Section Summary: This Policy explains how we may Process your information. This Policy may be amended or updated from time to time, so please check it regularly for updates.
Abrigo (“Abrigo”, “us”, “our” or “we”) owns or operates several websites, applications, and other online interactive features and services, including, but not limited to, emails, newsletters, communities, and webinars (collectively “Services”). This Policy applies to all information collected about you by Abrigo, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.
Except as otherwise noted in this Policy, Abrigo is a data controller pursuant to EU General Data Protection Regulation (GDPR) and other authoritative guidance, which means that Abrigo decides how and why the information you provide to us is processed. You can contact us using the information shown in the Contact Details section below. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully and to regularly check this page to review any changes we might make.
This Policy covers information collected through the following websites:
- Mainstreet Technologies
- Banker’s Toolbox
- Farin & Associates
Additionally, this Policy covers information collected through the following applications (“Customer Applications”):
- Sageworks Analyst
- Loan Loss Analyzer
- IQ AutoScan
Categories of Information Processed
Section Summary: We may Process your personal details (e.g., your name), demographic data (e.g., your age), your contact details (e.g., your address), records of your consents, details of your employer (where relevant), information about your interactions with our content or advertising, and any views or opinions you provide to us. We may also Process information about you from your use of our Services (e.g., the type of device you are using, the internet service provider, etc.), including your interactions with content and advertising on the Services.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.
“Process”, “Processing,” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
We may Process the following categories of Personal Information about you:
- Personal details: your name; username or log in details; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).
- Demographic information: gender; age/date of birth; nationality; salutation; job title, company information, education, work experience and other professional information; and language preferences.
- Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
- Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
- Location information: location data that describes the precise geographic location of your device (“Precise Location Data”).
- Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.
- Employer details: where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant.
- Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Services, including on forums.
We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:
- Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet and generally includes internet service provider.
- Device type and settings, including browser and other software used.
- Websites or other services you visited before and after interacting with the Services.
- Search terms used to find and link to the Services.
- Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
- Information collected using cookies, pixel tags, local storage, anonymous identifiers, and other technologies, including information collected using such methods and technologies about:
- Your visits to, and interaction and engagement with, the Services, content and ads on third-party websites, applications, platforms and other media channels (“Channels”), and
- Your interaction with emails including the content and ads therein (collectively, “Online Data”).
- Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
- Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps, and/or clickstream data, including any clicks on customized links.
Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information.”
Sensitive Personal Information
Section Summary: We do not seek to collect or otherwise Process your Sensitive Personal Information. Where we need to Process your Sensitive Personal Information for a legitimate purpose, we do so in accordance with applicable law. The Services are not intended for use by children.
We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business. Where it becomes necessary to Process Sensitive Personal Information under GDPR, we would rely on one of the following legal bases:
- Compliance with applicable law. We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law;
- Detection and prevention of crime. We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
- Establishment, exercise, or defense of legal rights. We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise or defense of legal rights; or
- Consent. We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.
Collection & Creation of Information
We may collect User Information about you from the following sources:
- Data you provide. We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters, webinars or white papers; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, competition or prize draw; receive promotional information by SMS text message; participate in surveys; perform search queries through the Services; contact us via email, telephone or by any other means; purchase a subscription, software license or product; or when you provide us with your business card, etc.).
- Relationship data. We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us).
- Data you make public. We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the Services.
- Service data. We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
- Content and advertising information. If you choose to interact with any third-party content or advertising on the Services or Channels, we may receive User Information about you from the relevant third party.
- Third-party information. We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available, or publicly-available sources (e.g., data brokers, data aggregators, public databases, etc.); third-party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.).
Please note that Abrigo is not responsible for the information you volunteer about yourself in the discussions in certain areas of the Services, such as forums, blogs, communities, message boards, or other publicly accessible interaction, or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page. To request removal of your Personal Information from these areas, please contact us by emailing email@example.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.
This Policy does not cover the practices of third parties, including those that may disclose information to Abrigo.
We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities.
Basis for Processing Personal Information
Section Summary: We may Process your User Information where you have given your consent, the Processing is necessary for a contract between you and us, the Processing is required by applicable law, the Processing is necessary to protect the vital interests of any individual, or where we have a valid legitimate interest in the Processing.
In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:
- Consent. We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
- Contractual necessity. We may Process your User Information where the Processing is necessary in connection with any contract that you may enter into with us;
- Compliance with applicable law. We may Process your User Information where the Processing is required by applicable law;
- Vital interests. We may Process your User Information where the Processing is necessary to protect the vital interests of any individual; or
- Legitimate interests. We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
As described above, we have identified how we market our business to our current and prospective customers as having a legitimate interest.
Purposes for Processing Your Information
Section Summary: We may Process User Information for the purposes of providing the Services to you, communicating with you, providing advertising to you on the Services and Channels, analyzing engagement with our audience, observing user engagement and purchase activity across the Service and Channels, marketing our services and offerings to current and prospective customers, managing our IT systems, financial management, conducting surveys, ensuring the security of our systems, conducting investigations where necessary, compliance with applicable law, and improving our Services.
The purposes for which we may Process User Information, subject to applicable law, include:
- Provision of the Services to You: providing the Services to you from Abrigo or its partners including:
- offering of contests, as well as chat areas, forums and communities,
- posting of your personal testimonial alongside other endorsements,
- display of your personal reviews of products or services,
- allowing you to search for other website members using information you may already know about that member such as username, full name or gamer profile and identify users matching that criteria,
- management of your account, and
- customer support and relationship management.
- Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.
- Surveys: engaging with you for the purposes of obtaining your views on our Services.
- Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out in the Direct Marketing section below.
- Advertising: providing advertising based on your interests and interactions with the Services and Channels, including using User Information to serve you advertisements on the Services and Channels, as well as licensing segments of User Information to third parties. For further information, please see the Cookies & Similar Technologies section below.
- Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service and on Channels.
- User Engagement and Purchases: tracking purchase traffic and activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.
- Marketing to Customers: We may market to current and prospective customers and their employees who have indicated an interest in doing business with, or have previously conducted business with, Abrigo in order to further generate and promote our business. Such efforts include sending marketing emails or conducting phone calls to drive the purchase of Services, lead generation, and other business services offered by Abrigo.
- IT Administration: administration of Abrigo’s information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
- Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
- Financial Management: general business and financial management purposes, including: economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements.
- Investigations: detecting, investigating, and preventing breaches of policy and criminal offences, in accordance with applicable law.
- Legal Proceedings: establishing, exercising, and defending legal rights.
The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the Services or obtaining coupons or codes from the Services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.
Customer Applications are intended for use by Abrigo customers to analyze and process data that may be proprietary. Most Customer Applications do not require a client name to be entered to generate any type of data analysis, and some institutions leverage a unique identifier or “code name” to use with associated financial data. This ensures that no company or individual can be directly associated with the financial data entered into our products.
Abrigo stores and aggregates report data within Customer Applications so we can build and continually improve our industry benchmark database, financial models, and other products. Abrigo will not publish or sell User Information or Personal Information without your express permission, and we agree to maintain the confidentiality of your information within these applications.
Abrigo reserves the right to use any User Information for internal quality control and product development as necessary to supporting product development. In addition, Abrigo reserves the right to freely use, sell, and distribute all data provided by users from which Abrigo has removed Personal information or otherwise de-identified such data. Abrigo’s use may include the future development of financial models, indices, or other reports derived from the financial data entered. You should not enter data or other information into our applications if you do not want your or your client data being used in this manner or contributed to our aggregate database.
Section Summary: We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. The Services use Transport Layer Security (TLS) encryption to transfer User Information along with other Personal Information in a non-human readable format to provide protection. Each web-based interface used by the Services leverage a Secure Sockets Layer (SSL) certificate issued by a publicly trusted root Certificate Authority to provide certain assurances that a given site is not being spoofed or otherwise manipulated between you and Abrigo.
Abrigo further protects User Information, Personal Information, and other content stored on our systems used to host the Customer Applications. These systems use industry standard computer security products and perimeter protections that include firewalls, intrusion detection systems, host and firewall logging, and real-time monitoring. In addition to the encryption of data in transit as described above, data entered into Customer Applications also remains encrypted at rest using Advanced Encryption Standard database-level encryption.
Because the internet is an open system, the transmission of information via the internet is not completely secure, and we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.
Section Summary: We take reasonable precautions to ensure that your User Information is kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
We take reasonable precautions to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.
Section Summary: We take reasonable precautions to limit the volume of your User Information that we Process to what is necessary.
We take reasonable precautions to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.
Section Summary: We take reasonable precautions to ensure that your User Information is only retained for as long as they are needed. Online Data related to OBA is kept by Abrigo for no more than 180 days after which it will expire, subject to certain conditions.
We take reasonable precautions to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.
Customer Application users have full control of all data, including User Information and Personal Information, that is entered in the application. As a result, each institution can determine their own data retention requirements and delete data within their account as necessary. If you would like to delete data at any time for security or any other reasons, you may do so through your account. Abrigo commits to maintaining the above measures and to working with our customers to monitor and modify our programs as needed to address any security concerns. Ownership of the data entered into Customer Applications remains that of the customer, and Abrigo agrees to delete and make unrecoverable all identifiable data belonging to a customer upon request, up to and including the end of their relationship with Abrigo.
Section Summary: We may Process your User Information to contact you with information regarding services that may be of interest to you. You may unsubscribe for free or opt out of SMS messages at any time.
We may Process your User Information to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for. You may opt out of any telephone marketing by contacting us by emailing firstname.lastname@example.org
Certain portions of the Services may provide features that allow us to contact you via push notification or SMS message. SMS features may be unsubscribed by texting STOP to the received SMS or by emailing email@example.com. You will not be charged by us for receiving or sending SMS messages, however, we make no representations, warranties or guarantees that a particular wireless service program will enable you to participate in an SMS feature.
Cookies & Similar Technologies
Section Summary: We may Process your User Information by placing or reading Cookies and similar technologies on the Services and Channels. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to Other Information about you, including your User Information for the purposes of learning more about you so we can provide you with relevant content. We and our partners also use these technologies to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement to our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to marketing campaigns.
Abrigo and/or certain third parties may collect information about you for online behavioral advertising purposes for you to receive relevant information on the Services and on other websites, platforms, and media channels. We use Online Data as well as other User Information to send you online behavioral ads. Online Data is aggregated with the Other Information and data we collect and/or similar data collected by partners to create groups of users and certain general-interest categories or segments that we have inferred. We use this information to get a more accurate picture of audience interests in order to serve ads we believe are more relevant to your interests.
Tracking technologies on the Services may be deployed by Abrigo and/or by our service providers or partners. Certain tracking technologies enable us to assign a unique identifier to you and relate information about your use of the Services to other information about you, including your User Information. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of learning more about you so we can provide you with relevant content and advertising.
When you receive email messages or newsletters from us, we may use web beacons, customized links, clear GIFs, or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other information, and/or to aggregate that information with other data we collect to use for some or all of the purposes outlined in this Policy.
We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) also may use technologies such as pixel tags, e-tags, IP addresses, Local Shared Objects, Local Storage, Flash cookies and HTML5 to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns. We may receive reports based on the use of these technologies by these third-party companies on an individual and aggregated basis. For example, we may connect information about your IP address to known corporate or User Information and use the associated information related to aggregate content preferences to assist in our efforts to market services to you or the originating corporation(s). Various browsers may offer their own management tools for removing Local Storage.
We may use mobile analytics software to collect data and to better understand the functionality of our mobile software, devices and applications on your phone and other devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link this information to User Information.
Abrigo and/or certain third parties may collect information about you for online behavioral advertising (“OBA”) purposes for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. OBA is also referred to as interest-based advertising.
Online Data is aggregated with the Other Information and data we collect as described in this Policy and/or similar data collected by partners to create groups of users and certain general-interest categories or segments that we have inferred based on:
- demographic or interest data and GeoIP Data,
- the pages you view and links you click when viewing an email or using the Services and those of our partners, and/or
- the search terms you enter when using certain search services.
We use this information to get a more accurate picture of audience interests in order to serve ads we believe are more relevant to your interests. We store page views, clicks and search terms used for ad personalization targeting separately from your Personal Information.
Disclosure to Third Parties
Section Summary: We may disclose your User Information to legal and regulatory authorities, our external advisors, parties who Process User Information on our behalf (“Processors”), any party as necessary in connection with legal proceedings, any party as necessary for investigating, detecting or preventing criminal offences, any purchaser of our business, and any third party providers of advertising, plugins or content used on the Services.
We may disclose your User Information to other entities within the Company for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
- Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation
- Outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality
- Third-party Processors (such as analytic providers; data centers; etc.) subject to the requirements noted in this section
- Relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise, or defense of legal rights
- Relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security
- Third-party acquirer(s) if we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation)
- Third-party provider, where our Services use third-party advertising, plugins or content
- Sponsors of contests, competitions, sweepstakes and prize draws, or white papers, webcasts or other downloads
With respect to surveys, if responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where Abrigo advises users of the possibility of such disclosure at the time they take the survey, Abrigo reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.
Abrigo may use third-party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Services. Often, these third-party advertising companies employ cookies and other technologies to measure the effectiveness of website, app, and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services.
We may engage third-party providers to assist with the collection, storage, and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third-party providers may collect User Information from our Services for their own purposes, including but not limited to monitoring fraud around the web.
We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also:
- Collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system
- Combine User Information about you received from Abrigo with information about you from other sites or services
- Place or recognize a unique cookie on your browser
If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to:
- only Process the User Information in accordance with our prior written instructions; and
- use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.
User Information, Personal Information, and other data entered into Customer Applications will remain within US-based datacenter facilities.
Controlling Your Information
Section Summary: You can directly take steps to change your preferences for newsletters and online correspondence as outlined in this section. EU residents may have the option to access their Personal Information. Abrigo complies with Privacy Shield, and provides mechanisms to report and dispute claims.
Newsletter & Email Subscriptions
You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow 10 business days for changes to take effect. On some Services, customer-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.
Cookies & Pixel Tags
You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all the features, functions, or services available on the Services.
The General Data Protection Regulation (GDPR) provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us using the information found in the Contact Details section below. If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.
The California Consumer Privacy Act (CCPA) provides certain rights for California residents. These rights include, in accordance with applicable law, the right to object to or request specific access, portability, and deletion information of your own information. If you are a California resident and wish to make such a request, please submit your request in writing using the information found in the Contact Details section below.
If you are an EU resident, you may have certain rights including: the right not to provide your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Information; the right to object to the Processing of your Personal Information; the right to have your Personal Information transferred to another controller; the right to withdraw consent; and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.
If we are unable to resolve any complaint related to Privacy Shield or if we fail to acknowledge your complaint in a timely fashion you may refer a complaint to your local data protection authority. We have committed to cooperate with the panel established by the EU data protection authorities (DPAs) regarding unresolved Privacy Shield complaints concerning data transferred from the EU. We will work with them to address complaints and provide appropriate recourse free of charge to you. In certain circumstances, Privacy Shield provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Principles.
Our compliance with Privacy Shield Principles is subject to the investigatory and enforcement powers of the Federal Trade Commission. We may be required to disclose Personal Information that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of User Information carried out by us, or on our behalf, please contact:
12331-B Riata Trace Parkway
Building 4 Suite 200
Austin, TX 78741
Phone: (888) 201-2231
Changes to This Policy
This policy was last updated on December 4, 2019.
We may change this Policy from time to time, and all changes will be effective at the time we post them. If we believe there is a significant change to this Policy or our data collection and use practices, we will indicate on our websites that our Policy has changed prior to the change becoming effective. The then-posted version of the Policy supersedes all prior versions. Your continued access to or use of any of the Services shall be deemed your acceptance of the Policy.
We urge you to come back to this web page and review this Policy regularly so that you remain aware of the terms and conditions that apply to you.
Banker’s Toolbox, Inc., d/b/a Abrigo, Inc., a California Corporation.