This Privacy Notice has been compiled to assist you (“you,” “your,” or “User”) to understand how Accucom Corporation ("we", "our", or "us") and our affiliates and subsidiaries, collect, use and disclose your personal information.
This Privacy Notice describes our practices in connection with information that we collect through your use of the IDStrong website (the “Site”), any mobile sites, applications, widgets, and other mobile interactive features associated with the Site (collectively, our “Apps”), through other services that we may offer in connection with our Site and Apps, through our official social media pages that we control (our “Social Media Pages”), as well as through email messages that we send to you (collectively, the Social Media Pages, Apps and Site, may be referred to as the “Sites”).
This notice does not apply to information collected or obtained by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Sites.
By accessing, browsing, or otherwise using the Sites, you acknowledge and consent to our collection and use of information as set forth in this Privacy Notice. PLEASE READ THIS PRIVACY NOTICE CAREFULLY. YOUR USE OF THE SITES CONSTITUTES YOUR CONSENT TO THIS PRIVACY NOTICE. DO NOT USE THE SITES IF YOU ARE UNWILLING OR UNABLE TO CONSENT TO THIS PRIVACY NOTICE.
This Privacy Notice applies only to your use of the Sites, and was last updated as of July 24, 2020. We may revise this Privacy Notice at any time and such revision shall be posted here and accessible via this link: https://idstrong.com/privacy. Any revision and/or addition to this Privacy Notice shall become effective and binding on you when you continue to use the Sites on or after the effective date of such revision and/or addition.
The Information We Collect
Information You Choose to Provide to Us
When using the Sites, you may choose to provide us with certain personal information, including:
- Your name, contact information, and other related information to inquire into our services, to report a problem with our Sites, or to contact customer service;
- Your name, contact information, information to verify your identity, financial information and other related information to register an account (“User Account”) and use our services;
- Your name, contact information, and other related information when you provide us with information, such as service reviews, to be published or posted on public areas of the Sites, or transmitted to other users of the Sites or to third parties (collectively, "User Contributions"). Contributions are submitted at your own risk. We cannot control the actions of other users of the Sites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information Collected from Third-Parties
We may collect personal data about you from third-parties such as:
- Credit reporting agencies and financial institutions (used for purposes such as identity theft protection services);
- Marketing and joint-marketing partners (used for purposes such as to offer products/services and/or joint product bundles to prospective members); and
- Public sources (such as The Dark Web to alert you to potential misuse of your data, and Data Broker sites allowing you to remove your data at your discretion, and other sources for purposes such as to identify prospective customers or alert customers to potential fraud).
Information Collected Via Your Use of our Sites
We may collect information about you when you are using the Site in a number of different ways; for example:
- We may collect and track your IP address; and/or
Information We Collect Automatically
We may now or in the future use tools, including third-party analytical software, to collect automatically certain data about the computer or other device you use to reach our Sites, without any active submission of information from you, such as:
- 1. Device properties including, but not limited to, unique or other device identifiers;
- 2. Device operating system and firmware;
- 3. IP address (i.e., a number that is automatically assigned to your device or computer used to access the Site, and allows us to identify your device or computer) and Internet service provider;
- 4. Mobile phone carrier;
- 5. Geographical data such as country or region; and
- 6. Other similar data.
This information may be collected via several technologies, including cookies, web beacons, clear GIFs and other means. All of this information belongs to us, and we use it to improve effectiveness, content, layout and/or operation of our Site. You can remove certain cookies by following the directions in your Internet browser’s “help” file (see below). If you disable cookies, your ability to use areas of the Site may be limited. Additional information regarding cookies is available below.
How We Use Your Information
In general, we do not and will not share your personally identifiable information except as set forth in this Privacy Notice. We generally do not sell, transfer, and/or share your personally identifiable information with third parties for their own marketing purposes.
We use the information we collect from you when you browse our Sites in the following manner:
|Categories of Personal Information||Use of Information|
|Identification information, Users Messages, application usage data (e.g., features/pages accessed by a member), location data (GPS).||To operate and improve the Sites and associated services.|
|Identification information, User Message, application usage data (e.g., features/pages accessed by a member), location data (GPS).||To understand and analyze information related to the number and type of visitors that browse and use the Sites.|
|Name, phone number, mailing address, email address, and credit report information.||To provide you with information, products, or services that you request from us, or that may be of interest to you.|
|Contact information (such as name, address, phone number, and email address); sensitive information (such as date of birth, driver’s license number and social security number); personal information to verify your identity and financial information (such as credit card number).||To verify your identity, charge you the agreed upon fees for our Services, and to fulfill our obligation to provide our Services to you, including communicating with third parties as necessary to provide such Services, such as identification verification companies, consumer reporting agencies, credit bureaus, payment validation companies, law enforcement agencies, or others.|
|Name, phone number, mailing address, email address.||To respond to your comments, inquiries and questions and provide customer services.|
|Name, phone number, mailing address, email address.||To permit you to participate in social sharing, including live social media feeds.|
|Name, phone number, mailing address, email address.||To send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies. Because this information may be important to your use of the Sites, you may not opt-out of receiving these communications.|
|Name, mailing address, email address, phone number, demographic information||To link or combine with other personal information we get from third-parties, to help understand your needs and provide you with better information on the Site.|
|User Contributions||To post on the Sites and transmit to others, including third-parties and other users.|
|Name, mailing address, email address, phone number, demographic information||To fulfill any other purpose for which you provide it or for which you have given us consent to use it.|
You can opt-out of certain use(s) of your personal information, as described below.
How We Use Automatically Collected Information
The information we collect automatically is statistical data and generally does not contain personal information. However, we may maintain it or associate it with personal information we collect in other ways or receive from third parties. We will use this automatically-collected information to improve our Sites and to deliver a better and more personalized service, including to:
- Estimate our audience size and usage patterns;
- Store information about your preferences, allowing us to customize our Sites according to your individual interests;
- Speed up your searches; and
- Recognize you when you return to our Sites.
We want to be completely transparent about the cookies we use and to make their control as easy as possible for you. When you first enter our Sites, you will be asked to accept or reject cookies via the Cookie Notice.
Further, if you want to delete any cookies that are already on your computer, please refer to the file management software to locate the file or directory that stores cookies under the following file names. Other information on deleting or controlling cookies is available at www.allaboutcookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.
Access to Your Personal Information
YOUR PERSONAL INFORMATION WILL NOT BE SOLD. Nor will Your Personal Information be licensed or disclosed to unaffiliated third-parties, except in connection with the sale, transfer, merger, consolidation or other transaction involving all or part of our company or as may be permitted under applicable law.
We may disclose your personal information to our subsidiaries and affiliates to fulfill the purpose for which you provide it, for example, to provide you with a requested communication.
In addition to the above, we may share the information collected from you, as described above, with our third party partners to enable us to analyze and use such information to provide you with our products and services, and in the manner set forth in this Privacy Notice. We may share your information with third-parties who assist us with its outreach and engagement communications to make you aware of certain of our products and services. We also allow our website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, to access and process your information so long as those parties agree to keep this information confidential. We do not sell your information to third parties for marketing purposes, and we restrict such third parties’ usage of your information consistent with this Privacy Notice.
Protection Your Information
We follow industry standard practices to protect, secure and maintain the integrity and availability of your information. The Site and our internal networks supporting the Site are scanned regularly for malware and other viruses. We use the Secure Socket Layer (SSL) to ensure that all the information you provide is encrypted and cannot be read as the information travels over the Internet. SSL is a worldwide industry standard for such sensitive transactions.
This Site is not intended to collect, maintain, or transmit any information related to your credit card, banking information, or other related financial information.
Notwithstanding the foregoing, you acknowledge that no security safeguards or method of transmission over the Internet are completely secure. Unfortunately, the transmission of information via the internet is not completely secure. Although we engage in best practices in order to protect data, we cannot guarantee the security of your personal information transmitted to our Sites. Any transmission of personal information is done at your own risk. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Geographic Location of Data Storage and Processing
The Sites collect information and process and store that information in databases located in the United States. If you are visiting the Sites from a country outside the United States, you should be aware that you may transfer personally identifiable information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Site and submitting any personally identifiable information you consent to the transfer of such personally identifiable information to the United States.
Additional information for international visitors can be found below.
The Length of Time that Your Information is Kept by Us
We store your information for as long as necessary to serve the business purposes for which it was collected and in conformance with applicable data protection laws. For additional information on the retention periods for any specific type of personal information subject to this Privacy Notice, please contact firstname.lastname@example.org.
Removal from Our Communications
Throughout the Sites, we provide you with the opportunity to receive emails or mailings that, for example, introduce new services, notify you of special offers, and announce upcoming promotions. To be removed from our email or mailing lists, you may
- Respond to the emails that we send out with your request for removal or
- Click the “unsubscribe” link (where available).
Please be aware that there may be a delay between our receipt of your request and our being able to update our lists. Thank you for your patience in this regard.
Third-Party Links On the Sites
Occasionally, at our discretion, we may link to third party sites or content on the Sites. We may do this for the convenience of you and other users of the Sites, but we do not have control over the operation of these third-party websites. These third-party sites have separate and independent privacy notices. We, therefore, have no responsibility or liability for the content and activities of these linked sites.
Nonetheless, we seek to protect the integrity of our Sites and welcome any feedback about these third party sites. We urge you to review the privacy notices posted on these third-party websites at the time you first visit such sites.
The California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws provides California residents (i.e., consumers) with specific rights regarding personal information. This section of the Privacy Notice describes those CCPA rights and how to exercise those rights. This section does not apply to publicly available information.
Access to Specific Information and Data Portability Rights
California residents have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm a verifiable consumer request from you, we will disclose to you, to the extent permitted by law:
- The categories of personal information we collected about you.
- The categories of sources for your personal information we collected about you.
- Our business or commercial purpose for collecting your personal information.
- The categories of third parties with whom we share your personal information.
- If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
You shall have the right to request that the information described above be provided to you in a portable and readily usable format, to the extent technically feasible (“data portability”).
We do not sell your personal information.
Deletion Request Rights
You have the right to request that we delete certain of your personal information that we collected from and/or related to you and retained, subject to certain exceptions.
To the extent that we can delete your personal information, once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected your personal information, provide a good or service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Contacting us at email@example.com; or
- Calling us, at 800-470-7489.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with your personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. Any disclosures provided pursuant to the CCPA will only cover the 12-month period preceding the receipt of the verifiable consumer request.
We will respond to a verifiable consumer request within 45 days of its receipt, or notify you that we require more time to respond and the reason for the extended response time. We will deliver the written response by mail or electronically, at your option.
To the extent that your verifiable consumer request is excessive, repetitive, or manifestly unfounded, we may charge a reasonable fee to respond to such request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
The Site is not intended for use by persons outside of the United States or non U.S. Residents. We do not knowingly solicit, collect, maintain or disclose any Personal Information from non U.S. residents. If you are not a resident of the United States, please do not:
- create or attempt to create an account on the Sites;
- sign up for any service via the Sites; or
- otherwise interact with the Sites.
Do Not Track Notice
We may not recognize or respond to every type of “do not track” signal or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services, but we give you certain choices about how we collect personally identifiable information as described in this Privacy Notice. Many Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site including certain opt-out cookies.
We encourage you to review the privacy policies of our third party advertisers and analytics service providers to learn about your choices about information they collect from you. In addition, the Network Advertising Initiative offers information about some of the Internet advertising companies we may use, including how to opt-out of interest based advertising they deliver. For all the details, including how to turn on Do Not Track, visit www.donottrack.us.
Not Intended for Children Under 13
The Site is not intended for use by persons under the age of 18 and we do not specifically market to children under 13. We do not knowingly solicit, collect, maintain or disclose any Personal Information from children under the age of 18. If you are under the age of 18, please do not:
- create or attempt to create an account on the Sites;
- sign up for any service via the Sites; or
- otherwise interact with the Sites.
You may add the protection of certain of our services to minors in your household, but we only process that personal data at your direction and in order to provide those specified Services. By providing such information for processing, you confirm that you are authorized to act on behalf of the minor.
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 by email or through a notice on our website homepage.
If there are any questions regarding this Privacy Notice you may contact us using the information below:
227 Lewis Wharf
Boston, MA 02110