AEROTRAINER PRIVACY POLICY

Effective Date: September 4, 2020

Version 2.0

Introduction and Scope

GOLO LLC (“GOLO”, “we”, “us” or “our”) respects the privacy of our visitors, users, customers, and members (referred to as “you” or “your”). This privacy policy (and as amended from time to time as posted on our website here) (“Privacy Policy”) describes the types of information we may or do collect from you or that you may provide when you visit or use our golo.com website (“Website”), purchase our products (“Products”), or use our services (“Services”), and our practices for collecting, using, maintaining, protecting, disclosing, retaining, and transferring that information. By “visitors” we mean visitors to our Website who are not yet customers, those who become customers, as well as those who do not become customers; whether you upload information to our Website, download it, or are merely visiting our Website. By “customers” we mean the persons who purchase our Products or Services. This Privacy Policy applies to you as applicable to the category to which you belong. This Privacy Policy applies to the data collected by us, or those working on our behalf, through information you enter or from the data imported from authorized and approved sources. It does not apply to data collected through other websites, products, or services not approved by us.

Acknowledgement and Consent

By visiting our Website or purchasing our Products or Services, you acknowledge that you accept the terms, practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, and share your information as described herein. If you do not agree with our policies and practices, your choice is not to use our Website or our Services. Your use of the Website and our Services is at all times subject to our Terms of Use (available here and as updated from time to time (the “Terms”)), which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

What Information Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of personally identifiable information. Such information is information which identifies, relates to, describes, or is reasonably capable of being associated or linked to a particular person, and may include name, mailing address, email address, telephone number, and other information (“Personal Information”). Please see additional information below on the information we collect. For this Privacy Policy the definition of “Personal Information” is the definition under the state, country, or other law applicable to the person whose data is collected; however, for California residents only, “Personal Information” shall have the definition as set forth in the California Consumer Privacy Act of 2018 (“CCPA”). Please see the section below entitled “Privacy Notice for California Residents” for more information.

We may also collect Personal Information from you through means other than our Website. This may include offline collection, such as if you submit a paper application, make a payment by check, or call or visit our office. It may also include emails, text messages, or other electronic communications that you send to us separate from our Website or by way of our third-party service providers. However, if we combine the Personal Information we collect from you outside of our Website with Personal Information that is collected through our Website or by another means as described above, the Privacy Policy will apply to the combined information, unless specifically disclosed otherwise.

Personal Information does not include your Personal Information that has been de-identified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).

Individuals under the Age of 18

We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. No one under age 18 should provide any Personal Information to us. In the event that we learn that we have collected Personal Information from a person under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.

California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see the section below entitled “Privacy Notice for California Residents” for more information.

Changes to Our Privacy Policy

We are constantly working to improve our Website and Services, and we may need to change this Privacy Policy from time to time as well. Our current Privacy Policy will always be on our Website and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates.

Please note that if you have opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Website, purchase products, or use our Services after any changes to the Privacy Policy have been posted, that means you agree to the new Privacy Policy, including all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.

Personal Information We Collect

We collect several categories of Personal Information from and about you as summarized in the following table:

Category

Specific Items of Personal Information

Identifiers

first and last name, user name (which may include first and last name), email address, postal address, unique personal identifier, e.g., device identifier (e.g., mobile device ID), IP address, customer/account name or number, phone number, cookies, beacons, pixel tags, mobile ad identifiers

Commercial Information

products/services purchased, purchasing/consuming history or tendencies

Internet or other electronic network activity

browsing, session, interaction, and search history related to our Website

Geolocation

physical location

Audio, electronic, visual, thermal, olfactory, or similar information

voice recording

Inferences drawn from any of the above to create a profile of a consumer

a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

 

How We Collect Personal Information and from What Sources

Information You Provide Us. The Personal Information we collect through our Website, or from our resellers, business partners, or service providers may include, but is not limited to:

  • Information that you provide by filling in webforms on our Website. This includes information provided when creating an online account, purchasing our products or Services, subscribing to our e-newsletters or other communications, requesting information from us, submitting or posting material (where permitted) on our forums, or interacting with customer support or service, report a problem with our Website, products, or Services, or otherwise communicating with us.
  • Records and copies of your correspondence (including email addresses), if you contact us
  • Your responses to surveys that we or our service providers might ask you to complete for research purposes
  • Your search queries on the Website
  • On mobile applications (parent, subsidiary and affiliate brands)
  • When communicating with customer service/support
  • Through participation in loyalty/rewards programs
  • Third party websites and mobile applications (e.g., websites that share information with us or advertising partners regarding online activities)
  • Data suppliers (e.g., companies that provide demographics and other information regarding consumers)
  • Online advertising companies
  • Fulfillment and delivery service providers
  • Social media companies
  • Other service providers

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

  • Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.
  • Behavioral Tracking. We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.

The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including, but not limited to, by enabling us to: (a) estimate our audience/visitor size and usage patterns; (b) store information about your preferences, allowing us to customize and improve our Website; (c) speed up your searches; and/or, (d) recognize you when you return to our Website.

Cookie Notice/Policy

The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF, and/or IP address. Each of these is discussed below.

Cookies (or browser cookies)

A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer or mobile device (Internet Explorer, Firefox, Safari or Google Chrome).

Different types of cookies which have different purposes are used on our Website.

Essential Cookies

These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.

Performance Cookies

These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Websites from their site and whether your visit has led to the use or purchase of a product or Service from our Website, including the references for the product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.

Functionality Cookies

These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.

It is possible that you will come across third-party cookies on some pages of sites that are not under our control.

We also use cookies to implement tracking technology on our Website. This allows us to display advertising that is tailored to you on our Website which parts of our content interest you the most and which Service categories you request. This tracking uses De-Identified Personal Information data). We will not combine this data with your other Personal Information without your express permission. Some of our service providers are allowed to place cookies on our Website. Those companies may also provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.

At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected; e.g., you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Local Storage Cookies. Certain features of our Website may use local stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.

GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.

IP Address. Our servers (or those of our service providers) may automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.

Information We Collect from Third Parties

We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website.

  • Third Party Services. If you link, connect, or login to your account with a third party social media service (e.g., Facebook, Google, Instagram, Yelp, etc.), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
  • Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Website through partnerships, or about your experiences and interactions from our partner ad networks.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Posting Content

You also may submit information, such as comments, reviews, testimonials, etc., to be published or displayed (“posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “Content”). Your Content is posted and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons. By posting any Content you agree to and do hereby grant us and our licensors, affiliates, partners, successors and assigns, a nonexclusive, perpetual, irrevocable, worldwide, sublicensable, transferrable, royalty-free right and license to use, store, display, publish, transmit, transfer, distribute, reproduce, rearrange, edit, modify, aggregate, summarize, create derivative works of and publicly perform the Content that you post or otherwise submit to us for any purpose, in any form, medium, or technology now known or later developed (“Right to Use”).

The Right to Use you grant us also extends to any Content that you have posted to our Facebook or other social media account pages, or on other websites, e.g., Google, Yelp, Trip Advisor, Instagram, etc. The term “Use” includes, but is not limited to, use, reproduce, modify, publish, list information regarding, edit, delete, translate, distribute, publicly display, publicly perform, and make derivative works of the content.

If we permit you to post Content, by posting any Content, or submitting Content for posting, you agree to with the following “User Content Posting Guidelines”:

To the extent our Website contains areas where you can post or submit to be posted such as comments, product reviews, testimonials, etc., you agree to post or submit Content that is proper and related to the general theme of the Website. Content also includes that which you send to us by email, text, mail, or other means. You agree not to post any Content that:

  • Is off-topic, false, inaccurate, misleading, defamatory, libelous, stalking, threatening, obscene, pornographic, indecent, vulgar, offensive, which contains unlawful material or information, or which otherwise violate the legal rights (such as rights of privacy and publicity) of others;
  • Harasses, degrades, intimidates, or is hateful toward an individual or group of individuals on the basis of religion, gender, sexual orientation or identity, race, ethnicity, age, or disability;
  • Is not your own original creation or that you do not have permission to use or that infringes the copyright, trademark, patent, or other proprietary right of any person or that is used without the permission of the owner;
  • Is intended to provide professional advice, including but not limited to, the provision of medical treatment, or legal, financial or investment advice;
  • Promotes or provides instructional information about illegal or illicit activities;
  • Purports to be from any person or entity, including but not limited to one of our employees, or falsely states or otherwise misrepresents your affiliation with a person or entity;
  • Includes personal or identifying information about another person without that person's explicit consent, or is doxing;
  • Contains software code of any kind, including, but not limited to, code that contain viruses, corrupted files, or any other similar software or programs designed to or that may interrupt, lock up, destroy, damage or limit the operation of another person's computer or network or telecommunications equipment;
  • Disrupts the normal flow of dialogue with an excessive number of messages (flooding attack) to the Website, or that otherwise negatively affects the ability of others to use the Website; or,
  • Advertises or offers to sell any goods or services, or engage in surveys, contests, chain letters, or for any commercial purpose.

You may not attempt to gain unauthorized access to our computer systems or those of any of our service providers or third parties, or engage in any activity that disrupts, diminishes the quality of, interferes with the performance of, or impairs the functionality of, the Website or our services. We reserve the right, but do not undertake the obligation, to refuse to post or remove any posted Content from our Website for violation of these rules or for any other reason, to refuse to accept any future postings by you, or to cancel your membership.

DMCA Notice. If you believe that any content on the Website violates these Terms or your intellectual property rights, you can report such violation to us in accordance with the Digital Millennium Copyright Act (17 U.S.C. §512 “DMCA”). In the case of an alleged infringement, please provide the following information:

      1. A description of the copyrighted work or other intellectual property that you claim has been infringed;
      2. A description of where the material that you claim is infringing is located on the Website (including the exact URL);
      3. An address, a telephone number, and an e-mail address where we can contact you;
      4. A statement that you have a good faith belief that the use is not authorized by the copyright or other intellectual property rights owner, by its agent, or by law;
      5. A statement by you under penalty of perjury that the information in your notice is accurate and that you are the copyright or intellectual property owner or are authorized to act on the owner’s behalf; and
      6. Your electronic or physical signature, or that of the person authorized to act on behalf of the owner of the copyright or other right being infringed.
      7. We have the right to terminate the user account of any user who repeatedly submits content that violates our intellectual property policies. A repeat infringer is a user who has been notified of infringing activity more than twice and/or has had User Content removed from the Website more than twice.
      8. We may request additional information before we remove allegedly infringing material. You may report a copyright violation by providing the above information to the designated agent listed below.

GOLO LLC
Attn: Support/DMCA
Address: 258 Chapman Road, Suite 202, Newark, DE 19702
Email: support@golo.com

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:

  • To present our Website and its contents to you.
  • To provide you with information and respond to your questions on products or Services that you request from us and information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you.
  • To provide you with the products, services, or information that you have requested.
  • To process transaction payments, including, but not limited to, product and/or service fees, subscription fees, professional fees, membership fees, registration fees, and payments, refunds and reimbursements for any products or services that you choose to purchase from us (though we do not receive your credit or debit card number).
  • To provide you with notices about your account, including expiration and renewal notices.
  • To notify you about information regarding or changes to our Website, our policies, terms, or any products or Services we offer or provide, or regarding your account.
  • To process your account application and any changes to your account information.
  • To process Personal Information or other information that you submit through to us.
  • To allow you to participate in interactive features on our Website.
  • To provide access to restricted parts of our Website, e.g., areas accessible if you have a user account.
  • To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends, or measuring demographics and interests.
  • For internal purposes, such as Website and system administration or internal audits and reviews.
  • For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.
  • To operate, maintain, and provide to you the features and functionality of the Services.
  • To provide statistics about the usage levels of the Website and other related information to reputable third parties, but these statistics will not include information which will allow you to be identified.
  • To notify you of data privacy incidents or provide you with legally required information.
  • To contact you regarding a sweepstakes, contest or promotion in which you have participated.
  • To request your participation in ratings, reviews, surveys, focus groups, or other initiatives which help us to gather information used to develop and enhance our products and Services.
  • For examination or event registration, scheduling, event attendance, administration and related purposes.
  • To fulfill any other purpose for which you provide Personal Information.
  • In any other way we may describe and for which we obtain your consent when you provide the information and you give your consent.

We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; and, (f) help you efficiently access your information after you sign in.

Our services may include a Short Message Service (“SMS”). Please see our SMS Terms of Service page available here, which is incorporated by reference herein.

Social Media Plugins

We may integrate social media application program interfaces or plug-ins (“Plug-ins”) from social networks, including Facebook, Google+, LinkedIn, Xing, Twitter, Instagram, Tumblr, Pinterest and/or possibly other companies, into the Website. In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site login.

For example, when you visit our Website, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Website with your IP address. If you click the Facebook “Like” button while you are logged on to your Facebook account, you can link the contents of our Website to your Facebook profile. This allows Facebook to assign your visit to our Website to your user account. Please note that as provider of the Website, we receive no notification about the contents of the transmitted data or their use by Facebook. If you do not want Facebook to assign your visit to our Website to your Facebook user account, please log out of your Facebook user account.

If you do so, you authorize us to access certain social media site account information, such as your public social media profile (consistent with your privacy settings in the social media site), your email address, interests, likes, gender, birthday, education history, relationships, interests, current city, photos, personal description, friend list, and information about and photos of your social media site friends who might be common social media site friends with other users. Plug-ins may transfer information about you to the Plug-in’s respective platform without action by you. This information may include your platform user identification number, which website you are on, and more. Interacting with a Plug-in will transmit information directly to that Plug-in’s social network and that information may be visible by others on that platform. Plug-ins are controlled by the respective platform’s privacy policy, and not by our Privacy Policy. You can find the privacy policy for a platform on their website.

How We Disclose Your Personal Information

We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more the following purposes:

  • Data storage or hosting providers for the secure storage and transmission of your data
  • Database and software service providers for the management and tracking of your data
  • Technology providers who assist in the development and management of our Website
  • Identity management providers for authentication purposes
  • Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
  • Payment solution providers for the secure processing of payments you provide to us
  • Fulfillment and shipping vendors for the fulfillment of our products and Services
  • Examination providers for the scheduling and delivery of credential and designation examinations
  • Survey and research providers who perform studies on our behalf

Disclosures to Service Providers: We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, analyze data, credit checks, screening checks, collection services, marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing search results and links (including paid listings and links), and processing credit card payments. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).

Event-Related Disclosures: From time to time, we may run contests, special offers, or other events or activities (“Events”), possibly together with a third-party vendor. If you provide information to such third parties, you give them permission to use it for the purpose of that Event and any other use to which you consent. We cannot control third parties’ use of your information. If you do not want your information to be collected by or shared with such third parties, you can choose not to participate in these Events.

Required Disclosures: Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process, or subpoena, including to respond to any government or regulatory request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, contracted vendors, or affinity partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) enforce our Terms or customer agreement (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations; (e) assist government enforcement agencies or to meet national security requirements; (f) to protect the security or integrity of our Website, our Services, or any software we provide related thereto; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others.

We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.

It is likely that the identity and categories of such third parties will change during the life of your account. We require that our third-party service providers only use your Personal Information as necessary to provide the requested services to us and each service provider is subject to a set of terms consistent with the applicable portions of this Privacy Policy.

We do not disclose or share your Personal Information with any third parties for which we receive any monetary or other valuable consideration. In other words, we do not sell your Personal Information, period.

Disclosure of De-Identified Personal Information: We may share De-Identified Personal Information with third parties for any purpose. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Website. It may be utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose. We may disclose, sell, rent, etc., your De-Identified Personal Information to third parties and we may receive valuable consideration for doing so.

Your Consent to Disclosure/Transfer of Your Personal Information: You consent to our disclosure of your Personal Information and other information to a potential or actual buyer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) of any or all of our rights to your Personal Information and your consents, in whole or in part, and other information, with or without notice to you and without your further consent.

Data Transfer/Access Outside of the United States

We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.

If you are a resident of a country other than the United States, you acknowledge and consent to our collecting, transmitting, and storing your Personal Information out of the country in which you reside.

Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of service providers who have special access rights to our systems, and who are required to keep the information confidential. Our Website software are scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safer.

Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information.

Our agents, contractors, service providers, and partners who require access to your Personal Information in order to provide services to us or to you on our behalf are also required to keep the information confidential in a manner consistent with this Privacy Policy and are not permitted to disclose the information to third parties or use the information for any purpose other than to carry out the services they are performing for us, or as permitted pursuant to our agreement with them.

The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or mobile device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given up those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.

Data Retention

The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will keep your Personal Information for as long as your account is active, or as long as you are an account holder or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.

Following termination or deactivation of your user account, we may retain your profile information and all information posted to public areas of the Website. Following termination or deactivation of your user account, we may retain your Personal Information and other data, but will maintain it as confidential according to the Terms, this Privacy Policy, and as required by applicable law. We have the right to delete all of your Personal Information and other data after termination of your user account without notice to you.

We may retain De-Identified Personal Information for as long as we deem appropriate.

Even if you delete your account, keep in mind that the deletion by our Service Providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. We may retain De-Identified Personal Information for as long as we deem appropriate.

What Information You Can Access, Change, or Delete

Through your user account settings page, you may access and, in some cases, edit, or delete certain information you have provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Products, Website, Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.

Privacy Notice for California Residents

The following in this section applies only to California residents.

California Online Privacy Protection Act (“CalOPPA”; Calif. Bus. & Prof. Code § 22575-22578:

CalOPPA applies only to companies which collect Personal Information of California residents.

How We Respond to Do Not Track Signals.

CalOPPA requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, see www.donottrack.us. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.

Visitors can visit our Website anonymously by adjusting the settings in your browser.

Third-Party Behavioral Tracking. We do not allow third-party behavioral tracking of Personal Information, though we may use De-Identified Personal Information to track users’ click or browsing patterns.

California Consumer Privacy Act of 2018 (“CCPA”): If you are a California resident (occasionally referred to as “Consumer”), California law provides you with additional rights regarding our use of your Personal Information. For purposes of this California Consumer Privacy Notice and only for California residents, the term Personal Information means “personal information” as defined under CCPA.

This “Privacy Notice for California Residents” section does not apply (at least until January 1, 2021) to the Personal Information of California residents that we collect:

  • which is  reflecting a written or verbal communication or a transaction between us and you, where you are acting as an employee, owner, director, officer, or contractor of a company or government agency and whose communications or transaction with us occurs solely within the context of our conducting due diligence regarding, or providing or receiving a product or service to or from such company or government agency; or,
  • in the course of your acting as a job applicant to or an employee of our company to the extent that your Personal Information is collected and used by us solely within the context of your role or former role as a job applicant to, an employee of our company.

California residents have the right to (a) access a copy of their Personal Information held by us, (b) request deletion of their Personal Information held by us, and (c) opt-out of the sale of their Personal Information (but which is inapplicable to us because we do not sell your Personal Information). These rights can be exercised by completing and submitting the webform available here.

The categories of your Personal Information we collect are listed above in the section entitled “Personal Information We Collect.” The purposes for which the categories of Personal Information are or may be used is described above in the section entitled “How We Use Your Information” and in other sections of this Privacy Policy.

No Sale of Personal Information

WE DO NOT SELL (AS THAT TERM IS DEFINED IN THE CCPA) YOUR PERSONAL INFORMATION, PERIOD.

Data Access and Portability Right

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, 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 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) and provide a copy to you in an electronic or paper format.
  • If we disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Right

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, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies (as described below).

As permitted by CCPA we may delete your Personal Information by (a) permanently and completely erasing the Personal Information on our existing systems with the exception of archived or back-up systems; (b) de-identifying the Personal Information; or, (c) aggregating the Personal Information.

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, 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.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal, regulatory or law enforcement obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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 sending an email to us at privacy@golo.com, or call us at 1-800-503-2390. Only you, or a person registered with the California Secretary of State that you authorize 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; and,
  • 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.

Verification Process

Upon receiving a data access or deletion request from you we will send an email to you at the email address we have for you on file. The email will ask you to respond to verify you as the Consumer making the request. Upon receipt of your verification we will match your information to that which is in our file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above).

Response Timing and Format

We will confirm receipt of your request within ten (10) days of receiving it. We will respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) 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.

Please note that this right does not apply to business-to-business customers, employment applicants, or independent contractors to us, or if the disclosure of Personal Information is for purposes consistent with the California resident’s reasonable expectations, when considering the submission’s circumstances.

Non-Discrimination

We will not discriminate against you simply for your 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 by refusing to grant discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or,
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Notices; Opting Out

By providing us with your email address (including by “following,” “liking,” linking your account to our Website or Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding the Service, the Website, and/or the Mobile App to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, where available, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.

You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.

Privacy Outside of the United States

If you are a citizen or resident of the UK, European Economic Area (“EEA”), Switzerland, or other regions with laws governing data collection and use that may differ from the laws in the United States, please note that we may transfer your information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. We may do so to process your information by staff operating outside these countries who work for us or for one of our service providers.

Contact Information

If you have any questions about this Privacy Policy, our privacy practices, or for any other purposes, please contact us: by email at privacy@golo.com; or by phone at 1-800-503-2390.