1. Introduction This website is presented by The Capitol Group. The Company cares deeply about your privacy and wants you to understand how we collect and use information that relates to you. We gather personally identifiable information from individuals who choose to provide it and gather non-personally identifiable and aggregated information about those who engage with our content. Non-personally identifiable and aggregated information helps us to better understand visitors to our website and apps. We may share aggregated, non-personally identifiable information with our clients and affiliates. We will only collect, store and use any personally identifiable information (“PII”) you provide to us for the purposes identified in this Privacy Policy, and we strive to keep PII confidential.
  2. Purpose of this Privacy Policy This Privacy Policy explains how we handle PII that you share with us, and the non-personally identifiable and aggregated information we gather. As explained in detail below, our Privacy Policy is designed to provide notice to individuals regarding how their information is being collected and used.
  3. Information Collection
    1. Personally Identifiable Information The Company collects PII (e.g., your name, address, e-mail address, telephone number, fax number, demographic information, and information about your interest in and use of various products, programs and services, etc.) when you provide it to us. PII collected by the Company is maintained and used as set forth in this Privacy Policy.
    2. PII Collected on Behalf of our Clients If PII is collected by the Company on behalf of an identified client, such information belongs solely to the client and will be used solely in accordance with that client’s privacy policy. Accordingly, we encourage you to review our client’s privacy policies when submitting information for its use. An individual’s desire to “opt-out” of receiving marketing or other information from a client will be handled in accordance with the client’s privacy policy. The Company requests its client to use the data that we collect on its behalf in accordance with generally accepted privacy standards for both offline and online data, which includes an “opt-out” method for individuals who have provided PII. Ultimately, however, the Company is not responsible for data collected on behalf of our client when such data is in the possession of our client.
    3. Non-Personally Identifiable Information In addition to information you voluntarily provide to us, the Company may collect on behalf of our clients and/or on our own behalf non-personally identifiable information (e.g., Internet Protocol (IP) addresses, device identifiers, “cookies,” browser information, Internet tags and navigational data). We do not attempt to associate such non-personally identifiable information with PII or with specific individuals.
    4. Cookies ”Cookies” are small pieces of information that are stored by your web browser software on your computer’s hard drive or temporarily in your computer’s memory. The use of cookies is now an industry standard, and you will find them on most major web sites. The Company may place and store Internet cookies on a user’s hard drive. The use of cookies provide benefits to you by saving user names, information that are supplied at registration, and other information that may make the use of our programs easier. Although most web browsers are initially set up to accept cookies, if you prefer you can decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to delete the cookie. Please note, however, that certain areas on a web site may not function properly if your web browser does not accept cookies.
    5. Google Analytics We use Google Analytics to collect information about visitor behavior on our website. Google Analytics stores information such as what pages people visit, how long they are on the site, how they got here and what they click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We, therefore, do not collect or store your personal information (e.g. your name or address) in this manner, so this information cannot be used to identify who you are. We have turned on Google Analytics Demographics and Interest Reporting to get an idea of our demographics and users’ interests. You can opt-out here to prevent your data from being used by Google Analytics.
  4. Sharing, Storage, and Retention of Personally Identifiable Information
    1. Sharing Except as set forth in Section 4d above, the Company does not sell or rent PII to third parties, and shares PII with our clients only when the client has been identified to you. The Company does not otherwise disclose your PII to unaffiliated third parties unless you have consented to such disclosure; or unless the Company in its sole discretion determines disclosure is necessary to protect the Company, its clients or other users of our website, apps and/or services; or unless such disclosure is required by law. Notwithstanding, the Company does share PII with its corporate affiliates.
    2. Storage The Company has measures in place to ensure that PII is safeguarded against loss and unauthorized access, use, modification, disclosure or other misuse. The Company stores all PII in a secured environment behind its “firewall.” Only those employees whose job responsibilities require them to use the PII are permitted access to such data. All employees sign confidentiality agreements and are not permitted to disclose any PII.
    3. Retention The Company will retain your PII for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws.
    4. Analyzing Data One of the ways the Company improves its solutions is by analyzing your data to create a more engaging and effective experience. We may use the data provided by Google Analytics Demographics and Interest Reporting to develop the site and content around our users’ interests. The Company may aggregate and anonymize data to provide better products. The Company may share information created by using aggregated and anonymized data with affiliates, select business partners and third parties.
  5. Use of Personally Identifiable Information The Company uses PII for the purposes for which it is submitted to us (e.g., to register individuals for our programs, send requested information, or identify interest in products or services referenced in the content we are involved with), and to communicate with individuals about our and/or our clients’ programs and products. You may opt out of receiving communications from us by updating your profile and/or preferences, if you have created an account or otherwise registered on our website or app, or by contacting us at 1-313-564-4820. You may opt out of receiving communications from our clients that we have identified to you by following the “opt-out” procedures described in each client’s privacy policy.
  6. Sharing and Use of Non-Personally Identifiable Information We use the non-personally identifiable and aggregated information we collect to better understand how visitors to our website/apps engage with the content we are involved with, and to assess, improve, and quantify the response to such content. We may share aggregated, non-personally identifiable information with our clients and affiliates.
  7. Collection of Information by Third Parties and Links to Third-Party Websites Our website may serve ads from and/or link to the websites of third-parties. Such third-parties may use automated methods to collect information about visitors to our websites.
  8. Special Note about Children Unless otherwise specifically indicated, the Company’s programs are not available to anyone under the age of thirteen (13). We do not solicit PII from children, and no one under the age of thirteen (13) should submit PII to us. If we discover that PII submitted to us pertains to a child under the age of thirteen (13), we will delete it.
  9. California Privacy Rights
    1. Rights of Minors. If you are a resident of the State of California and between the ages of thirteen (13) and eighteen (18), and have registered as a user of one or more of our websites or apps, you may request the removal of content or information you have posted that can be accessed by other users, by updating your profile and/or preferences. Please note, however, that removal of content or information you have posted from our websites or services does not ensure complete or comprehensive removal of the content or information, particularly if the content or information you posted has been copied and/or reposted by a third party.
    2. California Customers Pursuant to California Civil Code Section 1798.83, a California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes, unless the business adopts and discloses to the public a policy of not disclosing customer’s personal information to third parties for their direct marketing purposes if the customer “opts out” of such communications. In that case, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost-free means to exercise that right. Our cost-free “opt-out” procedure is described in Section 5 above. If you use our “opt out” procedure, we will not disclose your personal information to third parties for the third parties’ direct marketing purposes.
    3. Do Not Track Signals California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
  10. GDPR The Company processes Personal Data both as a Processor and as a Controller, as defined in the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the “Directive”) and the GDPR.The Company adheres to the Directive and the GDPR. Consequently, the Company processes all data provided by its Users with accounts in its United States and the European Data Region, in the European Economic Area (EEA) or the United States only.

    All data collected by the Company will be stored exclusively in secure hosting facilities. The Company has a data processing agreement in place with its provider, ensuring compliance with the Directive. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA and the United States is done in accordance with this data processing agreement.

  11. Material Changes to Policy The Company may make material changes to this Privacy Policy from time to time. Therefore, you should periodically visit this page to view the current Privacy Policy. Your continued use of our websites and any subsequent submission of PII to us indicates your consent to the terms of our then-current Privacy Policy. In the event of a material change to this Privacy Policy, the Company shall send an email advising of the change to all persons whose email addresses we have collected and retained pursuant to the terms set forth above.
  12. Data Protection Officer The Company’s Data Protection Officer may be reached at the following number if you have any questions 1-313-564-4820