Last Updated: Thursday, June 01, 2023
This Privacy Policy (the "Policy") constitutes a legally binding agreement made between you, whether personally or on behalf
of an entity, ("you") and Grassfire Communications ("GFC", "we", "us", "our", "ours"), concerning your expectations
to privacy during the use of the Grassfire Communications website as well as any other media form, media channel, mobile website,
or mobile application related, linked, or otherwise connected thereto (collectively, the "Site").
At Grassfire Communications, we take privacy and security seriously. This Privacy Policy describes how and why we might
collect, store, use, and/or share ("process") your information ("Personal Information", "PI", "Personal Data", or "PD") when you use
the Site, communication tools, mobile apps, and other online services (collectively, the "Services”), such as when you:
- visit the Grassfire Communications Site at http://www.grassfirecommunications.com, or any
website of ours that links to the Site and/or this Privacy Policy;
- download and use any application of ours that links to the Site and/or this Privacy Policy; or
- engage with GFC in other related ways including, but not limited to, any communications, messaging, chats, sales,
marketing, and/or events.
GFC may use your Personal Data to provide and improve the Services. By using the Services, you agree to
the collection and use of Personal Information in accordance with the Policy. It is of vital importance that you also
review our Terms and Conditions of Service in conjunction with this Privacy Policy.
GFC will alert you about any changes by updating the "Last Updated" date of this Privacy Policy,
and you waive any right to receive specific notice of each such change. It is your responsibility to periodically review this Policy
to stay informed of updates. You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes
in any revised Policy by your continued use of the Site after the date such revised Privacy Policy updates are posted.
Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree
with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us using
the information provided at the end of this Policy Page.
TABLE OF CONTENTS
- SUMMARY OF KEY POINTS?
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE PROCESS YOUR INFORMATION?
- WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
- DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
- HOW DO WE HANDLE YOUR SOCIAL LOGINS?
- IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- WHAT ARE THE CONTROLS FOR DO-NOT-TRACK FEATURES?
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
- HOW CAN YOU CONTACT GFC?
SUMMARY OF KEY POINTS
This Summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by using the
Table of Contents above to find a Section of interest.
- What Personal Information do we process? When you visit, use, or navigate the Site or our Services, we may process Personal Information
depending on how you interact with Grassfire Communications and the Services provided, the choices you make, and the Applications,
Tools, Products, and Features you use.
- Do we process any sensitive Personal Information? We may process sensitive Personal Information, but only with other related Client
websites under the Americans Restoring America umbrella or as otherwise permitted by applicable law.
- Do you receive any Personal Information from third parties? We may receive Personal Information from public databases, marketing partners, social media
platforms, and other outside sources.
- How do you process my Personal Information? We process your Personal Information to provide, improve, and administer our Services, communicate with you,
for security and fraud prevention, and to comply with law. We may also process your Personal Information for other purposes with your consent. We
process your Personal Information only when we have a valid legal reason to do so.
- In what situations and with which types of parties do we share Personal Information? We may share Personal Information in specific situations
and only within specific categories of third parties. In all cases, this is done only with your explicit consent.
- How do we keep your Personal Information safe? We have substantial organizational and technical processes and procedures in place to protect your
Personal Information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your Personal Information.
- What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights
regarding your Personal Information.
- How do I exercise my rights? The easiest way to exercise your rights is by contacting us directly. We will consider and act upon any request
in accordance with applicable data protection laws.
WHAT INFORMATION DO WE COLLECT?
Personal Information you disclose to us
In Short: We collect Personal Information that you provide to us.
When Do We Collect Personal Information? GFC collects Personal Information that you voluntarily provide to us when you register on the Services,
express an interest in obtaining information about GFC or our products and Services, when you participate
in various activities on the Services, or otherwise when you contact us.
From Where Do We Collect Your Personal Information? The Personal Information that we collect depends on the context of your interactions
with GFC, the Services you select, the choices you make, and the products and features you use. The Personal
Information we collect may include the following as shared by you:
- first name
- last name
- address
- county
- city
- state
- zip code
- telephone
- precinct
- email
How About Your Sensitive Information? GFC does NOT process Sensitive Information. Sensitive Information is Personal
Information that includes information or an opinion about an individual's racial or ethnic origin, political opinions or associations,
religious or philosophical beliefs, trade union membership or associations, sexual orientation or practices, criminal record, health
or genetic information, some aspects of biometric information, etc. In rare circumstances and depending on the products and/or Services
selected by you, select Sensitive Information may offered by you. In those cases, full disclosure will be offered and you may opt out of
any such requests for your Sensitive Information.
What About Your Payment Data? GFC may collect data necessary to process your payment if you make purchases, such as
your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All
payment data is typically stored by Vebndors assocated with your payment request (such as VISA, Master Card, American Express, etc.).
You may find their privacy notice link(s) at their respective websites. GFC does NOT retain private
payment information.
What About Social Media Login Data? GFC may provide you with the option to register with us using your existing
social media account details, like your Facebook, Twitter, or other social media accounts. If you choose to register in this way, we
will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
What Aboout Your Application Data? GFC does NOT process Application Data.
All Personal Information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such
Personal Information.
Information automatically collected
In Short: Some information - such as your Internet Protocol (IP) address and/or browser and device characteristics - is collected
automatically when you visit and use our Site, Services, Applications, Tools, and Features.
GFC automatically collects certain information when you visit, use, or navigate the Services. This information
does NOT reveal your specific identity (like your name or contact information) but may include device and usage information, such as your
IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location,
information about how and when you use our Services, and other technical information. This information is primarily needed to maintain
the security and operation of our Services, and for our internal analytics and reporting purposes.
The information we collect automatically may include:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically
collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may
include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the
date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use),
device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the
Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and
application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating
system, and system configuration information.
- Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise.
How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS
and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of
allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.
However, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information collected from other sources
In Short: GFC does NOT collect data from public databases, marketing partners, social media platforms, and other
outside sources.
HOW DO WE PROCESS YOUR INFORMATION?
In Short: GFC processes your Personal Information to provide, improve, and administer our Services, communicate with you,
for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
GFC processes your Personal Information for a variety of reasons, depending on how you interact with our Services,
including:
- To facilitate account creation and authentication and otherwise manage user accounts. GFC may process your Personal
Information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user. GFC may process your Personal Information to provide
you with the requested service.
- To respond to user inquiries and/or offer support to users. GFC may process your Personal Information to respond
to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. GFC may process your Personal Information to send you details about our
products and services, changes to our terms and policies, and other similar information.
- To fulfill and manage your orders. GFC may process your Personal Information to fulfill and manage your orders,
payments, returns, and exchanges made through the Services.
- To enable user-to-user communications. GFC may process your Personal Information if you choose to use any of our
offerings that allow for communication with another user.
- To request feedback. GFC may process your Personal Information when necessary to request feedback and to contact
you about your use of our Services.
- To send you marketing and promotional communications. GFC may process the personal Personal Information you send
to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below).
- To deliver targeted advertising to you. GFC may process your Personal Information to develop and display personalized
content and advertising tailored to your interests, location, and more.
- To protect our Services. GFC may process your Personal Information as part of our efforts to keep our Services safe
and secure, including fraud monitoring and prevention.
- To identify usage trends. GFC may process your Personal Information about how you use our Services to better
understand how they are being used so we can improve them.
- To determine the effectiveness of our marketing and promotional campaigns. GFC may process your Personal Information
to better understand how to provide marketing and promotional campaigns that are most relevant to you.
- To save or protect an individual's vital interest. GFC may process your Personal Information when necessary to save
or protect an individual's vital interest, such as to prevent harm.
WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: GFC is intended for use within the geographic scope of the United States of America. As such, we only
process your Personal Information when we believe it is absolutely necessary and we have a valid legal reason (i.e., legal basis) to do so under
applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations,
to protect your rights, or to fulfill our legitimate business interests.
In Short: GFC may share Personal Information in specific situations described in this section and/or with the
following categories of third parties.
GFC may share your data with third-party vendors, service providers, contractors, or agents ("third parties")
who perform services for us or on our behalf and require access to such information to do that work. GFC has contracts in place with our third parties, which are designed to help safeguard your Personal Information. This means that they cannot
do anything with your Personal Information unless we have instructed them to do it. They will also not share your Personal Information with
any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it only for the period we instruct. The
categories of third parties we may share personal information with are as follows:
- Affiliate Marketing Programs
- Cloud Computing Services
- Communication & Collaboration Tools
- Data Analytics Services
- Data Storage Service Providers
- Finance & Accounting Tools
- Order Fulfillment Service Providers
- Payment Processors
- Performance Monitoring Tools
- Product Engineering & Design Tools
- Retargeting Platforms
- Sales & Marketing Tools
- Testing Tools
- User Account Registration & Authentication Services
- Website Hosting Service Providers
GFC also may need to share your Personal Information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger,
sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Affiliates. We may share your information with our affiliates, in which case we require those affiliates to honor this
Privacy Policy. Affiliates include Americans Restoring America and any subsidiaries, joint venture
partners, trusts, or other companies and/or Client Websites that we control or that are under common control with GFC.
- Business Partners. We may share your Personal Information with our business partners to offer you certain products,
services, or promotions.
- Other Users. When you share Personal Information (for example, by posting comments, chats, emails, contributions, or other
content to the Services) or otherwise interact with public areas of the Services, such Personal Information may be viewed by all users
you target and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services, they
will see the Personal Information you choose to share with them. Other users will be able to communicate with you within our Services.
- Offer Wall. GFC application(s) may display a third-party hosted "offer wall." Such an offer allows
third-party advertisers to offer virtual currency, gifts, products, services, or other items to our users and Members in return for the
acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based
on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an
external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared
with the offer wall provider in order to prevent fraud and properly credit your account with any relevant reward(s).
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: GFC is not responsible for the safety of any Personal Information that you share with third parties
that we may link to or who advertise on, but are not affiliated with, our Services.
The Services, including any offer walls, may link to third-party websites, online services, or mobile applications and/or contain
advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications.
Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by
the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or
application does not imply an endorsement by GFC. We cannot guarantee the safety and privacy of data you provide
to any third parties. Any data collected by third parties is not covered by this Privacy Policy. We are not responsible for the content
or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be
linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: GFC may use cookies and other tracking technologies to collect and store your information.
Cookies are simple text files that are stored on your computer or mobile device by a website's server. Each cookie is unique to your
web browser. It will contain some anonymous information such as a unique identifier, website's domain name, and some digits and numbers.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.
What types of cookies do we use?
- Necessary cookies: allow GFC to offer you the best possible experience when accessing and navigating
through the Site and using its features. For example, these cookies let us recognize that you have created an account and have logged
into that account.
- Functionality cookies: let GFC operate the site in accordance with the choices you make. For example,
we will recognize your username and remember how you customized the site during future visits.
- Analytical cookies: enable GFC and third-party services to collect aggregated data for statistical
purposes on how our visitors use the Site. These cookies do not contain Personal Information such as names and email addresses and
are used to help us improve your user experience of the Site.
If you want to restrict or block the cookies that are set by our Site, you can do so through your Browser settings. Alternatively, you
can visit www.internetcookies.com, which contains comprehensive information on how to do this on a wide
variety of Browsers and devices. There, you will find general information about cookies and details on how to delete cookies from your device.
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: When possible, if you choose to register or log in to GFC services using a social media account, we may
have access to certain information about you.
Whenever our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook
or Twitter logins) and you choose to do so, GFC will receive certain profile information about you from your social
media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name,
email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If
you log in using Facebook, GFC may also request access to other permissions related to your account, such as your
friends, check-ins, and likes, and you may choose to grant or deny GFC access to each individual permission.
GFC will use the information we receive only for the purposes that are described in this Privacy Policy or that are
otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your Personal
Information by your third-party social media provider. GFC recommends that you review their privacy notice to understand
how they collect, use, and share your Personal Information, and how you can set your privacy preferences on their sites and apps.
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: GFC does not currently transfer, store, maintain, and process your Personal Information in countries other than the United
States of America; our servers are located in the United States of America.
Beginning in mid-2023, along with the entire Americans Restoring America family of Client Websites, Grassfire Communications will be migrating
the Site, including databases and content, to newer, faster, reliable, ultra-secure, freedom-of-speech web hosting service provider in Iceland
where GFC maintains its new, private, Dedicated Servers.
The Icelandic service provider is one of the few companies using highly-sophisticated DDoS protection methods to mitigate possible attacks toward
our Site. Their system is designed to protect our Site against all types of service exhaustion attacks and they guarantee their capability to mitigate
attacks up to 250Gb/second. They have a mitigation team on duty around the clock to monitoring our Site.
Sunsequent to the 2023 migration, Grassfire Communications will transfer, store, maintain, and process your Personal Information only in
Iceland, which is known for its outstanding laws of privacy in the web hosting industry.
HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: GFC keeps your Personal Iformation for as long as necessary to fulfill the purposes outlined in this Privacy
Policy unless otherwise required by law.
Grassfire Communications will only keep your Personal Information for as long as it is necessary to fulfill purposes set out in this Privacy
Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in
this Privacy Policy will require us keeping your Personal Information for longer than twelve (12) months past the termination of the user's account
or twelve (12) months past the start of the idle period of the User's account.
When GFC has no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize
such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then
GFC will securely store your Personal Information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: GFC aims to protect your Personal Information through a system of organizational and technical security measures.
Grassfire Communications has implemented appropriate and reasonable technical and organizational security measures designed to protect the
security of any Personal Information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission
over the Internet or information storage technology can be guaranteed to be 100% secure, so GFC cannot promise or guarantee
that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or
modify your information. Although we will do our best to protect your Personal Information, transmission of Personal Information to and from our
Services is at your own risk. You should only access the Services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
In Short: GFC does not knowingly collect data from or market to children under 18 years of age.
Grassfire Communications does not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent
that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If
GFC learns that Personal Information from users less than 18 years of age has been collected, GFC will
deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected
from children under age 18, please contact GFC using the contact details provided in the Section
HOW CAN YOU CONTACT GFC? below.
WHAT ARE YOUR PRIVACY RIGHTS?
In Short: GFC will consider and act upon any request in accordance with applicable data protection laws. You may review,
change, or terminate your account at any time.
You have the right (i) to request access and obtain a copy of your Personal Information, (ii) to request rectification or erasure; (iii) to restrict
the processing of your Personal Information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to
object to the processing of your Personal Information. You can make such a request by contacting GFC by using the contact details
provided in the Section HOW CAN YOU CONTACT GFC? below.
Withdrawing your consent: If GFC is relying on your consent to process your Personal Information, which may be express
and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time
by contacting us by using the contact details provided in the Section HOW CAN YOU CONTACT GFC?
below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect
the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by
clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting
GFC using the details provided in the Section HOW CAN YOU CONTACT GFC?
below. You will then be removed from the marketing lists - however, GFC may still communicate with you, for example to send you
service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided in the Section HOW CAN YOU CONTACT GFC?
below.
Upon your request to terminate your account, GFC will deactivate or delete your account and information from our active databases.
However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or
comply with applicable legal requirements.
Cookies and similar technologies: Most Web Browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser
to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
To opt out of interest-based advertising by advertisers on our Services visit ABOUT ADS. For further information,
please see the Section DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? above.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal
your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, GFC does not currently respond to DNT browser signals or any
other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in
the future, GFC will inform you about that practice in a revised version of this Privacy Policy.
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your Personal Information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits GFC users who are California residents
to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties
for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding
calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact
details provided in the Section HOW CAN YOU CONTACT GFC? below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted
data that you publicly post on the Services. To request removal of such data, please contact us using the contact details provided in the Section
HOW CAN YOU CONTACT GFC? below and include
the email address associated with your account and a statement that you reside in California. GFC will make sure the data is not
publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups,
archive storage, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
- every individual who is in the State of California for other than a temporary or transitory purpose and
- every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, GFC must adhere to certain rights and obligations regarding your personal
information.
What categories of personal information do we collect?
We may have collected the following categories of personal information in the past twelve (12) months:
Category | Examples | Collected |
A. Identifiers |
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier,
online identifier, Internet Protocol address, email address, and account name |
YES |
B. Personal Information categories listed in the California Customer Records statute |
Name, contact information |
YES |
C. Protected classification characteristics under California or federal law |
Gender and date of birth |
NO |
D. Commercial information |
Transaction information, purchase history, financial details, and payment information |
YES |
E. Biometric information |
Fingerprints and voiceprints |
NO |
F. Internet or other similar network activity |
Interest data and interactions with our and other websites, applications, systems, and advertisements |
YES |
G. Geolocation data |
Device location |
NO |
H. Audio, electronic, visual, thermal, olfactory, or similar information |
Images, audio, video, or call recordings created in connection with our business activities |
YES |
I. Professional or employment-related information |
Business contact details in order to provide you our services at a business level or job title,
work history, and professional qualifications if you apply for a job with us |
NO |
J. Education Information |
Student records and directory information |
NO |
K. Inferences drawn from other personal information |
Inferences drawn from any of the collected Personal Information listed above to create a profile
or summary about, for example, an individual's preferences and characteristics |
NO |
Grassfire Communications may also collect other Personal Information outside of these categories instances where you interact
with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How does GFC use and share your Personal Information?
Grassfire Communications may collect and shares your personal information through:
- Targeting cookies/Marketing cookies.
- Social media cookies.
- Beacons/Pixels/Tags.
- Click redirects: [Click Redirects].
- Social media plugins: [Social Media Plugins]. We may use social media features, such as a "Like" button, and widgets, such as a "Share"
button in our Services. Such features may process your Internet Protocol (IP) address and track which page you are visiting on the Site.
We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with
a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform.
To avoid this, you should log out from that social media platform before accessing or using the Services. Social media features and widgets
may be hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy notices
of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer
of Personal Information to the corresponding social media service. We have no control over the essence and extent of these transmitted data
or their additional processing.
More information about GFC data collection and sharing practices can be found in this Privacy Policy and in the Section
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? above.
You may contact GFC by using the contact information provided in the Section HOW CAN YOU
CONTACT GFC? below.
If you are using an authorized agent to exercise your right to opt out, GFC may deny a request if the authorized agent
does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
GFC may disclose your Personal Information with our service providers pursuant to a written contract between us and each
service provider. Each service provider may be a for-profit entity that processes the information on our behalf.
GFC may use your Personal Information for our own business purposes, such as for undertaking internal research for
technological development and demonstration. We also share your Personal Information with other Client Websites belonging to the ARA family of
businesses. Neither of these is considered to be "selling" of your Personal Information.
GFC has not sold any Personal Information to third parties for a business or commercial purpose in the preceding twelve
(12) months. These Categories include:
- Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique
personal identifier, online identifier, Internet Protocol address, email address, and account name.
- Category B. Personal Information, as defined in the California Customer Records law, such as your name, contact information, education,
employment, employment history, and financial information.
- Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
- Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.
- Category E. Biometric information, such as fingerprints and voiceprints.
- Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest
data, and interactions with our and other websites, applications, systems, and advertisements.
- Category G. Geolocation data, such as device location.
- Category H. Audio, electronic, visual, and similar information, such as images and audio, video or call recordings created in connection
with our business activities.
- Category I. Professional or employment-related information, such as business contact details in order to provide you our services at a
business level or job title, work history, and professional qualifications if you apply for a job with us.
- Category J. Education information, such as student records and directory information.
- Category K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an
individual's preferences and characteristics.
Your rights with respect to your personal data
Your rights with respect to your personal data include the following:
- Right to request deletion of the data - Request to delete: You can ask for the deletion of your Personal Information. If you ask us to
delete your Personal Information, we will respect your request and delete your Personal Information, subject to certain exceptions provided
by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements
resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
- Right to be informed - Request to know: Depending on the circumstances, you have a right to know: i) whether we collect and use your
Personal Information; ii) the categories of Personal Information that we collect; iii) the purposes for which the collected Personal Information
is used; iv) whether we sell your Personal Information to third parties; v) the categories of Personal Information that we sold or disclosed
for a business purpose; vi) the categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
vii) the business or commercial purpose for collecting or selling Personal Information.
In accordance with applicable law, GFC is not obligated to provide or delete consumer information that is de-identified
in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, GFC will need to verify your identity to determine you are the same person about whom we have
the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you
have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can
match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or
email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
GFC will only use Personal Information provided in your request to verify your identity or authority to make the request.
To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your
identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your
identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
Other privacy may apply as follows:
- You may object to the processing of your Personal Information.
- You may request correction of your Personal Information if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does
not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- If applicable, you may request to opt out from future selling of your Personal information to third parties. Upon receiving an opt-out request,
GFC will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request
submission.
To exercise these rights, you can contact us by using the contact information provided in the Section HOW CAN YOU
CONTACT GFC? below. If you have a complaint about how we handle your data, we would like to hear from you.
Financial Incentives
"Financial incentive" means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion,
or sale of Personal Information.
The law permits financial incentives or a price or service difference if it is reasonably related to the value of the consumer's data. A business
must be able to explain how the financial incentive or price or service difference is reasonably related to the value of the consumer's data. The
explanation must include:
- a good-faith estimate of the value of the consumer's data that forms the basis for offering the financial incentive or price or service difference; and
- a description of the method the business used to calculate the value of the consumer's data.
In the future, GFC may decide to offer a financial incentive (e.g., price or service difference) in exchange for the retention
or sale of a consumer's Personal Information. If we decide to offer a financial incentive, we will notify you of such financial incentive and explain the
price difference, as well as material terms of the financial incentive or price of service difference, including the categories of Personal Information
that are implicated by the financial incentive or price or service difference. If you choose to participate in the financial incentive you can withdraw
from the financial incentive at any time by emailing us by using the contact information provided in the Section HOW CAN YOU
CONTACT GFC? below.
DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, GFC will update this Privacy Policy as necessary to stay compliant with relevant laws.
GFC may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and
the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, GFC may
notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy
Policy frequently to be informed of how we are protecting your information.
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of the United States of America, you may have the right to request access to the Personal Information we collect from you,
change that information, or delete it in some circumstances. To request to review, update, or delete your Personal Information, please connect with us
by using the contact information provided in the Section HOW CAN YOU CONTACT GFC? below.
If you require additional information or resolve an issue regarding our Privacy Policy, please contact GFC at:
Grassfire Communications
Michael Edward
c/o 250 Palm Coast Parkway NE
Bldg.607 Rm.422
Palm Coast Florida
non-domestic
800.625.4250
ME@grassfirecommunications.com