Introduction
Aspirion respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the Aspirion website at https://www.aspirion.com/, and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On this website.
- In email, text, and other electronic messages between you and this website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
Please read this policy carefully to understand Aspirion’s policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our website https://www.aspirion.com/. By accessing or using this website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of this website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Information the Website Collects
(a) Information You Provide to Us
Personal Information. On the Aspirion website, we may ask you to provide personally identifiable information, which is information that identifies you personally, such as your first and last name, home address, email address, phone number, employer or other affiliated company name, account number, online account information, and bank account or payment card information (“Personal Information”). We may collect this information through various forms and in various places on our website, including through our service forms, if you request to receive information from us or when you otherwise interact with our website. If we combine any other information about you with the Personal Information we collect directly from you on our website, we will treat the combined data as Personal Information under this Privacy Policy.
(b) Information We Collect and Store as You Access and Use the website
In addition to any Personal Information or other information that you choose to submit to us via our website, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect and store certain information whenever you visit or interact with the website (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (each a “Device”) whenever you visit or interact with our website. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information with your Personal Information, we will treat it as Personal Information. This Usage Information may include:
- your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the website, and our computers identify your Device by its Device Identifier;
- your Device functionality (including browser, operating system, hardware, mobile network information);
- the URL that referred you to our website;
- the areas within our website that you visit and your activities there, including remembering you and your preferences;
- your Device location;
- your Device characteristics; and
- certain other Device data, including the time of day, and other information.
We may use various methods and technologies to collect and store Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit the website. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, go to Adobe’s website www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our website may not function properly, and that when you revisit our website your ability to limit cookies is subject to your browser settings and limitations.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our website’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the website, to monitor how users navigate the website, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the website, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the website, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even when the consumer blocks HTTP, Flash and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
We may use Tracking Technologies for a variety of purposes, including:
Strictly Necessary. We may use cookies or other Tracking Technologies that we consider to be strictly necessary to allow you to use and access our website, including cookies required to prevent fraudulent activity, improve security or allow you to make use of website functionality.
Performance Related. We may use cookies or other Tracking Technologies that are useful in assessing the performance of the website, including as part of our analytic practices or otherwise to improve the content, products or services offered through the website.
Functionality Related. We may use cookies or other Tracking Technologies to offer you enhanced functionality when accessing the website, including identifying you when you visit our website or keeping track of our specified preferences, including the presentation of content on our website.
Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on our website and third-party websites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
There may be other Tracking Technologies now and later devised and used by us in connection with the website. Further, third parties may use Tracking Technologies in connection with our website, which may include the collection of information about your online activities over time and across third-party web websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our website and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.
(c) Information Third Parties Provide About You
We may receive information about you from companies and others that use the website, such as when they submit your information to us about you. Additionally, we may, from time to time, supplement the information we collect directly from you on our website with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the website, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties.
(d) Interactions with Third-Party Services
The website may include functionality that allows certain kinds of interactions between the website and your account on a third-party website, application or other service. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, we may provide third-party websites’ interfaces or links on the website to facilitate your sending a communication from the website. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party websites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our website.
(e) Information You Provide About a Third-Party
You may send someone else a communication from the website, such as sending an information request on behalf of a friend. If so, the information you provide (names, email addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any such functionality on our website, your email address, mobile number, name or username and message may be included in the communication sent to your addressee(s).
(f) California / Delaware Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
How We Use the Information Collected
We may use your Personal Information, Demographic Information or Usage Information for various purposes, including:
- to provide you with information such as sending you electronic newsletters or updates;
- to improve the website, marketing endeavors or our website offerings;
- to customize your experience on the website or to serve you specific content that we believe is relevant to you;
- to help us collect a debt on behalf of one of our clients;
- to provide customer support;
- to contact you with regard to your use of the website and, in our discretion, changes to the website and/or website’s policies;
- to improve the overall experience at the website;
- for internal business purposes; and
- for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
How and When We Disclose Information to Third Parties
We may share non-Personal Information, such as aggregate user statistics, with third parties. Further, we may share your Device Identifiers with third parties along with data related to you and your activities. We do not share your Personal Information that we collected directly from you on the website with third parties for those third parties’ marketing purposes unless you consent to such sharing at the time you provide your Personal Information. In addition, we may share the information we collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. We may disclose your information as follows:
(a) When You Request Information from or Provide Information to Third Parties.
You may be presented with an option on our website to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our website or link to them from our website. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
(b) Third Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of us or the website, such as: (i) to assist us in website operations; (ii) to manage a database of customer information; (iii) hosting the website; (iv) designing and/or operating the website’s features; (v) tracking the website’s activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have regarding such choices is available in Section 4 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
(c) Administrative and Legal Reasons. We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the website’s Terms of Service or other policies applicable to the website, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the website or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
(d) Affiliates and Business Transfer. We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries, and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the website or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
Ads and Information About You
Data about your activities online is being collected on our website for use in providing advertising tailored to your individual interests. We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third-party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third-party websites and viewing of ads and of our content. Third parties may offer you a choice as to whether or not to have your information collected for that purpose. This section of the Privacy Policy provides details and explains how to exercise that choice.
You may see certain ads on our website and/or on other third-party websites across the Internet because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third-party websites by collecting information through automated means, including through the use of the tracking technologies described elsewhere in this Privacy Policy, and they use this information to show you advertisements (including our ads) that are tailored to your individual interests. The information they collect includes information about your visits to our website, such as the pages you have viewed. These third-party tracking technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your device and may set or change settings on your device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may act as web beacons, which enable third parties to carry out the previously described activities.
This collection and ad targeting may take place both on our website and on third-party websites that participate in the ad network, such as websites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website.
Third-party Tracking Technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to provide you with information on their practices and any available opportunity to exercise choice. The relevant third-party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties. Further, while we may use a variety of companies to serve advertisements on the website, you may wish to visit http://www.networkadvertising.org/choices, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other websites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI opt-out may not, or may no longer, be effective.
Mobile Text Information Privacy
We recognize the importance of protecting the privacy of end users’ mobile information. When you provide us with your mobile phone number and other personal information through text messaging, we will not share or sell your personally identifiable information (“Mobile Information”) to third parties for marketing purposes. Your Mobile Information will only be used for the purpose of providing you with services or information you have requested, and to communicate with you regarding your account or other matters related to our services. Your Mobile Information will be treated with the same level of protection as other personal information you provide to us, as described in this Privacy Policy.
Third-Party Content, Links to Third-Party Websites and/or Third-Party Apps Appearing on the Website
The website may contain content, links or apps that are supplied by a third-party, and those third parties may collect Usage Information and your Device Identifier when pages from the website are served to you for their own commercial purposes. In addition, when you are on the website you may be directed to other websites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their websites or apps. They may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the website onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our website and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.
Changing Your Information and Communications Preference
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The website may allow you to review, correct or update Personal Information you provided through the website’s forms, and you may provide updates and changes by contacting us via email at info@aspirion.com. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.
You may cancel or modify certain email communications you receive from us by following the instructions contained within such communications or in some cases by logging into your website account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to send you certain communications relating to your account or use of our website, such as administrative and website announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us via email at compliance@aspirion.com.
Transfer of Information to the United States
Our website is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the website or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.
Children Under the Age of 16
Our website is not intended for children under 16 years of age. No one under age 16 may provide any personal information on the website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at compliance@aspirion.com.
Security Safeguards
We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us. You agree that using our website and/or providing us with your information is at your own risk.
Changes to the Privacy Policy
We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our website indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than indicated at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
Privacy Policy Supplement for Residents of Certain U.S. States
This Privacy Policy Supplement section applies to residents of the following states: Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia. It is provided pursuant to applicable state privacy laws, including the:
- Colorado Privacy Act
- Connecticut Data Privacy Act
- Delaware Personal Data Privacy Act
- Iowa Consumer Data Protection Act
- Montana Consumer Data Privacy Act
- Nebraska Data Privacy Act
- New Hampshire Consumer Data Privacy Act
- New Jersey Data Privacy Act
- Oregon Consumer Privacy Act
- Texas Data Privacy and Security Act
- Utah Consumer Privacy Act
- Virginia Consumer Data Protection Act
This Supplement is intended to supplement our primary Privacy Policy. In the event of a conflict between this Supplement and our general Privacy Policy, this Supplement will govern with respect to residents of the above-listed states. Any terms defined under the applicable state privacy laws shall carry the same meaning when used in this Supplement.
1. Personal Data We Collect About You
We may process personal data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be directly or indirectly linked, with a consumer, device, or household (“personal data”).
Personal data does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the scope of the above privacy laws, such as (but not limited to) information governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Fair Credit Reporting Act (“FCRA”), and the Gramm-Leach-Bliley Act (“GLBA”).
We regularly process (and have processed in the past 12 months) several types of personal data about individuals regarding accounts we service or purchase, including:
- Identifiers – Examples: Name, signature, postal address, Internet Protocol address, email address, telephone number, account number, Social Security number, or other similar identifiers
- Financial Information – Examples: Bank account number, credit card number, debit card number, or other financial information; medical insurance information
- Protected Classifications – Examples: Age, gender, medical condition, disability, veteran or military status
- Commercial Information – Examples: Records of products or services purchased, obtained
- Internet or Other Similar Network Activity – Examples: Information on a consumer’s interaction with our website(s) or application(s)
- Audio, Electronic, Visual or Similar Data – Example: Call recordings
- Professional, or Employment-related Information – Examples: Current or past job history
- Inferences Drawn from Personal Information – Examples: To create a profile reflecting the consumer’s preferences, characteristics, aptitudes, or behavior
- Personal Information – Examples: A consumer’s Social Security Number, driver’s license, state identification card, or passport number; a consumer’s account log-in in combination with any required security or access code, password, or credentials allowing access to the account
2. Why We Process Your Personal Data
We regularly process personal data for one or more of the following business purposes:
- Fulfill the reason you provided the information. For example, if you share your personal data to make a payment, we will use that information to process your payment.
- Perform services on behalf of a business or service provider, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing analytic services, or providing similar services on behalf of the business or service provider.
- Provide you with information or services that you request from us
- Auditing related to consumer interactions.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient use, where the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction.
- Undertaking activities to verify or maintain the quality of a service or device that is owned, made by or for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, made by or for, or controlled by us.
- Respond to law enforcement requests and as required by applicable law or court order.
- As appropriate to protect the rights, property, or safety of us, our clients, or others.
- As described to you when collecting your personal information or as otherwise permitted by law.
We will not collect additional categories of personal data or use the personal data we collected for materially different purposes without providing you notice.
3. Third Parties To Whom We Disclose Personal Data
We regularly disclose (and have disclosed in the past 12 months) the above listed categories of personal data for business purposes to one or more of the following categories of third parties: our service providers (payment processing, mailing, and other vendors), regulatory and law enforcement agencies.
4. We Do Not Sell Personal Data Or Engage In Targeted Advertising Or Profiling
We do not sell your personal data, process your personal data for targeted advertising, or process your personal data for automated decision-making including profiling in furtherance of decisions that produce legal or similarly significant effect on you.
5. How To Request To Exercise Your Rights
Upon our verification of identity through commercially reasonable means you may request to exercise one or more of the following rights:
- To confirm whether or not we are processing your personal data and to access such personal data;
- To delete personal data provided by or obtained about you;
- To obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another company without hindrance, where the processing is carried out by automated means.
Additionally, upon our verification of identity through commercially reasonable means, Colorado, Connecticut, Delaware, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas and Virginia residents may request to exercise the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes for processing the data.
You may request to exercise these rights by one of the following methods:
- Via our website www.aspirion.com
- Calling us at 1.866.621.3601
- Emailing us at info@aspirion.com
Contact Information
For questions or concerns about our privacy policies and practices, please contact us at compliance@aspirion.com.