the case, we will make you aware of this when the personal data is collected.
In addition to the other information, rights and duties described elsewhere in this Privacy Policy, you have the following rights as a data subject in relation to your personal data processed by us:
Subject Access Request: you have the right to access the personal data we hold about you, as described in this policy. You also have the right to: (i) to correct inaccuracies or, where appropriate and taking into account the purpose for which we process your data, the right to have incomplete data completed; (ii) to have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest (e.g. when we need to retain a historical archive); (iii) to object to the processing of your personal data for marketing purposes. If you ask us to delete your personal data, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. We may also need to retain some financial records for statutory purposes; (iv) to object to the processing of your personal data when that processing is based on specific criteria such as the public interest or other legitimate interests, unless we have compelling lawful grounds to continue; (v) to restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period; (vi) to ask for the transfer of your data electronically to a third party; (vii) to ask what the legal basis for us processing your personal data is, e.g. your consent, or to withdraw that consent at any time.
If you would like more information on your rights, you would like to exercise any right, you have any queries relating to our processing of your personal data, or you wish to complain please contact our Data Protection Officer identified on the top page of this Privacy Policy. You also have a right to complain to the Information Commissioner’s Office (ICO) about the way in which we process your personal data. You can make a complaint using the ICO’s website.
13. U.S. State Privacy Notice.
This U.S. State Privacy Notice applies to “Consumers” as defined under currently effective U.S. state privacy laws, to the extent such laws are applicable to you, including for example and without limitation California [California Consumer Privacy Act (California Civil Code § 1798.100 et seq.), as amended including, without limitation, by the California Privacy Rights Act (the “CCPA”)], Colorado [Colorado Privacy Act (Colorado Revised Statute Title 6 Article 1 Part 13 § 6-1-1301 et seq.) (“CPA”)], Connecticut [Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring (Public Act No. 22-15)], Texas [Texas Data Privacy and Security Act], Virginia [Virginia Consumer Data Privacy Act] and Utah [Utah Consumer Privacy Act, SB 227] collectively, “U.S. State Privacy Laws”).
Capitalized terms used but not defined in this section will have the meanings given to them in the Privacy Policy. This section of our Privacy Policy does not apply to our employment practices or data collected in the human resources context. This section of our Privacy Policy does not apply to (i) any data that is exempt from the US State Privacy Laws, (ii) is preempted by U.S. federal law, (iii) is data that is not treated as Personal information under US State Privacy Laws, or (iv) is collected by third-party website links or third-party cookies or tracking technologies.
This U.S. State Privacy Notice is designed to provide you with notice of our data practices on our website, Digital Services and services provided to you in the United States and publicized in the 12 months prior to the Effective Date listed at the top of this Privacy Policy, as required under some U.S. State Privacy Laws. Additionally, this U.S. State Privacy Notice also applies to our current data practices such that it is also meant to provide you with “notice at collection,” which is notice of personal information we collect, and the purposes for which we process personal information, among other things as required by the U.S. State Privacy Laws.
In addition to the information provided in other sections of this Privacy Policy, below is a table describing the information we collect, its source, the purpose of that collection the categories of third-parties with whom we share personal information and the purposes for the third-parties’ receipt of the personal information.
CATEGORY OF PERSONAL INFORMATION
1. Identifiers
(e.g. name, telephone or facsimile number, electronic mail, physical, or IP address, account name, driver’s license number, or similar identifiers, etc.)
SOURCE OF PERSONAL INFORMATION
From you; SEO or SEM Agencies, Mobile Service Providers, ISPs, event management software business and potential business partners; authentication partners, payment vendors
PURPOSES FOR COLLECTION
Delivery of Services requested by you; processing and managing interactions and transactions; research and development; quality assurance; improving services, detecting and preventing fraud; security; safety; marketing and error/bug correction;
defending or protection of our rights or property; responding to legal process; account management; customized offers; targeted advertising; safety, security, compliance with legal obligations, for purposes that are compatible with the purpose of collecting your personal information that are not prohibited by law.
Any other purposes listed in this policy.
CATEGORIES OF THIRD PARTIES WITH WHOM PERSONAL INFORMATION IS SHARED
Us or services professionals and providers which assists us in providing services, Digital Services and Website operation; advertising and marketing vendors, cloud or storage vendors; internal business operations, law firms, collection agencies; meeting service providers; calling and texting providers; customer service relationship management (CRM) providers; any other third-party with whom we share information described in this Privacy Policy, (collectively “Vendors”)
PURPOSES OF THIRD PARTIES RECEIVING PERSONAL INFORMATION
Performing services on behalf of us; processing and managing interactions; research and development; quality assurance, improving our services; detecting and preventing fraud; security; safety; marketing and error/bug correction; defending or protection of our rights or property; responding to legal process. Any other purposes listed in this policy.
CATEGORY OF PERSONAL INFORMATION
2. Personal Records (name, numbers, physical or electronic signature, addresses, account; employment information or history, bank or financial account information; credit / debit card numbers, dates and codes
SOURCE OF PERSONAL INFORMATION
From you; Vendors
PURPOSES FOR COLLECTION
Delivery of Services requested by you; processing and managing interactions and transactions; research and development; quality assurance; improving services, detecting and preventing fraud; security; safety; marketing and error/bug correction;
defending or protection of our rights or property; responding to legal process; account management; customized offers; targeted advertising; safety, security, compliance with legal obligations, for purposes that are compatible with the purpose of collecting your personal information that are not prohibited by law. Anyother purposes listed in this policy.
CATEGORIES OF THIRD PARTIES WITH WHOM PERSONAL INFORMATION IS SHARED
Us or Vendors
PURPOSES OF THIRD PARTIES RECEIVING PERSONAL INFORMATION
Performing services on behalf of us; processing and managing interactions; research and development; quality assurance, improving our services; detecting and preventing fraud; security; safety; marketing and error/bug correction;
defending or protection of our rights or property; responding to legal process.
Any other purposes listed in this policy.
CATEGORY OF PERSONAL INFORMATION
3. Consumer Personal Characteristics
SOURCE OF PERSONAL INFORMATION
Data enrichment tools; Vendors
PURPOSES FOR COLLECTION
Delivery Services requested by you or for marketing; account management; customized offers; targeted advertising; safety, security, compliance with legal obligations, for purposes that are compatible with the purpose of collecting your personal information that are not prohibited by law.
Any other purposes listed in this policy.
CATEGORIES OF THIRD PARTIES WITH WHOM PERSONAL INFORMATION IS SHARED
Us or Vendors
PURPOSES OF THIRD PARTIES RECEIVING PERSONAL INFORMATION
Delivering Services requested by you; marketing
CATEGORY OF PERSONAL INFORMATION
4. Transactional and Commercial Information; Customer Account Details; (e.g. details of services, requests, purchases, quotes, tendencies)
SOURCE OF PERSONAL INFORMATION
Directly from you; data enrichment tools; Vendors
PURPOSES FOR COLLECTION
Delivery of Services requested by you; processing and managing interactions and transactions; research and development; quality assurance; improving services, detecting and preventing fraud; security; safety; marketing and error/bug correction;
defending or protection of our rights or property; responding to legal process.
Any other purposes listed in this policy.
CATEGORIES OF THIRD PARTIES WITH WHOM PERSONAL INFORMATION IS SHARED
Us or Vendors
PURPOSES OF THIRD PARTIES RECEIVING PERSONAL INFORMATION
Delivery of Services requested by you; processing and managing interactions and transactions; research and development; quality assurance; improving services, detecting and preventing fraud; security; safety; marketing and error/bug correction;
defending or protection of our rights or property; responding to legal process.
Any other purposes listed in this policy.
CATEGORY OF PERSONAL INFORMATION
5. Internet Activity internet or other electronic network activity information, including but not limited to browsing history, search history, interaction with an internet website, application or advertisement.
SOURCE OF PERSONAL INFORMATION
From you; analytics partners; advertising partners
PURPOSES FOR COLLECTION
Delivery of Services requested by you; processing and managing interactions and transactions; research and development; quality assurance; improving services, detecting and preventing fraud; security; safety; marketing and error/bug correction;
defending or protecting our rights or property; responding to legal process.
Any other purposes listed in this policy.
CATEGORIES OF THIRD PARTIES WITH WHOM PERSONAL INFORMATION IS SHARED
Us or Vendors.
PURPOSES OF THIRD PARTIES RECEIVING PERSONAL INFORMATION
Delivery of Services requested by you; processing and managing interactions and transactions; research and development; quality assurance; improving services, detecting and preventing fraud; security; safety; marketing and error/bug correction; defending or protecting our rights or property; responding to legal process. Any other purposes listed in this policy.
CATEGORY OF PERSONAL INFORMATION
6. Sensory or Location Data (e.g. recordings of customer service calls, location data from your device or inferred from your rough location such as zip code. Latitude/longitude)
SOURCE OF PERSONAL INFORMATION
Directly from you; mobile service providers; ISPs; SEO and SEM Agencies; Vendors
PURPOSES FOR COLLECTION
Delivery of Services requested by you; processing and managing interactions and transactions; research and development; quality assurance; improving services, detecting and preventing fraud; security; safety; marketing and error/bug correction.
defending or protection our rights or property; responding to legal process; account management; customized offers; targeted advertising; safety, security, compliance with legal obligations, for purposes that are compatible with the purpose of collecting your personal information that are not prohibited by law. Any other purposes listed in this policy.
CATEGORIES OF THIRD PARTIES WITH WHOM PERSONAL INFORMATION IS SHARED
Us or Vendors
PURPOSES OF THIRD PARTIES RECEIVING PERSONAL INFORMATION
Delivery of Services requested by you; processing and managing interactions and transactions; research and development; quality assurance; improving services, detecting and preventing fraud; security; safety; marketing and error/bug correction; defending or protecting our rights or property; responding to legal process. Any other purposes listed in this policy.
CATEGORY OF PERSONAL INFORMATION
7. Inferences from PI Collected (e.g. your preferences, likelihood of interest in certain of our services
SOURCE OF PERSONAL INFORMATION
Vendors; internal systems
PURPOSES FOR COLLECTION
Delivery of Services requested by you; processing and managing interactions and transactions; research and development; quality assurance; improving services; account management; customized offers; targeted advertising; safety, security, compliance with legal obligations, for purposes that are compatible with the purpose of collecting your personal information that are not prohibited by law.
CATEGORIES OF THIRD PARTIES WITH WHOM PERSONAL INFORMATION IS SHARED
Us or Vendors
PURPOSES OF THIRD PARTIES RECEIVING PERSONAL INFORMATION
Performing services; processing and managing interactions and transactions; quality assurance; improving our services; security; fraud prevention; marketing; errors/ debugging.
CATEGORY OF PERSONAL INFORMATION
8. Professional or Employment Information (such as information from a CV, title, education, experience, etc.)
SOURCE OF PERSONAL INFORMATION
Directly from you
PURPOSES FOR COLLECTION
Employment applications online; Delivery of Services requested by you; processing and managing interactions and transactions; research and development; quality assurance; improving services; account management; customized offers; targeted advertising; safety, security, compliance with legal obligations, for purposes that are compatible with the purpose of collecting your personal information that are not prohibited by law.
CATEGORIES OF THIRD PARTIES WITH WHOM PERSONAL INFORMATION IS SHARED
Us or Vendors
PURPOSES OF THIRD PARTIES RECEIVING PERSONAL INFORMATION
Performing services; processing and managing interactions and transactions; quality assurance; improving our services; security; fraud prevention; marketing; errors/ debugging.
CATEGORY OF PERSONAL INFORMATION
9. Any categories of personal information described in subdivision (e) of Section 1798.80 (e.g. 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.)
SOURCE OF PERSONAL INFORMATION
From You; Vendors
PURPOSES FOR COLLECTION
To process and respond to any forms, requests, inquiries, or other information submitted to us; to provide customer service; to provide products or Services; to complete contracts as well as any disclosures or other documents required by law; to support participation in promotions, competitions, sweepstakes and surveys and to administer these activities; to provide embedded social media services; to assist us in providing better products and Services including, to evaluate the performance of our staff, to assess the quality of our products and Services and to help us improve our Websites, facilities and Services; to ensure the security of our Website and information technology systems; to protect our rights and/or property or the rights and/or property of a third-party; to communicate about our products and/or Services; to customize the online ads, special promotions, e-mails, and other marketing information; in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); to have third-parties check the validity of the sort code, account number and card number of any credit or debit card that is provided as payment to prevent fraud; in other circumstances in which we believe our Digital Services, services and/or website are being or have been used in violation of our Terms of Use, applicable law or otherwise in the commission of a crime; when we have a good faith belief that there is an emergency that poses a threat to the safety of any person; to send direct marketing in relation to our relevant products and Services, or other products and services provided by us, our affiliates and partners; in response to requests by government or law enforcement authorities conducting an investigation; to fulfill a contract, or take steps linked to a contract, including fulfilling orders and taking payments and arranging the delivery or other provision of products, Services or prizes; to analyze our data; to conduct audits, security and fraud monitoring and prevention; to allow customers to access their online accounts.
CATEGORIES OF THIRD PARTIES WITH WHOM PERSONAL INFORMATION IS SHARED
Us or Vendors
PURPOSES OF THIRD PARTIES RECEIVING PERSONAL INFORMATION
Performing services on behalf of us; processing and managing interactions; research and development; quality assurance, improving our services; detecting and preventing fraud; security; safety; marketing and error/bug correction;
defending or protection of our rights or property; responding to legal process; law firms; customer relationship management (CRM) services providers, security, technology and cloud storage providers; automated calling or texting providers; event management vendors, collections companies, online meeting providers; Vendors; and any other purposes listed in this policy.
In addition, we may collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.
We do not “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA/CPRA and will treat personal information we collect from you as subject to a do not sell request. You can exercise control over browser-based cookies by adjusting the settings on your browser.
Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you, so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.
Certain Consumers have the right to exercise the privacy rights under US State Privacy Law. These rights may be exercised via your authorized agent who meets the agency requirements under applicable law. Any request you give to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your request unless you have supplied sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. Please follow the instructions below and respond to any follow-up inquiries we may make.
Some personal information we keep about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by applicable law, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot follow a request, we will explain the reasons in our response to you.
We will make commercially reasonable efforts to find Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your applicable state law privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
To make a request according to your right to request deletion of your PI set forth below, you may send a request by email (including the email address that you have used to transact with us to privacy@ensolvers.com.
Generally you have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date, by sending a request by email (including the email address that you have used to transact with us) to privacy@ensolvers.com:
The categories of PI we have collected about you.
The categories of sources from which we collected your PI.
The business or commercial purposes for our collecting or selling your PI.
The categories of third parties to whom we have shared your PI.
The specific pieces of PI we have collected about you.
A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we would explain: the categories of your PI we have sold; and the categories of third parties to which we sold PI, by categories of PI sold for each third party.
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining, by sending a request by email (including the email address that you have used to transact with us privacy@ensolvers.com.
Please note that PI is kept by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
Except to the extent we have a basis for retention under applicable US State Privacy Law, you may request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.
We will not discriminate against you in a manner prohibited by applicable law because you exercise your rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your PI as allowed by certain US State Privacy Law that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that taking part in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e. terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.
14. Employment Applications.
If you choose to apply online for employment with us, we collect personal information about you to assess your suitability for employment. When you apply for employment with us, we also collect additional Personal Information such as, without limitation: your maiden name; alias; marital status; date and place of birth; former home addresses; employment history; current and former employer names and addresses; state/governmental identification number; tax and withholding information; social security number; emergency contact information; and other types of information that you choose to provide to us or that we may obtain about you.
15. Google Workspace API Disclosure.
At OOTB, we want to be transparent about our use of technology and data. In that context, we want to clarify that Google Workspace APIs are not utilized in the development, improvement, or training of generalized Artificial Intelligence (AI) and/or Machine Learning (ML) models by our solutions. Our focus is on leveraging our own proprietary technology and data processing methods to enhance the functionality and performance of the platform. We prioritize data privacy and security, and any data collected through our platform is used solely for the purposes outlined in this Privacy Policy.
16. Contact Us
If you have questions or concerns regarding the way in which your personal data is being processed or this Privacy Policy, please email us at privacy@ensolvers.com or reach out to us using the contact information below:
OOTB LABS, INC.d/b/a Ensolvers
2875 NE 191stSte, Ste 801
Aventura, Florida 33180
United States
