Instant Debt Solution PRIVACY POLICY
LAST UPDATED: [3/2/2022]
1. INTRODUCTION
Introduction to Instant Debt Solution’s Services
Instant Debt Solution and its various affiliates and subsidiaries provide to clients a wide variety of data-driven marketing services to help our clients provide more targeted, efficient and relevant marketing and communications. Our clients may use our services to advertise to and communicate through various media channels, such as, email, display ads, social channels, direct
mail, or other mediums.
The data we aggregate is not collected on this Website, but rather is received from data suppliers and partners. This Privacy Policy is offered to clients and users who want to learn more about our data collection and marketing services.
Introduction to the Privacy Policy
This Privacy Policy describes how Instant Debt Solution (“Instant Debt Solution”, “we”, “us”, “our”) collects, uses, and discloses the information it receives from its data-driven marketing services (the “Services”), as well as through www.continuingschool.org (the “Website”). Please read this Privacy Policy carefully. By accessing or using the Website or any other Services, you agree to the collection, use, and sharing of your information as described herein. If you do not agree to this Privacy Policy, please do not access and use the Website. Instant Debt Solution reserves the right to change this Privacy Policy at any time and will notify users of the existence of a new privacy statement. This statement and the policies outlined here are not intended to and do not create any contractual or other legal rights in or on behalf of any party.
Business Clients
If you represent a business and/or are specifically interested in the information that Instant Debt Solution collects to provide its Services, please refer to Sections 2, 3, and 6 below.
Website Users
To understand the ways in which we collect, use, and share information we’ve collected on the Website, please refer to Sections 4, 5, 6, and 8 through 13 below.
California Consumers
If you are a consumer who resides in the state of California, please review Section 7 below to exercise your rights under the California Consumer Privacy Act (CCPA) and other California laws, as applicable.
2. INFORMATION WE COLLECT FOR OUR SERVICES
To provide our advertising and marketing Services, we obtain the following categories of information from third-party suppliers and sources. Such information may be exact (such as an individual’s full name), or it may be presented on a segment level (e.g. “household income between $40,000 – $49,000”). Some of the below categories of information are given to us as estimates, predictions, or inferences. The information we obtain for our Services may include:
Basic identifiers and contact information, including name, home address, and email address, as well as unique identifiers linked to these records which allow us to associate the information within this subsection.
• Household identifiers and characteristics, such as ages and genders of persons in a household, the composition of a household (e.g., number of children and adults), and employment details of household members.
• Geographic and residential information, such as address, neighborhood, residence type, residence value, other characteristics of a residence, voting district, census block, ZIP code, county, and general region.
• Age and demographic information, such as age, ethnicity, language, religion, or country of origin.
• Education information, including the number of years spent in school and the level of education or degree achieved.
• Health information, such as the presence of certain ailments or health issues.
• Lifestyle information, such as marriage status, pet ownership details, hobbies, and affinities for certain types of goods groups, interests, or activities.
• Spending habits and characteristics, including type(s) of credit cards used, spending habits and interests, and expenses for certain types of purchases (e.g., vacations).
• Political activity and preferences, such as political party, political contribution activity, voter registration status, and donor codes.
• Earnings and financial information, including annual income, purchasing power, details on mortgage or other loans, property value, general investment activity, and asset values.
• Other inferred classifications and characteristics, including inferred information such as the type or classification that a given consumer is likely to fit within based upon the above factors.
• Automotive information, such as the type of automobile owned, new or used car purchases, or number of cars in a given home.
3. HOW WE USE INFORMATION TO PROVIDE OUR SERVICES
We may use the above information we collect to provide the Services to:
• Help our clients and businesses providing services to or partnering with our clients to target, deliver, and optimize their advertising efforts and marketing campaigns;
• Measure the effectiveness of our clients’ advertising campaigns;
• Grow and enrich our marketing and advertising databases;
• Tailor our clients’ advertising campaigns and identify individuals who will or will not be targeted with certain advertisements;
• Create sets of consumer attributes or data segments, which we then use to facilitate our clients’ marketing campaigns;
• Compile statistical analyses, including aggregate statistical reports; and
• Comply with applicable law and other legal requirements.
4. INFORMATION WE COLLECT FROM OUR WEBSITE
Instant Debt Solution’s website is primarily directed to potential and existing clients that may wish to use our Services. If you visit our Website or otherwise interact with us, we may collect the following information from you:
• Account Registration. When you create an account on the Instant Debt Solution Website, we collect the information you provide to us in order to create your account. Such information may include your name, email, and password
• Contact and Other Inquiry Forms. You may provide us with certain information when you contact us on the Website or when you otherwise send us an inquiry, including your name, email address, and content of your request.
• Comments or Discussions. We will receive any information you choose to include when you post a comment on our blog or otherwise post content to the Website.
• Job Applications. If you apply for a job with us, we will receive your name, email address and other contact information, and resume or CV details.
• Automatically Collected Information. If you visit our Website, we may collect and store certain information about your use of these sites, including your location, IP address, the name of the domain from which you access the Internet, the date and time you access our site, and the Internet address of the website you used to link directly to the Website.
The website uses cookies and similar analytic and tracking technologies to facilitate easier navigation and provide a higher level of convenience. A cookie is a small piece of information about an Internet session that may be created when a user accesses a website. Cookies and similar analytic or tracking technologies may automatically collect information about users. The cookies used by our Website are not written to your hard drive, exist only until your browser is closed, and do not retrieve any information from the your personal computer. To learn more about cookies, please refer to Section 11 below.
5. HOW WE USE WEBSITE INFORMATION
We may use the information we collect from you on the Website for certain purposes,
including to:
• Provide the Instant Debt Solution Services;
• Create and maintain your account with us;
• Communicate with you;
• Provide you with special offers or promotions;
• Promote Instant Debt Solution’s platforms and Services;
• Process and evaluate your application for employment;
• Better understand the way users interact with our Website;
• Provide customer support and respond to inquiries;
• Process orders;
• Process payments;
• Monitor the Website to protect against fraud or other malicious or damaging activity;
• Maintain the security of the Website;
• Enforce any applicable terms; and
• Comply with applicable law and other legal requirements.
6. HOW WE SHARE INFORMATION FOR BUSINESS PURPOSES
We may share the information we have collected for the Services and on the Website for a number of reasons. For example, we may share this information for certain business purposes, including:
• With service providers and partners
We use certain service providers and partners to help us operate or improve the Website and our Services. These service providers and partner assist us with various tasks, including data storage, payment processing, analytics, and campaign management. In addition to the above, we may share information in the following circumstances for the following purposes:
• For business transactions
We may transfer information if we are involved, in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
• When required by law
We may also share information if we also under a duty to disclose or share information in order to comply with any law or other legal obligation, respond to legal process, cooperate with law enforcement, exercise or defend legal claims, or to protect the rights, property, or safety of Instant Debt Solution, our customers or others.
• With consent or by request
With an individual’s permission or direction, we may disclose that individual’s information to a third party recipient.
7. YOUR CALIFORNIA PRIVACY RIGHTS
Sharing for direct marketing purposes
California law permits users in California to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is shared with third parties for direct marketing purposes. We may from time to time elect to share certain “personal information” with third parties for those third parties’ direct marketing purposes. California users may, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. Where applicable, California users may obtain the categories of personal information shared and
the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2019 will receive information about 2018 sharing activities). To make such a request, please contact us using the information listed below. Please note
that we are only required to respond to one request per California resident each year. California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) provides California residents with the additional rights listed here. To exercise these rights, see the “Exercising Your California Privacy Rights” subsection below.
• Right to Know
California residents have the right to know and see what information we have collected
about them over the past 12 months, including:
o The categories of information we have collected;
o The categories of sources from which the information is collected;
o The business or commercial purpose for collecting the information;
o The categories of third parties with whom we have shared the information; and
o The specific pieces of information we have collected.
• Right to Delete
California residents may have the right, subject to certain exceptions, to request that we delete the information we have collected (and direct our service providers to do the same).
• Right to Opt-out
We may sell or share this information for valuable consideration with third parties. For example, we may sell or otherwise share information with advertisers, who may purchase or license certain information for their own marketing purposes. California residents have the right to “opt-out,” or direct us to stop “selling” or otherwise sharing their information with third parties in exchange for monetary or other valuable consideration. To submit an opt-out request, please visit our webform or email us at dataprivacy@continuingschool.org.
• Other Rights
California residents have the right not to be discriminated against for exercising any of the rights listed above. Requests can also be submitted via an agent. However, we may require written proof of the agent’s authorization to act on behalf of a resident prior to fulfilling requests made through an agent.
• Exercising Your California Privacy Rights
To request access to or deletion of personal information, to opt-out, or to exercise any other rights under California law, please visit our webform or email us at dataprivacy@continuingschool.org, or contact us at the information listed in Section 14 below. We may require submission of additional information in order to verify and/or authenticate a request. We will do so in accordance with applicable law.
• Response Timing and Format
We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform the requestor of the reason and extension period in writing.
8. THIRD PARTY WEBSITES AND LINKS
Our Website may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Website and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.
9. SOCIAL FEATURES
Certain features of the Website permit you to initiate interactions between the Website and third-party services or platforms, such as social networks (“Social Features”). Social features include features that allow you to click and access Instant Debt Solution’s pages on certain third party platforms, such as Facebook and Twitter, and from there to “like” or “share” our content on those platforms. Use of Social Features may entail a third party’s collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both Instant Debt Solution and the third party may have access to information about you and your use of the Website and the third-party service.
10. USER GENERATED CONTENT
The Website may provide users with the ability to interact and post public comments. Through your participation in these features, you may submit your comments (User-Generated Content” or “UGC”) on our blog or other discussion board(s). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the ability to share it with third parties. If you choose to submit UGC to any public area of the Website, your UGC will be considered “public” and will
be accessible by anyone, including Instant Debt Solution. Please note that we do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or
security of any information that you make publicly available on the features permitting creation of UGC or what others do with information you share with them on such platforms. We are not responsible for the accuracy, use or misuse of any UGC that you disclose or receive from third parties through the forums or email lists.
11. COOKIES AND TRACKING
Do Not Track Signals
We do not currently respond to browser Do Not Track signals or other browser or device based mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. Unless and until the law requires us to respond to browser Do Not Track signals, we will not respond to those signals as an opt out, but if we do so in the future, we will describe how we do so here.
Cookies and Other Tracking Technologies You may control the way in which your devices permit the use of cookies or similar tracking technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some parts of Instant Debt Solution’s Website, including
any portal features and general functionality, to work incorrectly. Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Website or Services without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. For example, in the Internet Explorer menu bar, select: Tools Internet Option Browsing History Delete to view manual and automatic options.
12. SECURITY
Please note that any information you send to us electronically, while using the Website or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.
Please be aware though that, despite our best efforts, no security measures are perfect or
impenetrable, and we cannot guarantee “perfect security.” Any information you send us through
any means is transmitted at your own risk.
13. CHILDREN’S PRIVACY
We do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.
14. QUESTIONS OR CONCERNS
If you have any questions or concerns about your privacy or this Privacy Policy, including if you need to access this Policy in an alternate format, please email us at dataprivacy@continuingschool.org