Privacy Policy
Effective Date: July 2020
Introduction and Scope
Lou Hansell, Inc. (“Lou Hansell”, “we”, “us” or “our”) respects the privacy of our visitors, users, clients, and business partners (also occasionally referred to as “you” or “your”). This privacy policy (and as amended from time to time as posted on our website at https://www.louhansell.com/privacy-policy) (“Privacy Policy”) describes the types of information we collect from you or that you may provide when you visit or use our www.louhansell.com website (“Website”), or purchase our products or use our services (products and services collectively referred to as “Services”), and our practices for collecting, using, maintaining, protecting, disclosing, retaining, and transferring that information. By “visitors” we mean visitors to our Website who are not yet client, those who become clients, as well as those who do not become clients. By “clients” we mean the person or company which purchases our products or Services. This Privacy Policy applies to the data collected by us, or those working on our behalf, through information you enter or from the data imported from authorized and approved sources. It does not apply to data collected through other websites, products, or services not approved by us.
Contacting Us
You may contact us using the Contact Information provided at the end of this Privacy Policy.
Acknowledgement and Consent
By using or accessing our Website or the Services in any manner, you acknowledge that you accept the practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, and disclose your information as described herein. If you do not agree with our policies and practices, your choice is not to use our Website or our Services. Your use of the Website and our Services is at all times subject to our Terms of Service (available at https://www.louhansell.com/terms-of-service (the “Terms”), which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.
What Information Does This Privacy Policy Cover?
This Privacy Policy covers our treatment of personally identifiable information. Such information may include name, mailing address, email address, telephone number, and other information which identifies you as a specific individual (“Personal Information”). For this Privacy Policy the definition of “Personal Information” is the definition under the state, country, or other law applicable to the person whose data is collected; however, for California residents only, “Personal Information” shall have the definition as set forth in the California Consumer Privacy Act of 2018 (“CCPA”). Please see the section below entitled “Privacy Notice for California Residents” for more information. If you are a citizen or resident of the European Economic Area, the definition of personal information is defined under GDPR and you have certain rights; therefore, please see the section toward the end of this Privacy Policy entitled “GDPR”.
Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).
Other than as stated herein, this Privacy Policy does not apply to information collected by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our Website. We are not responsible for the practices of sites linked to from the Services, and before interacting with any of these sites you are advised to review their rules and policies before providing them with any private information.
Individuals under the Age of 18
As noted in the Terms, we do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. No one under age 18 should provide any Personal Information to or on the Services. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.
Changes to Our Privacy Policy
We are constantly working to improve our Website and Services, and we may need to change this Privacy Policy from time to time as well. Our current Privacy Policy will always be on our Website at https://www.louhansell.com/privacy-policy and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates.
Please note that if you have opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Website, purchase products, or use our Services after any changes to the Privacy Policy have been posted, that means you agree to the new Privacy Policy, including all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.
Personal Information We Collect
We collect several categories of Personal Information from and about you, namely,
Identifiers
First and last name, user name (which may include first and last name), email address , postal address , device identifier (e.g., mobile device ID), IP address, customer/account name or number, phone number, cookies, beacons, pixel tags, mobile ad identifiersCommercial Information
Products and services purchased, purchasing history or tendenciesInternet or other electronic network activity
Browsing history, search history, your interaction with a website, app, or advertisementGeolocation
Your locationProfessional or employment information
Email address that identifies you (e.g., jane.smith@website.com versus jsmith@.website.com)Inferences drawn from any of the above to create a profile of a person
Preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes
How We Collect Personal Information and from What Sources
Information You Provide to Us. The Personal Information we collect on or through our Website may include, but is not limited to:
Information that you provide by filling in webforms on our Website. This includes information provided when creating an online account, purchasing our products or Services, subscribing to our e-newsletters or other communications, requesting information from us, submitting or posting material (where permitted), or interacting with customer support or service, report a problem with our Website, products, or Services, or otherwise communicating with us.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Your search queries on the Website.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services, or associate Personal Information with other information collected in this manner (behavioral tracking).
The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including, but not limited to, by enabling us to: (a) estimate our audience/visitor size and usage patterns; (b) store information about your preferences, allowing us to customize and improve our Website; (c) speed up your searches; and/or, (d) recognize you when you return to our Website.
Cookie Notice/Policy
The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.
Cookies (or browser cookies)
A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer (Internet Explorer, Firefox, Safari or Google Chrome).
Different types of cookies which have different purposes are used on our Website.
Essential Cookies
These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.
Performance Cookies
These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Websites from their site and whether your visit has led to the use or purchase of a product or Service from our Website, including the references for the product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.
Functionality Cookies
These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
It is possible that you will come across third-party cookies on some pages of sites that are not under our control.
We also use cookies to implement tracking technology on our Website. This allows us to display advertising that is tailored to you on our Website which parts of our content interest you the most and which Service categories you request. This tracking uses De-Identified Personal Information data). We will not combine this data with your other Personal Information without your express permission. Some of our contracted vendors and affinity partners are allowed to place cookies on our Website. Those companies may also provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.
At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected; e.g., you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Local Storage Cookies. Certain features of our Website may use local stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing and research.
GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
IP Address. Our servers automatically record certain log file information reported from your browser when you access the Services. These server logs may include information such as which pages of the Service you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Services. These log files are generally deleted periodically.
Information We Collect from Third Parties
We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website.
Third Party Services. If you link, connect, or login to your account with a third party social media service (e.g., Facebook, Yelp, etc.), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Website through partnerships, or about your experiences and interactions from our partner ad networks.
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information on how to opt-out of third-party advertiser tracking mechanisms, please click here.
Google Analytics. We use, and some of our third-party service providers may use, Google Analytics (click for link to Google’s website) or other analytics service to help us understand use of our Services. Such service providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.
Google AdSense Advertising. We use Google AdSense Advertising (or other search engine or display network advertising) on our website. Google’s advertising requirements can be summed up by Google’s Advertising Principles (click for link to Google’s website). They are put in place to provide a positive experience for users. We have implemented the following: (a) Remarketing with Google AdSense and (b) Google Display Network Impression Reporting.
Google DART Cookie. Google, as a third-party vendor, uses cookies to serve ads on our Website. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our Website and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.
We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website.
Google DoubleClick Cookie. We may work with DoubleClick Cookie Google, as a third-party vendor, uses cookies to serve ads on our Website. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Website or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/.
Google Maps/Google Earth. We also use Google Maps (including the Google Maps API(s)) and/or Google Earth, which may, among other things, request access to your geolocation, and both of which are subject to their own terms of use and privacy policy.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:
To present our Website and its contents to you.
To provide you with information on products or services that you request from us.
To provide you with the services that you have requested.
To process transaction payments and refunds.
To provide you with notices about your account, including expiration and renewal notices.
To send you emails and newsletters with product, service, company, and other information.
To provide you with information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you.
To respond to your questions or other requests.
To contact you with regard to the Website and to send important notices, such as communications about our Services, your account or changes to our terms, conditions, and policies.
To process any applications, changes to your account information.
To process other information or Personal Information that you submit through this Website.
To notify you about changes to our Website, our policies, terms or any products or Services we offer or provide though it.
To allow you to participate in interactive features on our Website.
To provide access to restricted parts of our Website, e.g., areas accessible if you have a user account.
To request your participation in surveys, focus groups, or other initiatives which help us to gather information used to develop and enhance our products and Services.
To serve relevant information to you when you visit our Website or other third-party sites (including social media platforms).
To contact you about our own and third-parties’ products and services that may be of interest to you. If you do not want us to use your information in this way, please either check the relevant box located on the form on which we collect your data (the order form) or adjust your user preferences in your account profile).
To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends and measuring demographics and interests.
For internal purposes, such as Website and system administration or internal audits and reviews.
For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.
To operate, maintain, and provide to you the features and functionality of the Services.
To provide statistics about the usage levels of the Website and other related information to reputable third parties, but these statistics will not include information which will allow you to be identified.
To notify you of data privacy incidents or provide you with legally required information.
To fulfill any other purpose for which you provide it.
In any other way we may describe and for which we obtain your consent when you provide the information.
We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; and, (f) help you efficiently access your information after you sign in.
We may use your Personal Information you provide us and which we obtain from other sources to better understand your interests so we can try to predict what other products, services and information you might be most interested in. This practice is called “profiling”, which involves making automated decisions about you based on this information in order to better enable us to tailor our interactions with you to make them more relevant and interesting. You may object to such profiling at any time by contacting us (see Contact Information/User Rights below).
We use the information we collect about you to deliver the services we offer, and to operate and improve our Website. Our services may include a Short Message Service (“SMS”) which may deliver up to 2 messages per day to your wireless device and the display of personalized content and advertising. We may use your information to contact you about Website updates, conduct surveys, or informational and service-related communications, including important security updates. You may remove your information by replying “STOP” to the SMS text message you received or by sending “STOP"” via SMS to the short code indicted in our messages. Alternatively, you may submit your request by email to us, including the email address and phone number you registered with us.
Social Media Plugins
We integrate social media application program interfaces or plug-ins (“Plug-ins”) from social networks, including Facebook, Google+, LinkedIn, Xing, Twitter, Instagram, Tumblr, Pinterest and/or possibly other companies, into the Website. In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site login.
For example, when you visit our Website, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Website with your IP address. If you click the Facebook “Like” button while you are logged on to your Facebook account, you can link the contents of our Website to your Facebook profile. This allows Facebook to assign your visit to our Website to your user account. Please note that as provider of the Website, we receive no notification about the contents of the transmitted data or their use by Facebook. If you do not want Facebook to assign your visit to our Website to your Facebook user account, please log out of your Facebook user account.
If you do so, you authorize us to access certain social media site account information, such as your public social media profile (consistent with your privacy settings in the social media site), your email address, interests, likes, gender, birthday, education history, relationships, interests, current city, photos, personal description, friend list, and information about and photos of your social media site friends who might be common social media site friends with other users. Plug-ins may transfer information about you to the Plug-in’s respective platform without action by you. This information may include your platform user identification number, which website you are on, and more. Interacting with a Plug-in will transmit information directly to that Plug-in’s social network and that information may be visible by others on that platform. Plug-ins are controlled by the respective platform’s privacy policy, and not by our Privacy Policy. You can find the privacy policy for a platform on their website.
How We Share Your Personal Information
Personal Information:
We may disclose your Personal Information, in whole or in part, with third parties for the purpose of introducing, providing, or improving our Services to you who perform services on our behalf,. We may or do disclose Personal Information to the following types of third parties, and for one or more the following purposes:
Hosting providers for the secure storage and transmission of your data
Identity management providers for authentication purposes
Database software providers for the management and tracking of your data
Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
Payment solution providers for the secure processing of payments you provide to us
Technology providers who assist in the development and management of our Website
Outbound call center providers, who may perform outreach on our behalf regarding our products and Services
Fulfillment and shipping vendors for the fulfillment of our products and Services
Survey and research providers who perform studies on our behalf
Advertising partners, including social media providers, for the delivery of targeted advertisements
Disclosures to Service Providers: We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, analyze data, credit checks, screening checks, collection services, marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing search results and links (including paid listings and links), and processing credit card payments. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).
Event-Related Disclosures: From time to time, we may run contests, special offers, or other events (e.g., trade show exhibits) or activities (“Events”), possibly together with a third party vendor. If you provide information to such third parties, you give them permission to use it for the purpose of that Event and any other use to which you consent. We cannot control third parties’ use of your information. If you do not want your information to be collected by or shared with such third parties, you can choose not to participate in these Events.
Required Disclosures: Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process, or subpoena, including to respond to any government or regulatory request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, contracted vendors, or affinity partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) enforce our Terms (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations; (e) assist government enforcement agencies or to meet national security requirements; (f) to protect the security or integrity of our Website, our Services, or any software we provide related thereto; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others.
We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
It is likely that the identity and categories of such third parties will change during the life of your account. We require that our third-party service providers only use your Personal Information as necessary to provide the requested services to us and each service provider is subject to a set of terms consistent with the applicable portions of this Privacy Policy.
Your Consent to Disclosure/Transfer/Sale of Your Personal Information: You consent to our disclosure of your Personal Information and other information to a potential or actual buyer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) of any or all of our rights to your Personal Information and your consents, in whole or in part, and other information, with or without notice to you and without your further consent.
Data Transfer/Access Outside of the United States
We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the UK, European Economic Area (“EEA”), or Switzerland, we provide adequate protection for the transfer of Personal Information to countries outside of the UK, EEA or Switzerland through a series of intercompany agreements based on the Standard Contractual Clauses. We may also need to transfer your information to other group companies or service providers in countries outside the EEA. This may happen if our servers or suppliers and service providers are based outside the UK, EEA, or Switzerland, or if you use our services and products while visiting countries outside this area.
If you are a resident of a country other than the United States, you acknowledge and consent to our collecting, transmitting, and storing your Personal Information out of the country in which you reside.
Security
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.
Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of service providers who have special access rights to our systems, and who are required to keep the information confidential.
Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information. We do not collect or store full credit card numbers.
Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safer.
We may store, retrieve, access, and transmit your Personal Information in the US or in other countries.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of service providers who have special access rights to our systems, and who are required to keep the information confidential. Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information. We do not collect or store full credit card numbers. Our Website software are scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safer.
Our agents, contractors, service providers, and partners who require access to your Personal Information in order to provide services to us or to you on our behalf are also required to keep the information confidential in a manner consistent with this Privacy Policy and are not permitted to disclose the information to third parties or use the information for any purpose other than to carry out the services they are performing for us, or as permitted pursuant to our agreement with them.
The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We’ll never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or used with our Services.
Data Retention
The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will keep your Personal Information for as long as your account is active, or as long as you are a registered account holder or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
Following termination or deactivation of your user account, we may retain your profile information and all information posted to public areas of the Website. Following termination or deactivation of your user account, we may retain your Personal Information and other data, but will maintain it as confidential according to the Terms, this Privacy Policy, and as required by applicable law. We have the right to delete all of your Personal Information and other data after termination of your user account without notice to you.
We may retain De-Identified Personal Information for as long as we deem appropriate.
You can delete your account or request that we delete your account by contacting us. If you choose to delete your account, we will begin the process of deleting your account from our systems.
We retain your information after you request such deletion for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. For example, when we process your payments, we will retain this data for longer periods of time as required for tax or accounting purposes. See below for examples of specific reasons we would retain some data for longer periods of time:
Our contractual and business relationships with you.
Security, fraud and abuse prevention – i.e., to protect you, other people, and us from fraud, abuse, and unauthorized access.
Financial record-keeping – when you make a payment to us we are often required to retain this information for long period of time for purposes of accounting, dispute investigation and resolution, and compliance with tax, anti-money laundering, and other financial regulations.
Complying with legal or regulatory requirements – to meet any applicable law, regulation, legal process, or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.
Direct communications with us – if you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.
Even if you delete your account, keep in mind that the deletion by our third party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time.
What Information You Can Access, Change, or Delete
Through your user account settings page, you may access and, in some cases, edit, or delete certain information you’ve provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.
Privacy Notice for California Residents
The following in this section applies only to California residents.
Shine the Light Law California Civil Code § 1798.83 (available here)
Under this law, California residents are entitled to ask us annually for a notice identifying the categories of Personal Information (if any) which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties with whom we have shared such information during the immediately preceding calendar year. You also have the right to request that we revise your Personal Information on record. To make such a request, please contact us with “Request for California Privacy Information” in the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
California Online Privacy Protection Act (“CalOPPA”; Calif. Bus. & Prof. Code § 22575-22578, available here):
CalOPPA applies only to companies which collect Personal Information of California residents.
How We Respond to Do Not Track Signals.
California law (CalOPPA) requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
Visitors can visit our Website anonymously by adjusting the settings in your browser.
We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
California Consumer Privacy Act of 2018 (“CCPA”, available here):
If you are a California resident (occasionally referred to herein as “Consumer”), California law provides you with additional rights regarding our use of your Personal Information.
This “California Consumer Rights Privacy Notice section does not apply (at least until January 1, 2021) to the Personal Information of California residents that we collect:
which is reflecting a written or verbal communication or a transaction between us and you, where you are acting as an employee, owner, director, officer, or contractor of a company or government agency and whose communications or transaction with us occurs solely within the context of our conducting due diligence regarding, or providing or receiving a product or service to or from such company or government agency; or,
in the course of your acting as a job applicant to or an employee of our company to the extent that your Personal Information is collected and used by us solely within the context of your role or former role as a job applicant to, an employee of our company.
Starting January 1, 2020, California residents have the right to (a) access a copy of their Personal Information held by us, (b) request deletion of their Personal Information held by us, and (c) opt-out of the sale of their Personal Information (if we did sell such information, which we do not do). These rights can be exercised by completing and submitting the webform available here.
The categories of your Personal Information we collect are listed above in the section entitled “Personal Information We Collect.” The purposes for which the categories of Personal Information are or may be used is described above in the section entitled “How We Use Your Information” and in other sections of this Privacy Policy.
No Sale of Your Personal Information
We do not sell (as that term is defined under CCPA) your Personal Information, period.
Right To Access to Specific Information
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 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 disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Right
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 (as described below).
As permitted by CCPA we may delete your Personal Information by (a) permanently and completely erasing the Personal Information on our existing systems with the exception of archived or back-up systems; (b) de-identifying the Personal Information; or, (c) aggregating the Personal Information.
We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) 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 et. seq.).
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal, regulatory or law enforcement obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising 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: sending an email to us at info@louhansell.com, using our webform available here, submitting a form in person, or by mailing a request to us at 201 S. Main Street, Suite 550, South Bend, Indiana 46601, Attn: Data Access Request. 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 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.
Verification Process
Email Verification Method: Upon receiving a data access or deletion request from you we will send an email to you at the email address we have for you on file. The email will ask you to respond to verify you as the Consumer making the request. Upon receipt of your verification we will match your information to that which is in our file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above).
Webform Verification Method: When you submit a request using our webform (available here) we will match the information you submitted with the information we have for you on file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above). We may not be able to comply with your request if (a) we are unable to verify your request, (b) if we are unable to match you with information in our database, or (c) if an exception under the law exists exempting us from complying with your request.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days of receiving it. We will respond to a verifiable Consumer request within forty-five (45) calendar days of its receipt. If we require more time (up to an additional forty-five (45) calendar 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.
Please note that this right does not apply to business-to-business customers, employment applicants, or independent contractors to us, or if the disclosure of Personal Information is for purposes consistent with the California resident’s reasonable expectations, when considering the submission’s circumstances.
Non-Discrimination
We will not discriminate against you simply for your 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 by refusing to gran discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or,
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We may not be able to comply with your request if (a) we are unable to verify your request, (b) if we are unable to match you with information in our database, or (c) if an exception under the law exists exempting us from complying with your request.
Notices; Opting Out
By providing us with your email address (including by “following,” “liking,” linking your account to our Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding the Service or the Website to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, when/if we have an e-newsletter, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.
Contact Information
If you have any questions about this Privacy Policy, our privacy practices, or for any other purposes, please contact us: by email at info@louhansell.com.
Privacy Outside of the United States
If you are a citizen or resident of the European Economic Area (“EEA”), Switzerland, or other regions with laws governing data collection and use that may differ from the laws in the United States, please note that we may transfer your information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. We may do so to process your information by staff operating outside these countries who works for us or for one of our service providers.
GDPR: The Follow Provisions Apply Only to Citizens and Residents of the EEA and Switzerland
The following provisions apply only if you are a citizen or resident of the EEA or Switzerland. For such citizens or residents, all processing of your Personal Information is performed in accordance with privacy rights and regulations, in particular, (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Information and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”), and our processing will take place in accordance with the GDPR. For purposes of the GDPR, we will be the “data controller” of Personal Information (referred to in the GDPR as “Personal Data”, and which is defined here) we collect through the Website, unless we collect such information on behalf of a “data controller” in which case we will be a “data processor.” This Privacy Policy does not apply to websites, applications or services that do not display or link to this Privacy Policy or that display or link to a different privacy policy. For UK, EEA, and Swiss residents and citizens only, to the extent any definition in this Privacy Policy conflicts with a definition under the GDPR, the GDPR definition shall control.
Your Data Rights Under GDPR
Your rights under GDPR include the following:
The right to access - Upon request, we will confirm any processing of your Personal Information and, and provide you with a copy of that Personal Information in an acceptable machine-readable format.
The right to rectification - You have the right to have us correct any inaccurate Personal Information or to have us complete any incomplete Personal Information.
The right to erasure - You may ask us to delete or remove your Personal Information and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion).
The right to restrict processing - You have the right to ask us to suppress the processing of your Personal Information but we may still store your Personal Information. See below for more information.
The right to object to processing - You have the right to object to your Personal Information used in the following manners: (a) processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); (b) direct marketing (including profiling); and, (c) processing for purposes of scientific/historical research and statistics. See below for more information.
The right to data portability - You have the right to obtain your Personal Information from us that you consented to give us or that is necessary to perform fulfillment of member benefits with you. We will give you your Personal Information in a structured, commonly used and machine-readable format.
The right to complaint to a supervisory authority - You have the right to file a complaint with a supervisory authority, in particular in the European member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of Personal Information relating to you infringes upon your rights.
The right to withdraw consent - We rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
Your right to have us cease processing your Personal Information is dependent upon the following events:
You state that the personal information we have about you is incorrect; but we may retain the information for as long as it requires to check the accuracy of the relevant personal information;
There is no legal basis for our processing of your personal information and you demand that we restrict your personal information from further processing;
We no longer require your personal information but you claim that you require such data in order to claim or exercise legal rights or to defend against third party claims; or,
In case you object to the processing of your personal information by us, we may retain and process the information for as long as it is required to review as to whether we have a prevailing interest or legal obligation in continuing to process your personal information.
You may inquire about the exercise of these rights and, if the laws of your jurisdiction permit, exercise them as permitted by law by contacting us.
Our Legal Basis for Processing Personal Data (UK, EEA and Swiss Visitors Only)
If you are a visitor from the UK, European Economic Area or Switzerland, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
However, we will normally collect Personal Data from you only where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests or rely upon your consent where we are legally required to do so and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided below.
Data We Process on Your Behalf: Service Data
We only process Service Data as per our Customer's instructions. For purposes of the GDPR and the Swiss Federal Act on Data Protection, we are the processor and not the controller of the Service Data. Service Data means all electronic data, text, messages or other materials, including Personal Data of Users and End-Users, submitted to the Service(s) by our Customers through Customer’s Account in connection with Customer’s use of the Service(s), including data collected under “Other Information”. Our UK, EEA, or Switzerland-based Customers are the “controllers” of that data and are responsible for compliance with the applicable data protection law. We work with our Customers to help them provide notice to their customers concerning the purpose for which Personal Data is processed by us.
If you are our Customer from the UK, EEA ,or Switzerland, then in your role as a controller, you are authorizing, on behalf of you and your authorized agents and End-Users, and representing that you have the authority to provide such authorization to the processing and transfer of Personal Data in and to the United States and other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that the Service Data is treated securely and in accordance with this Notice.
We do not own, control or direct the use of Service Data, and in fact we are largely unaware of what information is being stored on our platform and only access such information as reasonably necessary to provide the Service(s) (including to respond to support requests), as otherwise authorized by Customers or as required by law. Unless we explicitly agree otherwise in writing, you will not process sensitive personal data (such as health data) on our platform.
As the controller, it shall be your responsibility to inform the End-Users about the processing, and, where required, obtain necessary consent or authorization for any Personal Data that is collected as part of the Service Data through your use of the Service(s). As the processors of Personal Data on behalf of our Customers, we follow Customer’s instructions with respect to the Service Data to the extent consistent with the functionality of our Service(s). In doing so, we implement technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, Personal Data.