Privileged & Confidential:
ZG Edits 08-28-23
Effective Date: [September, 2023]
This Privacy Policy describes the information protection practices of Blend360 (“Blend360,” “we,” “us,” or “our”). This Privacy Policy applies to information that we collect and use about you when you access or use an Blend360 website, other online or offline Blend360 services, or communicate or interact with us; and it also covers the information we may collect and process about you from third party services to build our data products ("Data Products"). We refer to all of our products and services collectively as the “Services.”
Please note that this Privacy Policy does not cover the activities Blend360 undertakes on behalf of its clients under an agreement (“Services Agreement”) in which it acts as a service provider. Should you wish to inquire about the processing we undertake for any of our clients under a Service Agreement, or wish to assert your rights regarding that processing, please contact the relevant client directly.
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
This Policy contains the following sections:
HOW DO WE USE YOUR INFORMATION?
ONLINE ANALYTICS AND ADVERTISING
WHO DO WE DISCLOSE THIS INFORMATION TO, AND WHY?
HOW DO YOU EXERCISE YOUR RIGHTS AND CHOICES?
HOW IS YOUR INFORMATION SAFEGUARDED?
HOW LONG IS YOUR INFORMATION RETAINED?
ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
NEVADA RESIDENT RIGHTS
We collect information about you from various sources:
Information You Provide to Us
We collect a variety of information that you provide directly to us. For example, we collect information from you through:
The types of information we may collect directly from you includes:
Information We Collect Through Automated Means
When you use our Services, we and our service providers (who are third parties that perform services on our behalf) automatically collect certain information about your device and how you use the Services, including your IP address, browser type, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), number of clicks, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, and other similar information. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).
To collect this information, we and our service providers may use "cookies" or similar tools that track, measure, and analyze the behaviors and usage patterns of our users. Cookies are small information files that can be stored on your browser and device so we can recognize you when you return. We use cookies for analytics purposes, to deliver certain features of the Services, to help us understand how users engage with the Services, and to improve your experience. You may set your web browser to notify you when you receive a cookie and to accept or refuse certain cookies. However, if you elect not to accept cookies, some functionality and areas of the Services may be restricted. For more details, please refer to our Cookie Policy.
Information We Collect from Others
From time to time, we may collect information about you from other sources, including our affiliates, marketing vendors, and third-party databases. We use this information to supplement the information that we collect directly from you and for any of the purposes described in the next section.
As part of our Data Products, we collect a variety of information from partners and public sources, which may include:
When you "like" or "follow" us on Facebook, LinkedIn, Twitter or other social media sites, we may collect some information from you including your name, email address, and any comments or content you post relevant to us.
We use your information for various purposes depending on the types of information we have collected from and about you, including to:
Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.
Aggregated/Anonymized Information. We may aggregate and/or anonymize information collected through the Services so that such information does not identify you as the source of the information. We may use such information to improve the Services, for research and marketing purposes, and may also disclose such information to third parties, including advertisers, promotional partners, customers, and sponsors.
Analytics. We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here . If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture information such as when you open our message or click on any links or banners our email contains. This information allows us to gauge the effectiveness of our communications and marketing campaigns.
Online Advertising. In using the Services, we may allow select third party advertising technology partners to place cookies or other tracking technologies on the browser of your device to collect information about you as discussed above. These third parties may use this information to serve relevant content and advertising to you as you browse the Internet, and access their own cookies or other tracking technologies on your browser to assist in this activity. If you are interested in more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out link , the Digital Advertising Alliance's Consumer Opt-Out link , or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. You can also opt out of certain online advertising activities by following the instructions in the "How Do I Exercise My Consumer Privacy Rights and Choices" section below. Please note that if you use these mechanisms, you may still see advertising on our Services or across the Internet, but it will not be tailored to you based on your online behavior over time.
Do Not Track ("DNT"). DNT is a privacy preference that web users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services through cookies and similar technologies, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. Please note that DNT is a different functionality from the legally-required browser-based global privacy control signal, which Blend360 does honor in accordance with applicable legal obligations.
Like many businesses, we sometimes have companies perform certain business-related functions for us. These companies include our database service providers, backup and disaster recovery service providers, email service providers, professional advisors, and others. When we engage these companies, we may provide them with your information, including personal information, so they can perform their designated functions. They are not permitted to use your personal information for other purposes than as set forth in our agreement with them.
We may also disclose your information:
Email Communications If you wish to update your email marketing preferences, or unsubscribe, you can do so by clicking the unsubscribe link in the bottom of the email or by emailing us at [email protected]. Please note that even if you unsubscribe, we may still send you transaction-related communications.
Your Legal Rights
You can make more specific requests with respect to your personal information depending on where you live. Your local law may permit you to request that we:
Such laws may also permit you to revoke your consent to the processing of your information for certain purposes. We will consider all requests and provide our response within the time-period stated by applicable law and as otherwise required by applicable law. However, certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. Depending on applicable law, you may have the right to appeal our decision to deny your request. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
As provided in applicable law, you also have the right to not be discriminated against for exercising your rights.
If you are a client end user and your information has been collected by Blend360 as a result of our Client's use of the Services pursuant to a Service Agreement between Client and Blend360, Blend360 collects and processes any information of yours under the directions of the relevant client. If these circumstances apply to you and you wish to access, correct, delete or exercise any rights you may have under applicable information protection laws with respect to any information that we have collected about you, please direct your query to the relevant client, as this may expedite the completion of your request. We will provide reasonable assistance to our client to give effect to information subject rights as appropriate and required by applicable laws.
Notice of right to opt out of sales of personal information and processing/sharing of personal information for targeted advertising purposes
Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”
As explained in the “Who We Disclose This Information To, and Why” section above, we sometimes disclose information to our clients in connection with our Data Products so that our clients can provide offers that may be of value to you. We also provide information to third-party advertising providers for targeted advertising purposes or use advertising analytics partners to assist us in analyzing use of our services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the “processing/sharing of personal information for targeted advertising purposes.”
If you would like to opt out of the disclosure of your personal information, through cookie and pixel technology, for purposes that could be considered “sales” for those third parties' own commercial purposes, or processing/sharing of personal information for targeted advertising purposes”, please visit the following link, available here. Note that you will need to opt out on each device you use to access the Services. To opt out of our disclosure of your information to our clients and partners in ways that could be considered "sales" or " processing/sharing of personal information for targeted advertising purposes," but where the disclosure is not cookie/pixel-based, please email us at [email protected].
Please note that we do not knowingly sell the personal information of minors under 16 years of age.
Blend360 is committed to securing your information and keeping it confidential. We've taken reasonable precautions to safeguard all the information we collect online to prevent information theft, unauthorized access, and disclosure. However, no Internet or email transmission is ever fully secure or error-free. Please keep this in mind when disclosing any information to us online.
Our website contains links that lead to other websites. If you click on these links, Blend360 is not held responsible for your information and privacy protection. Those websites are not governed by Blend360 or this Privacy Policy.
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws.
Our Services are primarily located in the United States. Your use of the Services may therefore involve the transfer of your information to locations outside of the country where you reside. The level of information protection in countries to which your information is transferred may be less than that offered within the original country. Where this is the case, we will implement appropriate measures to ensure that such information remains adequately protected and secure in accordance with applicable data protection laws.
If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. Our use of third-party online advertising services, which are described in detail above, may result in the disclosure of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” or "sharing" under the CCPA.
The following chart details these activities:
For more information about each category of personal information, purpose of use, and third parties to which we disclose personal information, please see the “What User Information We Collect?,” “How Do We Use Your Information?,” “Who Do We Disclose This Information To, And Why?" sections of our Privacy Policy.
Your Choices Regarding “Sharing” and “Selling”: You have the right to opt out of our sale/sharing of your personal information for purposes of online analytics and advertising through cookie/pixel technologies by clicking here. To opt out of the disclosure of your information to third parties for these purposes other than through cookie and pixel technology, please email us at [email protected].
Other CCPA Rights. If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.
The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.
Please see the "How Do You Exercise Your Privacy Rights and Choices" section of our Privacy Policy above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.
Retention of Your Personal Information. Please see the “How Long Is Your Information Retained?” section above.
Shine the Light Disclosure
The California "Shine the Light" law gives residents of California the right, under certain circumstances, to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. Please email us at [email protected] to make such a request.
We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our information collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the date included at the beginning of the document. If we make a material change to the Privacy Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.
Please feel free to contact us if you have any questions about the Privacy Policy or the information practices of the Services. You can reach us via:
Email: [email protected]
Mail: 10221 Wincopin Circle, 3rd Floor, Columbia, MD 21044
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