Current as of [INSERT LAUNCH DATE, 2020]
XPAN Consulting Solutions, LLC (“XPAN”) takes a proactive stance on privacy and data security. It’s considered in everything we do, from providing content to a general audience, working with clients to managing complex databases. Rest assured that your data is in good hands. Please take a moment to review our Privacy Notice below.
At XPAN, we respect your privacy and know that you care about how your personal information is collected and used. This Privacy Notice discusses how XPAN collects, uses, maintains, and discloses information collected from our Website (www.xpanconsultingsolutions.com).
This notice does not apply to information collected or obtained by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Sites.
By accessing, browsing, or otherwise using the Website, you acknowledge and consent to our collection and use of information as set forth in this Privacy Notice. PLEASE READ THIS PRIVACY NOTICE CAREFULLY. YOUR USE OF THE SITES CONSTITUTES YOUR CONSENT TO THIS PRIVACY NOTICE. DO NOT USE THE SITES IF YOU ARE UNWILLING OR UNABLE TO CONSENT TO THIS PRIVACY NOTICE.
This Privacy Notice applies only to your use of the Website, and was last updated as of [INSERT DATE]. We reserve the right to revise this Privacy Notice at any time and such revision shall be posted here and accessible via this link: [INSERT URL]. Any revision and/or addition to this Privacy Notice shall become effective and binding on you when you continue to use the Sites on or after the effective date of such revision and/or addition.
We value transparency in everything that we do. We also value simplicity and, since we these documents can get a little “wordy,” we want to boil this all down to the main point:
We only collect what you give us, to use to respond to you or to provide you with services you ask us to provide. We do not sell your data, loan your data, or really do anything with your data beyond what you ask us to do. Frankly, data scares us.
The information provided below is meant to provide that clarity so that you can feel comfortable with how we approach data privacy and security.
Information You Choose to Provide to Us
When using the Website, you may choose to provide us with certain personal information, including:
- Your name and contact information to subscribe to a newsletter and/or other similar types of marketing materials;
- Your name, contact information, and other related information to inquire into our Services or to request information about XPAN;
- Your name, contact information, and other related information when you provide us with information, such as customer reviews, to be published or posted on public areas of the Website, or transmitted to other users of the Websites or to third parties (collectively, “Customer Reviews”); and
- Your name, contact information, demographics and educational information to inquire into and/or apply for a job with us (collectively, “Job Application”).
Information Collected Via Your Use of our Website
We may collect information about you automatically when you are using the Website in a number of different ways; for example:
- We may collect and track your IP address; and
This information may be collected via several technologies, including cookies, web beacons, clear GIFs and other means. All of this information belongs to us, and we use it to improve effectiveness, content, layout and/or operation of our Website. You can remove certain cookies by following the directions in your Internet browser’s “help” file (see below). If you disable cookies, your ability to use areas of the Site may be limited.
How We Use Your Information
In general, we do not and will not share your personally identifiable information except as set forth in this Privacy Notice. We do not sell, transfer, and/or share your personally identifiable information with third parties for their own marketing purposes.
We use the information we collect from you when you browse our Sites in the following manner:
|Categories of Personal Information||Use of Information|
|Identification information, application usage data (e.g., features/pages accessed by a member), location data (GPS).||To operate and improve the Website and associated services.|
|Identification information, application usage data (e.g., features/pages accessed by a member), location data (GPS).||To understand and analyze information related to the number and type of visitors that browse and use the Website.|
|Name, phone number, mailing address, email address.||To provide you with information or Services that you request from us, or that may be of interest to you.|
|Name, phone number, mailing address, email address.||To respond to your comments, inquiries and questions.|
|Customer Reviews||To post on the Website and transmit to others, including third-parties and other users.|
|Name, mailing address, email address, phone number, demographic information, and educational information||To process an application for a job opportunity.|
|Name, mailing address, email address, phone number, demographic information||To fulfill any other purpose for which you provide it or for which you have given us consent to use it.|
You can opt-out of certain use(s) of your personal information, as described below.
How We Use Automatically Collected Information
The information we collect automatically is statistical data and generally does not contain personal information. However, we may maintain it or associate it with personal information we collect in other ways or receive from third parties. We will use this automatically-collected information to improve our Sites and to deliver a better and more personalized service, including to:
- Estimate our audience size and usage patterns; and
- Speed up your searches.
We want to be completely transparent about the cookies we use and to make their control as easy as possible for you. When you first enter our Website, you will be asked to accept or reject cookies via the Cookie Notice. If, after your initial visit to the Website, you decide to change your cookie selection, you can do so by visiting the Cookie Notice, available at https://xpanconsultingsolutions.com/cookie-notice/.
Further, if you want to delete any cookies that are already on your computer, please refer to the file management software to locate the file or directory that stores cookies under the following file names. Other information on deleting or controlling cookies is available at www.allaboutcookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.
Who Has Access to Your Personal Information?
YOUR PERSONAL INFORMATION WILL NOT BE SOLD. Nor will Your Personal Information be licensed or disclosed to unaffiliated third-parties, except in connection with the sale, transfer, merger, consolidation or other transaction involving all or part of our company or as may be permitted under applicable law.
We may disclose your personal information to our subsidiaries and affiliates to fulfill the purpose for which you provide it, for example, to provide you with a requested communication.
Legal Requests for Information
In the event that XPAN is subject to a legal demand for information, XPAN will comply as required by state, federal and international law. Demands for information include, but are not limited to, subpoenas, warrants, and civil discovery demands. Information covered by our Privacy Notice may be disclosed following such a request if XPAN determines that such a disclosure is necessary or required; or if it is necessary or required to protect your interests or our interests.
Through normal business processes, we access volumes of highly confidential client data. XPAN utilizes strict data segmentation and confidentiality practices to keep this data secure.
XPAN stores its data within the United States and in Europe. Because of the ingenuity of technology, at any moment your data may be in the United States or Europe.
XPAN utilizes cloud storage, computing, and sharing technologies. These technologies may be maintained by third parties such as Google, Microsoft, Amazon or others and may be stored in jurisdictions outside of the United States. Should our security team become aware of any potential security incident or breach, XPAN will take appropriate measures to ensure your data is secured and you are notified as soon as possible. At no time do any of the third-party storage providers have access to any personal information stored on its platform.
Data Security & Retention
Information collected by the technologies described in this Privacy Notice is protected by Google data encryption and security services. Google’s G Suite Security & Privacy information can be found at https://gsuite.google.com/learn-more/security-g-suite.html. Information kept by us in our business is protected using industry standard security measures.
More data, more problems: if we don’t need it, we don’t keep it.
We emphasize data minimization principles: as such, we will only keep and store your data for as long as necessary to provide the services you requested or to comply with a legal obligation.
The California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws provides California residents (i.e., consumers) with specific rights regarding personal information. This section of the Privacy Notice describes those CCPA rights and how to exercise those rights. This section does not apply to publicly available information.
Access to Specific Information and Data Portability Rights
California residents have the right to request that XPAN disclose certain information to you about XPAN’s collection and use of your personal information over the past twelve (12) months. Once XPAN receives and confirms a verifiable consumer request from you, XPAN will disclose to you, to the extent permitted by law:
- The categories of personal information XPAN collected about you.
- The categories of sources for your personal information XPAN collected about you.
- XPAN’s business or commercial purpose for collecting your personal information.
- The categories of third parties with whom XPAN shares your personal information.
- If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
You shall have the right to request that the information described above be provided to you in a portable and readily useable format, to the extent technically feasible (“data portability”).
XPAN does not sell your personal information.
Deletion Request Rights
You have the right to request that XPAN delete certain of your personal information that XPAN collected from and/or related to you and retained, subject to certain exceptions.
To the extent that XPAN can delete your personal information, once XPAN receives and confirms your verifiable consumer request, XPAN will delete (and direct our service providers to delete) your personal information, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected your personal information, provide a good or service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to XPAN by contacting us at firstname.lastname@example.org.
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 XPAN to reasonably verify you are the person about whom XPAN collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows XPAN to properly understand, evaluate, and respond to it.
XPAN cannot respond to your request or provide you with your personal information if XPAN cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Any disclosures provided pursuant to the CCPA will only cover the 12-month period preceding the receipt of the verifiable consumer request.
XPAN will respond to a verifiable consumer request within 45 days of its receipt, or notify you that XPAN requires more time to respond and the reason for the extended response time. XPAN will deliver its written response by mail or electronically, at your option.
To the extent that your verifiable consumer request is excessive, repetitive, or manifestly unfounded, XPAN may charge a reasonable fee to respond to such request.
XPAN will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, XPAN will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
EU Personal Data & Data Rights
XPAN acknowledges that EU individuals have certain rights associated with the personal information maintained by XPAN. XPAN is committed to providing the protections under the GDPR to all personal data. Those rights include:
- the right to request access to any of your personal data;
- the right to request the rectification or correction of your personal data if it is inaccurate;
- the right to request the erasure of your personal data so long as XPAN does not have a valid reason to maintain that information;
- the right to request restricted processing of your personal data;
- the right to request the transmission of your personal data to another entity; and
- the right to object to the processing of your personal data.
If you would like to exercise any of these rights, or just have questions about these rights, please contact us at email@example.com. One of our team members will respond to you within a reasonable timeframe.
XPAN is not responsible for loss corruption or unauthorized acquisition and use of information covered by this Privacy Notice, or for any resulting damages, including unauthorized acquisition and use.
We do not collect sensitive information about you. If you provide it to us, we will inform you that it will be deleted from our databases immediately. Sensitive information is the worst.
‘Sensitive information’ includes personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual. Again, please do not send this to us.
Third-Party Services and Products
We use third-party services and products to host our Website, provide our newsletter, and to support the services that we provide to you. To the extent that these services and products collect data on our behalf, the collection and processing of that data is covered by this Privacy Notice.
We try to only partner with products and services that we believe operate with a similar emphasis and respect for data privacy and security.
However, this Privacy Notice does not cover any third-party websites that are available through the XPAN website. We have no responsibility for how these third parties treat your information; if we have access to their privacy policies, we will provide them to you upon your request. For information on how third-parties collect, use, and protect personal information, please visit the specific third-party’s Privacy Notice.
If you see something, say something.
We are not perfect and want to improve how we offer our services to you. We are open to suggestions, comments, and concerns regarding this Privacy Notice. For additional information regarding this Privacy Notice, or to contact us regarding any of the information you have provided to XPAN, please contact our Data Protection Officer as follows:
Jordan L. Fischer, Esq.
Data Protection Officer
01 267 536 9376