Privacy Policy
Effective Date: September
5, 2018
CCPA Privacy Notice for
California Residents Effective: January 2, 2020
Facilgo,
Inc. (“Facilgo”) is committed to providing our product and service users with
clear and concise information regarding our privacy policy and practices. This
Privacy Policy describes in detail our policy and practices regarding the
collection, use, and disclosure of user information by the technology and
services platforms owned and operated by Facilgo, Inc. By accessing our websites or utilizing our
products and services, you consent to the information collection and handling
practices outlined in this policy.
Information Collection
Facilgo
may collect various types of information, both personal and anonymous, through
our products, services, and websites. The information is gathered from your
usage of our products and services, as well as from your entry of information
on our websites. This collected information consists of two basic types of
data: 1) personal and business information and 2) non-personal information.
Personal
and business information is information that can be used to uniquely identify
you as an individual or contact you directly. This may include contact
information such as your name, signature, address, telephone number, email
address, mail forwarding address, lease dates, and move out date. For certain
financial or credit-based products and services, personal and business
information may also include sensitive data such as payment data, credit
records, social security numbers, date of birth, account numbers, employer
identification numbers, insurance policy information and license numbers.
Personal and business information is only collected based upon your choice to
provide it to Facilgo through our products, services, and websites. You have
the option to choose not to provide personal and business information to us;
however, the lack of such personal and business information will typically
prevent Facilgo from providing the requested products or services to you.
Because Facilgo seeks to help buyers and suppliers to find one another, extend
their network, and do business, you should assume that information you submit
for these purposes may be publicized on the Facilgo website.
If
you provide us personal information about others, or if others give us your
information, we will only use that information for the specific reason for
which it was provided to us.
Non-personal
information is general information that does not permit direct association with
you as an individual. When you browse Facilgo websites, we may automatically
collect non-personal information such as your IP address, device information,
browser, internet connection speed, past web pages visited, and your link
selections on our various website pages. This information may be used to: (1)
manage and protect our websites, products, services, and users from fraudulent,
abusive, or unlawful uses; and (2) help us research, develop, and improve our
websites, products, and services. This type of information may also be
aggregated or otherwise rendered anonymous for business and marketing uses by
us or by third parties.
Information Disclosure
Except
as explained in this Privacy Policy, Facilgo does not sell, license, or share
our users’ information without the consent and authorization of the user whose
information will be shared. Your personal and business information is your
property, although we may use this information in the aggregate as detailed
below.
We
may share your information within the technology
and services platforms owned and operated by Facilgo for operational and
marketing purposes. The Facilgo technology and services platforms that access
your information will do so in conformity with the practices described in this
Privacy Policy. Sharing this information allows Facilgo to provide you with the
best customer service experience possible, provide you with the services you
have ordered or requested, and notify you of the latest information regarding
new or enhanced products, services, and promotions. Facilgo may periodically
send offers, promotions, and updates regarding Facilgo products and services to
current and potential users via e-mail. Every marketing e-mail Facilgo sends
contains instructions and procedures allowing you to opt out of additional
marketing e-mails for that product or service.
In
some circumstances, we use third-party companies, agents, and contractors to
perform services on our behalf, such as website optimization, email
distribution, processing credit card transactions, processing ACH and other
payment transactions, infrastructure and IT services, background screening, and
other data processing or handling functions. In the course of engaging these
third party services, Facilgo only shares your information to the extent
reasonably necessary for the third party to perform the services on our behalf.
We do not permit these third parties to use or disclose your personal
information except for the purpose of providing the services we request of
them. However, please note that Facilgo does not maintain control over the privacy
policies and practices of any third parties, including, but not limited to, companies,
agents, and contractors.
Facilgo
also reserves the right to disclose user information if we reasonably believe
that such disclosure is necessary to (1) satisfy any applicable legal or
regulatory requirement, (2) to respond to a governmental request, as required
by law such as to comply with a subpoena, or similar legal process (3) enforce
Facilgo Subscription Agreements or Terms of Use or investigate potential
violations thereof, (4) to protect against fraudulent, malicious, abusive,
unauthorized or unlawful use of Facilgo products, services, and websites, or
(5) to protect our rights or property, or the safety or security of our
customers, employees or data.
If
Facilgo enters into any business transition, restructuring, merger, sale, or
other transferring of assets, we reserve the right to transfer user
information, including all personal information, as part of or in connection
with the transaction. You will be notified via email and/or a prominent notice
on our website of any change in ownership or uses of your personal information,
as well as any choices you may have regarding your personal information.
Cookies, Web Beacons, and Other Technologies
When
you access our websites, products, and services, Facilgo servers may place
small text files (“cookies”) on your computer for recordkeeping purposes. Among
other things, cookies enable Facilgo to gather information about your activity
on our websites, products, and services for the purposes of improving your
online experience, remembering your preferences and settings, delivering
advertising to match your preferences and interests, and for other similar
customization purposes.
In
addition to cookies, Facilgo may utilize web beacons, clear gifs, or other
technologies built into our websites, products and services to gather
information on how users interact with and utilize various features. These
technologies can help personalize your Facilgo usage experience and help associate
your interactions with our products and services to other information within
your account. For example, these technologies can identify popular pages,
viewing patterns, click-through, conversion rates, and other information that
can be used to improve, monitor, and operate our websites, products, and
services. For greater detail on how these technologies function and how your
activity records are used, please review the Google Analytics privacy
disclosures at www.google.com/policies/privacy/partners/.
Third Party Advertisements and Links to Other Sites
Certain
Facilgo websites may include third party advertisements and links to other
websites. These linked websites are operated by unaffiliated third parties that
have separate and independent privacy statements, terms of use, and related
notices or disclosures regarding information handling practices. Third party
advertisers may also utilize cookies, web beacons, and similar technologies to
collect information regarding your website interactions and activities. These
third party technologies may be utilized by those entities to provided targeted
advertising and web links based upon your activities and preferences. If you
choose to interact with specific advertisers who advertise on our sites, the
information you provide to them is subject to the conditions of their specific
privacy policies and in no way covered by the practices described in this
policy. Facilgo cannot be responsible for the information handling practices of
independent parties and encourages you to review their practices prior to
information disclosure.
Social Media Integration
Facilgo
websites, products, and services may include the option of integration through
third party social networking sites and related social media plug-ins or
applications. When you integrate or link our websites, products, and services
with your social media applications (e.g., Facebook, LinkedIn, Twitter,
Google+, etc.), you authorize Facilgo to have access to certain information
from your social media profile (e.g., name, e-mail address, photo, gender,
birthday, location, your list of friends, comments, etc.) to deliver the
content or as part of the operation of the integrated application. We may also
obtain non-personally identifiable information (e.g., content viewed,
advertising viewed, etc.) from your interaction with our integrated content.
By
choosing to integrate Facilgo websites, product, and services with social media
applications, you consent to the use of this information in accordance with our
privacy policy. When you provide personal and business information to us
through an integrated application, it may be publicly viewed by other members
of these sites and Facilgo cannot prevent further use of the information by
independent third parties. For more information about how social networking
sites handle your personal information and available privacy settings, please
refer to their privacy policies and terms of use.
Mobile Applications and Location-based Services
Certain
Facilgo websites, products, and services offer mobile applications for access
via smartphones and tablet devices. These applications are subject to the
information handling practices outlined in this policy.
Facilgo
mobile applications may include the option to provide you with helpful
information based on where you are. To provide such location-based services,
Facilgo may collect, use, and share precise location data, including the
real-time geographic location of your mobile device. This location data is
collected anonymously in a form that does not personally identify you and is
solely used by Facilgo to provide and improve location-based products and
services. If you wish to deactivate this feature, you can disable the location
services on your mobile device.
Information Security
Facilgo
implements and maintains physical, administrative, and technical safeguards
designed to secure user information and prevent unauthorized access to or
disclosure of that information. Under our security policies and practices,
access to sensitive personal information is authorized only for those who have
a business need for such access, and sensitive records are retained only as
long as reasonably necessary for business or legal purposes. Facilgo strives to
protect the user information that we collect and store, however, no security
program is 100% secure and we cannot guarantee that our safeguards will prevent
every unauthorized attempt to access, use, or disclose personal information.
Facilgo maintains security incident response policies and procedures to handle
incidents involving unauthorized access to private information we collect or
store.
Children’s Online Privacy
Facilgo
does not target children under the age of 13 for the collection of information
online. Our products, services, and websites are not designed to attract the
attention of persons under the age of 13.
Accessing and Updating Personal Information
In
the event that your personal information is found to be outdated, incomplete,
or inaccurate, you may access and update your information by logging into your
Facilgo product or service account. If you remove information that you posted
to the Facilgo website, copies may remain viewable in cached and archived
pages, or if other users have copied or saved that information. If you require
verification that your requested changes have been completed, and such
verification is not readily displayed in your product or service account, you
may request confirmation at the email address listed below (See “Contact Us”).
We will respond to your request as soon as possible and in any event within 45
days from the date of the request. If we need more time, we will let you know.
Privacy Policy Changes
As
Facilgo develops new products and services, updates or expands technologies,
and develops new information uses, we reserve the right to update this Privacy
Policy as necessary to reflect such changes. We recommend that you review our
website and this policy periodically for any changes that may have been made.
Your continued use of Facilgo products, services, and websites subsequent to
any changes made after your initial consent means that you agree to be bound by
those changes. The most current version of this Privacy Policy supersedes all
previous versions.
Contact Us
If
you have any questions or concerns about the Facilgo Privacy Policy or its
implementation, you may contact us at privacy@Facilgo.com or mail your written
inquiry to:
Facilgo, Inc.
Attn: Privacy (Legal)
4546 El Camino Real B10-185
Los Altos, CA 94022
Updated on September 5,
2018.
FACILGO, INC.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This Privacy
Notice for California Residents supplements the information contained in
the Privacy Policy, located at http://www,facilgo.com/privacy, for Facilgo,
Inc. (the “Company” or “us”) and applies solely to all
visitors, users, and others who reside in the State of California (“consumers”
or “you”).
We adopt this notice to comply with the California Consumer Privacy Act of 2018
(CCPA) and any terms defined in the CCPA have the same meaning when used in
this Notice.
This
Notice does not apply to employment-related personal information collected from
California-based employees, job applicants, contractors, or similar
individuals.
Where
noted in this Notice, the CCPA temporarily exempts personal information
reflecting a written or verbal business-to-business communication (“B2B personal information”) from some
its requirements.
1.
Information We Collect
We
collect information that identifies, relates to, describes, references, is
reasonably capable of being associated with, or could reasonably be linked,
directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal
information does not include:
•
Publicly available information from
government records.
•
Deidentified or aggregated consumer
information.
•
Health or medical information covered
by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and
the California Confidentiality of Medical Information Act (CMIA) or clinical
trial data.
In
particular, we have collected the following categories of personal information
from consumers within the last 12 months:
|
Category |
Examples |
Yes/No |
|
A. Identifiers. |
A real name, alias, postal address, unique personal identifier,
online identifier, Internet Protocol address, email address. |
Yes |
|
B. Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, address, telephone number. Some personal information included in this category may overlap
with other categories. |
Yes |
|
C. Protected classification characteristics under California or
federal law. |
Age (40 years or older), race, color, ancestry, national origin,
citizenship, religion or creed, marital status, medical condition, physical
or mental disability, sex (including gender, gender identity, gender
expression, pregnancy or childbirth and related medical conditions), sexual
orientation, veteran or military status, genetic information (including
familial genetic information). |
No |
|
D. Commercial information. |
Records of personal property, products or services purchased,
obtained, or considered, or other purchasing or consuming histories or
tendencies. |
No |
|
E. Biometric information. |
Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a template or other
identifier or identifying information, such as, fingerprints, faceprints, and
voiceprints, iris or retina scans, keystroke, gait, or other physical
patterns, and sleep, health, or exercise data. |
No |
|
F. Internet or other similar network activity. |
Browsing history, search history, information on a consumer’s
interaction with a website, application, or advertisement. |
No |
|
G. Geolocation data. |
Physical location or movements. |
Yes |
|
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar
information. |
No |
|
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
No |
|
J. Non-public education information (per the Family Educational
Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an
educational institution or party acting on its behalf, such as grades,
transcripts, class lists, student schedules, student identification codes,
student financial information, or student disciplinary records. |
No |
|
K. Inferences drawn from other personal information. |
Profile reflecting a person’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes. |
No |
|
L. Other information |
Lease information |
Yes |
We
obtain the categories of personal information listed above from the following
categories of sources:
•
Directly from you (e.g., from forms
you complete or products and services you purchase).
•
Indirectly from you. (e.g., from
observing your actions on our Website).
•
Indirectly from our customers (e.g.,
from our property management clients).
2.
Use
of Personal Information
We
may use or disclose the personal information we collect for one or more of the
following purposes:
•
To fulfill or meet the reason you provided
the information. For example, if you share your name and contact information to
request a price quote or ask a question about our products or services, we will
use that personal information to respond to your inquiry. If you provide your
personal information to purchase a product or service, we will use that
information to process your payment and facilitate delivery. We may also save
your information to facilitate new product orders or process returns.
•
To provide, support, personalize, and
develop our Website, products, and services and the products and services of
our customers.
•
To create, maintain, customize, and
secure your account with us, if any.
•
To process your requests, purchases,
transactions, and payments and prevent transactional fraud.
•
To provide you with support and to
respond to your inquiries, including to investigate and address your concerns
and monitor and improve our responses.
•
To personalize your Website
experience and to deliver content and product and service offerings relevant to
your interests, including targeted offers and ads through our Website,
third-party sites, and via email or text message (with your consent, where
required by law).
•
To help maintain the safety,
security, and integrity of our Website, products and services, databases and
other technology assets, and business.
•
For testing, research, analysis, and
product development, including to develop and improve our Website, products,
and services.
•
To respond to law enforcement
requests and as required by applicable law, court order, or governmental
regulations.
•
As described to you when collecting
your personal information or as otherwise set forth in the CCPA.
•
To evaluate or conduct a merger,
divestiture, restructuring, reorganization, dissolution, or other sale or
transfer of some or all of our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which personal information
held by us about our users/consumers is among the assets transferred.
We
will not collect additional categories of personal information or use the
personal information we collected for materially different, unrelated, or
incompatible purposes without providing you notice.
3.
Sharing Personal Information
We may
disclose your personal information to a third party for a business purpose.
When we disclose personal information for a business purpose, we enter a
contract that describes the purpose and requires the recipient to both keep
that personal information confidential and not use it for any purpose except
performing the contract. We share your personal information with the following
categories of third parties: service providers, customers, and their authorized
users.
4.
Disclosures of Personal Information for a Business Purpose
In
the preceding twelve (12) months, Company has disclosed the following
categories of personal information for a business purpose:
•
Category A: Identifiers.
•
Category B: California Customer
Records personal information categories.
•
Category G: Geolocation data.
•
Category H: Sensory data.
•
Category L: Other information.
We
disclose your personal information for a business purpose to the following
categories of third parties: service providers, customers, and their authorized
users.
5.
Sale of Personal Information
Company
has not sold any of your personal information to third parties.
6.
Your Rights and Choices
The CCPA provides consumers (California residents) with
specific rights regarding their personal information. This section describes
your CCPA rights and explains how to exercise those rights.
a.
Access to Specific Information and Data Portability Rights: You have the right to request that
we disclose certain information to you about our collection and use of your
personal information over the past 12 months. Once we receive and confirm your
verifiable consumer request (see the Section 6(c): Exercising Access, Data
Portability, and Deletion Rights, below), we will disclose to you:
•
The categories of personal
information we collected about you.
•
The categories of sources for the
personal information we collected about you.
•
Our business or commercial purpose
for collecting or selling that personal information.
•
The categories of third parties with
whom we share that personal information.
•
The specific pieces of personal
information we collected about you (also called a data portability request).
•
If we sold or disclosed your personal
information for a business purpose, two separate lists disclosing: (1) sales,
identifying the personal information categories that each category of recipient
purchased; and (2) disclosures for a business purpose, identifying the personal
information categories that each category of recipient obtained.
We
do not provide these access and data portability rights for B2B personal
information.
b.
Deletion Request Rights: You have the right to request that we delete any of your
personal information that we collected from you and retained, subject to
certain exceptions. Once we receive and confirm your verifiable consumer
request (see Section 6(c): Exercising Access, Data Portability, and Deletion
Rights, below), we will delete (and direct our service providers to delete)
your personal information from our records, unless an exception applies. We may
deny your deletion request if retaining the information is necessary for us or
our service provider(s) to:
•
Complete the transaction for which we
collected the personal information, provide a good or service that you
requested, take actions reasonably anticipated within the context of our
ongoing business relationship with you, fulfill the terms of a written warranty
or product recall conducted in accordance with federal law, or otherwise
perform our contract with you.
•
Detect security incidents, protect
against malicious, deceptive, fraudulent, or illegal activity, or prosecute
those responsible for such activities.
•
Debug products to identify and repair
errors that impair existing intended functionality.
•
Exercise free speech, ensure the
right of another consumer to exercise their free speech rights, or exercise
another right provided for by law.
•
Comply with the California Electronic
Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
•
Engage in public or peer-reviewed
scientific, historical, or statistical research in the public interest that
adheres to all other applicable ethics and privacy laws, when the information’s
deletion may likely render impossible or seriously impair the research’s
achievement, if you previously provided informed consent.
•
Enable solely internal uses that are
reasonably aligned with consumer expectations based on your relationship with
us.
•
Comply with a legal obligation.
•
Make other internal and lawful uses
of that information that are compatible with the context in which you provided
it.
We
do not provide these deletion rights for B2B personal information.
c.
Exercising Access, Data Portability, and Deletion Rights: To exercise the access, data
portability, and deletion rights described above, please submit a verifiable
consumer request to us by either calling us at (801) 610-6103 or emailing us at
privacy@facilgo.com.
Only
you, or someone legally authorized to act on your behalf, may make a verifiable
consumer request related to your personal information. You may also make a
verifiable consumer request on behalf of your minor child. You may only make a
verifiable consumer request for access or data portability twice within a
12-month period. The verifiable consumer request must:
•
Provide sufficient information that
allows us to reasonably verify you are the person about whom we collected
personal information or an authorized representative.
•
Describe your request with sufficient
detail that allows us to properly understand, evaluate, and respond to it.
We
cannot respond to your request or provide you with personal information if we
cannot verify your identity or authority to make the request and confirm the
personal information relates to you. Making a verifiable consumer request does
not require you to create an account with us. We will only use personal
information provided in a verifiable consumer request to verify the requestor’s
identity or authority to make the request.
d.
Response Timing and Format: We endeavor to respond to a
verifiable consumer request within forty-five (45) days of its receipt. If we
require more time (up to 90 days), we will inform you of the reason and
extension period in writing.
If
you have an account with us, we will deliver our written response to that
account. If you do not have an account with us, we will deliver our written
response by mail or electronically, at your option.
Any
disclosures we provide will only cover the 12-month period preceding the
verifiable consumer request’s receipt. The response we provide will also
explain the reasons we cannot comply with a request, if applicable. For data
portability requests, we will select a format to provide your personal
information that is readily useable and should allow you to transmit the
information from one entity to another entity without hindrance.
We
do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine
that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.
e.
Personal Information Sales Opt-Out and Opt-In Rights: If you are 16 years of age or
older, you have the right to direct us to not sell your personal information at
any time (the “right to opt-out”). We do not sell the personal information of
consumers we actually know are less than 16 years of age, unless we receive
affirmative authorization (the “right to opt-in”) from either the
consumer who is at least 13 but not yet 16 years of age, or the parent or
guardian of a consumer less than 13 years of age. Consumers who opt-in to
personal information sales may opt-out of future sales at any time.
To
exercise the right to opt-out, you (or your authorized representative) may
submit a request to us by calling us at (801) 610-6103 or emailing us at privay@facilgo.com.
Once
you make an opt-out request, we will wait at least twelve (12) months before
asking you to reauthorize personal information sales. However, you may change
your mind and opt back in to personal information sales at any time by calling
us at (801) 610-6103 or emailing us at privay@facilgo.com.
You
do not need to create an account with us to exercise your
opt-out rights. We will only use personal information provided in an opt-out
request to review and comply with the request.
7.
Non-Discrimination
We
will not discriminate against you for exercising any of your CCPA rights.
Unless permitted by the CCPA, we will not:
•
Deny you goods or services.
•
Charge you different prices or rates
for goods or services, including through granting discounts or other benefits,
or imposing penalties.
•
Provide you a different level or
quality of goods or services.
•
Suggest that you may receive a
different price or rate for goods or services or a different level or quality
of goods or services.
However,
we may offer you certain financial incentives permitted by the CCPA that can
result in different prices, rates, or quality levels. Any CCPA-permitted
financial incentive we offer will reasonably relate to your personal
information’s value and contain written terms that describe the program’s
material aspects. Participation in a financial incentive program requires your
prior opt in consent, which you may revoke at any time.
8.
Other California Privacy Rights
California’s
“Shine the Light” law (Civil Code Section § 1798.83) permits users of our
Website that are California residents to request certain information regarding
our disclosure of personal information to third parties for their direct
marketing purposes. To make such a request, please call us at (801) 610-6103,
send an email to privay@facilgo.com, or write us at: 4546 El Camino Real
B10-185, Los Altos, CA 94022.
9.
Changes to Our Privacy Notice
We
reserve the right to amend this privacy notice at our discretion and at any
time. When we make changes to this privacy notice, we will post the updated
notice on the Website and update the notice’s effective date. Your continued
use of our Website following the posting of changes constitutes your acceptance
of such changes.
10.
Contact Information
If
you have any questions or comments about this notice, the ways in which we
collect and use your information described here and in the Privacy Policy, your choices and
rights regarding such use, or wish to exercise your rights under California
law, please do not hesitate to contact us at:
Phone: (801) 610-6103
Website: www.facilgo.co
Email: privay@facilgo.com
Postal
Address: Facilgo, Inc.,
4546 El Camino Real B10-185, Los Altos, CA 94022
Effective
Date: January 2, 2020
Last
Updated on: January 3,
2020