Last Updated: December 22, 2022
Scope and Overview
Our processing of personal information, such as your name, address, e-mail address, or telephone number, will be undertaken consistent with the requirements of applicable privacy laws, including, but not limited to, the California Consumer Privacy Act (“CCPA”) the California Privacy Rights Act (“CPRA”), and to the extent applicable, General Data Protection Regulation (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”), and the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”).
Personal Information We Collect About You
We receive a variety of personal information from and about you. We have collected the following categories of personal information from consumers within the last twelve months and disclosed or sold/shared for purposes of behavioral advertising:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone numbers, account name, Social Security number, date of birth, driver's license number, passport number, or other similar identifiers.||Yes||Organizations providing services to Company, Affiliates, Third Parties|
|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||Organizations providing services to Company, Affiliates, Third Parties|
|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).||Yes||Organizations providing services to Company|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes||Organizations providing services to Company, Affiliates|
|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||Organizations providing services to Company, Affiliates, Third Parties|
|G. Geolocation data.||Physical location or movements.||Yes||Organizations providing services to Company, Affiliates, Third Parties|
|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, state date and job title, location of employment, education and training, employment records (including profession memberships, references, work history, and proof of work eligibility).||Yes||Organizations providing services to Company, Affiliates|
|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||Organizations providing services to Company, Affiliates, Third Parties|
Automatically Collected Information When You User our Site
In order to access and use certain areas or features of the Company Services, you consent to our collection and use of certain information about your use of the Company Services through the use of tracking technologies or by other passive means. Your consent to our access and use of this “passively collected” information includes, but is not limited to, the domain name of the website that allowed you to navigate to the Company Services, search engines used, the internet protocol (IP) address used, the length of time spent on the Company Services, the pages you looked at on the Company Services, other webpages you visited before and after visiting the Company Services, the type of device and/or internet browser you have, the frequency of your visits to the Company Services, and other relevant statistics (collectively “Traffic Data”).
How we Collect Your Personal Information
We collect personal information about you in a variety of different ways:
- When you access, use, or contact us through the Company Services.
- When you voluntarily provide information through the Company Services.
- If you use a location-enabled browser, we may receive information about your location and device.
- Through Cookies, Web Beacons, analytics services and other tracking technologies (collectively, “Tracking Tools”)
We do not use “Dark Patterns” or undisclosed mechanisms to record your consent.
“Do Not Track” (DNT) and Universal Opt-Out Preference Signals
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to web services that a visitor does not want to have their online activity and behavior tracked. Historically, there has not been consensus on what constitutes a DNT signal, so many web sites do not honor them, including this one. For more information about DNT signals, visit http://allaboutdnt.com.
New standards are being developed for a Universal Opt-Out Mechanism, such as the Global Privacy Control (GPC), which allow users with GPC-enabled browsers and devices to send a signal that will communicate the user’s request to opt-out of sales of their personal information and to opt-out of certain sharing of their personal information. The CPRA and other laws allow for the acceptance of Opt-Out Preference Signals such as the GPC, as an option for users to transmit an Opt-Out of selling/sharing personal information. If we detect and recognize such a signal from your device or browser, we will honor it. As an alternative, if you wish to opt-out of the selling or sharing of your personal information for these purposes, please access the following link:
How We Use Your Personal Information
We may use or share information (including information that has been de-identified and/or aggregated) to better understand who uses the Company Services and how we can deliver a better user experience. We use or shareinformation, including personal information, to provide the Company Services and to help improve the Company Services, to develop new services, and to advertise our services. Specifically, such use or sharing may include:
- Providing you with the products, services and information you request.
- Corresponding with you.
- Providing, maintaining, administering or expanding the Company Services, performing business analyses, and for other internal purposes.
- Showing you advertisements, including interest-based or online behavioral advertising.
- Fulfilling our legal obligations, such as preventing, detecting and investigating security incidents, fraud, and potentially illegal or prohibited activities.
You will not be subject to decisions based on automated data processing without your prior consent.
Disclosure of Your Personal Information
In certain circumstances, and in order to perform the Company Services, we may disclose certain information about you as described in this section:
- Although we do not sell your personal information in the traditional sense, the definition of “sale” under the California law is very broad and may cover many common business activities not otherwise considered selling information for money, such as sharing certain technical information with third party data analytics, marketing, and advertising partners. You have a right to opt-out of this sharing. We may share your personal information with our partners to customize or display our advertising.
- We may disclose your personal information with our partners to customize or display our advertising.
- We may disclose your personal information and/or Traffic Data with our partners who perform operational services for us (such as hosting, billing, fulfillment, data storage, security, insurance verification, web service analytics, or ad serving).
- We may disclose your personal information and/or Traffic Data with our partners to analyze device activities and generate targeted advertisements.
- We may transfer your personal information to another company in connection with a proposed merger, sale, acquisition or other change of ownership or control by or of Company (whether in whole or in part). We will make reasonable efforts to notify you before your information becomes subject to different privacy practices.
You have indicated that you do not “sell” personal information in that you do not track user behavior with third party cookies. However, the definition of sale is broad and if you’re doing targeted ads, then I recommend indicating that you do sell/share information as indicated here.
[IF APPLICABLE (Collection of Sensitive Person Information (SPI) for purposes of inferring characteristics about a consumer)]
Collection and Use of Sensitive Information
We have collected the following categories of personal information from consumers within the last twelve months:
- Government Identifiers;
- Complete Account Credentials;
- Racial or Ethic Origin;
- Religious or philosophical beliefs;
- Union Membership;
- Genetic Data;
- Mail, email, or text message contents;
- Unique identifying biometric information; and/or
- Health, sex life, or sexual orientation.
We [do/do not] use or disclose sensitive personal information for purposes other than those allowed for ordinary business purposes in the CCPA/CPRA.
Sharing of Personal Information
In the preceding twelve (12) months, we have shared the following categories of personal information:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information.
We share your personal information to the following categories of third parties: affiliates, organizations providing services to the Company and third parties.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider our statutory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means.
Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
Your Rights and Choices
The CCPA/CPRA provides consumers (California residents) with specific rights regarding their personal information. If you live in another state you may not be entitled to some or all of these rights. If these laws apply to you, this section describes your CCPA/CPRA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Right to Correct
You have the right to request that we correct inaccurate personal information regarding the information you provide us.
Do Not Sell or Share My Information
If you qualify under applicable law, you have the right to opt out of sale of your personal information to a third party or to opt out of sharing of your personal information for cross contextual behavioral advertising. Please note that this does not stop us from distributing this information within our organization across business units. Additionally, your right to opt out does not stop all transfers to third parties as we can continue to provide your personal information to our service providers pursuant to a written contract that meets requirements within the CCPA. Furthermore, we can continue to provide data that does not meet the definition of personal information.
This right to opt out applies to all California consumers ages 16 or older and may be exercised at any time. We will honor all such requests unless you subsequently decide to opt in to the sale of your personal information.
The sale of personal information does not include if you direct us to interact with a third party, any third party alerts that you have opted out of, the sharing of information is necessary to perform a business purpose and meets the other conditions specified, or the information is transferred as part of an asset in a merger, acquisition, bankruptcy or other change of control event.
You may also opt out by broadcasting the global privacy control signal.
If you wish to exercise your right to opt out, please submit a request via DataPrivacy@unitedsiteservices.com. We will honor your request for twelve (12) months before we ask you to opt in to the sale of your personal information.
Right to Restrict the Use of Sensitive Personal Information
You have the right to restrict the use of your sensitive personal information. You may (i) request that we restrict the use of their sensitive personal information; (ii) direct an us to limit its use of sensitive personal information to specific business purposes; and (iii) instruct us to limit disclosure of sensitive personal information, absent a qualifying exemption.
If you wish to exercise your right restict the use of Senstive Personal Information, please submit a request via the following link:
Right to Access Information on Automated Decision-Making
You have the right to access information collected through automated decisiosn-making and the explanation behind our collection. Additionally, you can opt-out of our use of automated decision-making related to your performance, health, behavior, reliability and location/movement.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, 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 the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract 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 );
- 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; and
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, Correction and Deletion Rights
To exercise the access, data portability, opt out, and deletion rights described above, please submit a verifiable consumer request to us in one of the following ways:
By E-Mail: firstname.lastname@example.org
Or at our mailing address:
United Site Services
118 Flanders Street Ste 1000
Westboro, Massachusetts, 01581
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; and
- 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 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.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate or retaliate against you for exercising any of your CCPA/CPRA rights.
Not Open to EU Users
The Site is controlled and operated by us from the United States, and is not intended to subject us or any Affiliated Entity to the laws or jurisdiction of any state, country or territory other than that of the United States. We do not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. The Company does not offer goods or services specifically targeted at the European Union or its residents. If you are a resident of the EU, these services are not intended for your use and are not intended to target you for goods or services.
Canada, European Union and United Kingdom Privacy Rights
If our processing of your personal information is subject to GDPR, UKGDPR, and/or PIPEDA, and unless subject to an exemption, you may have the following rights with respect to your personal information:
- To request a copy of the personal information we hold about you and where possible, to transmit that data directly to another data controller.
- To request we correct any personal information about you.
- To request your personal information be erased when no longer necessary for us to retain such data;
- To withdraw your consent to the processing of your personal information.
- To request a copy of the personal information we hold about you.
- Where there is a dispute in relation to the accuracy or processing of your personal information, to request a restriction be placed on further processing.
- To object to the processing of personal information (where applicable).
- To lodge a complaint with a data supervisory authority.
We will need to verify your identity to process any requests described in this Section and may deny your request if we are unable to verify your identity. Government or other identification may be required.
If you are a resident of the European Economic Area (“EEA”), when we process your personal information, we will only do so in the following situations:
- We need to use your information to perform our responsibilities under our agreement with you.
- We have a legitimate interest in processing your personal information. For example, we may process your personal information to send you marketing communications, to communicate with you about the Company Services, and to provide and improve the Company Services.
- We have your consent to do so.
If your personal data is subject to GDPR or UK GDPR, we will transfer personal data from the EEA to a location outside the EEA only when there has been a documented adequacy determination, or where we have confirmed adequate privacy protections. If your personal data is subject to PIPEDA, we will transfer personal data from Canada to locations outside Canada only where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place.
Changes to This Privacy Notice
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.
By visiting this website or providing the Company with personal information, you agree to receiving communications by electronic means or other method at the sole discretion of the Company.
If you have any questions or comments about this Privacy Notice, the ways in which we collect and uses your information described int his policy your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us:
By email at: DataPrivacy@unitedsiteservices.com
Or our mailing address at:
United Site Services
118 Flanders Street Ste 1000
Westboro, Massachusetts, 0158
Last Updated: December 22, 2022