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PRIVACY POLICY

Privacy Policy

This is the privacy policy (“Privacy Policy”) for all websites owned and operated by Smartboost, LLC. (“smartboost” “SMARTBOOST” “we” or “our”), including siodigital.com, siohub.com, cngdigitalmarketing.com and smartboost.com, (collectively, the “Service”). We respect your privacy and appreciate the confidence you have placed in the Service. We are committed to protecting your privacy and preserving your trust. Please carefully review this Privacy Policy to learn about how we collect, use, and protect any personal information you provide us and your choices for managing your personal information. This Privacy Policy is subject to California Consumer Privacy Act CCPA. We want to communicate with you only if you want to hear from us. If you have questions or concerns regarding this Privacy Policy or wish to exclude your personal information from our direct marketing purposes, please feel free to contact us at: E-mail: legal@smartboost.com If you would like to update or delete your email address, mailing address or other personal information with us please contact us the same way.

What Kinds of information do we collect?

We collect information from our users at several different points on the Service. For example, we may collect personally identifiable information from you such as your first name, last name, phone number, mailing and postal, city, company name, job title and email address when you register, subscribe to one of our services, and at other times. We also collect credit card information in connection with any purchase you make through the Service. In addition, we automatically collect non-personal information such as your browser type, operating system, IP address, devices and Service usage information, in order to, among other things, evaluate and improve the performance of the Service. We will not sell, share, or rent personal information to third parties, and we will not otherwise disclose personally identifiable information to third parties, without your explicit permission, except as disclosed in this Privacy Policy.

How do we use this information?

We collect and use information for internal purposes, such as:
  • enhancing your experience at the service and to allow us to deliver the type of content and product offerings in which you are most interested;
  • performing administration and technical support for the Service;
  • sending periodic emails regarding products and services that may be of interest to you;
  • creating aggregate information about demographics and usage patterns;
  • following up with you after correspondence as live chat, email or phone inquiries;
  • inviting our promotional vendors and advertisers-with your explicit permission-to call to your attention special offers, products and services that may be of interest to you;
  • enabling purchases of goods and services.

How is this information shared?

We may use aggregate information to measure general Service usage patterns and characteristics of our user base, and we may include such aggregate information about our audience in reports to our commercial vendors. We may also disclose aggregated user statistics (for example, a certain percentage of our users live in a certain area) without your permission in order to describe our audience to existing and prospective advertisers or other third parties. However, this aggregate information does not reference names, phone numbers, email addresses, or other personally identifiable information, and it is not traceable to a specific recipient or user email address. We also may share personal information with companies affiliated with smartboost. In the event that smartboost is merged, or in the event of a transfer of our assets, we may disclose or transfer your personal information in connection with such transactions. In the event of such a transfer, we will notify you of the change of control of your personal information. You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your personal information to be shared or transferred to third parties without your permission. From time to time, we might establish a business relationship with other persons or entities whom we believe trustworthy and whom we have asked to confirm that their privacy practices are consistent with ours. For example, we may contract with service providers to provide certain services including credit card processing, data management, promotional services, etc. We provide our service providers with the information needed for them to perform these services. Each service provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of your information in order to protect your personal information from unauthorized access, destruction, use, modification or disclosure. Although unlikely, in certain instances we may disclose your personal information when we have reason to believe that it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Freedom or its affiliates, or to others. We may also disclose your personal information when we believe the law requires it. The general registration area can be found on the Service home page and at other locations throughout the Service. To use or access certain features of the Service, you may have to register or otherwise provide personal information. The decision to provide this information is optional; however, if you elect not to register or provide such information, you may not be able to access certain content or features or participate in various areas of the Service.

How do we protect your information?

We restrict access to your Information to employees who we have determined need it in order to provide products or services to you. We train our employees to safeguard customer information, and we require them to sign confidentiality and non-disclosure agreements. We maintain strict physical, electronic, and procedural safeguards to protect your Information from unauthorized access by third parties. We use encryption and authentication tools when appropriate to protect the security of personal information that you share with us. However, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect personal information, we cannot and do not guarantee or warrant the security of any information you transmit to or from the Service, and you do so at your own risk.

California Residents

Under the California Consumer Privacy Act (“CCPA”), California residents have the following rights: (1) the right to know, which is the right to request that SMARTBOOST disclose what personal information we collect, use, and may disclose about them; (2) the right to delete, which is the right to request that we delete personal information that is collected or maintained by SMARTBOOST; and (3) the right to non-discrimination, which is the right to be free from discrimination for exercising any consumer rights under the CCPA. We may limit our responses to any requests under the CCPA as permitted by law. To exercise your rights to know or delete under the CCPA, please email us at legal@smartboost.com. For verification purposes only, we will collect a limited number of personal identifiers, send those securely through a verification system, ask you follow-up questions through our online portal or representative, and then confirm whether your identity has been verified. You may also designate an authorized agent to make a request to know or delete on your behalf. To designate an authorized agent, you must provide the natural person, or entity registered with the California Secretary of State, with written permission to submit such a request. You (or your agent) will still be required to verify your identity. However, if an authorized agent has been provided with power of attorney in accordance with the California Probate Code, then no additional written authorization is required. All agents must submit proof to SMARTBOOST that they have been authorized by any consumer(s) to act on their behalf. NOTICE OF COLLECTION FOR CALIFORNIA RESIDENTS: In the 12-month period prior to the effective date of this Privacy Policy, we have collected the following categories of personal information:
  • First name, last name, phone number, mailing and postal, city, company name, job title and email address. We collect this category of information directly from consumers—either online, by phone, or in person.
  • Internet or other electronic network-activity information, which may include business information, such as browsing history, online identifier(s), IP (Internet Protocol) address, search history, and information regarding a consumer’s interaction with one of our operating websites, or advertisement. We collect this information through a user’s use of our website and third-party partners such as analytics and marketing softwares.
We collect each of the above categories of information for a variety of purposes, including:
  • For our core business purposes, such as providing quotes for our services,
  • To assess and improve our product and service offerings, including the development of new products and services.
  • To perform data analysis (including market and consumer search and analytics and trend analysis).
  • To conduct marketing activities and communicate with you regarding products and services offered by smartboost and its partners.
  • To deliver website content (including advertising) based on your interests and browsing history.
  • To enable you to interact with us through social media platforms.
  • To maintain and enhance the security of our systems, data, and workplace.
  • To hire qualified employees and maintain our workforce.
  • To comply with legal obligations and policies.
  • To bring and defend claims.
  • For other purposes as permitted by law or to which you consent.
We have not sold users’ personal information in the 12-month period preceding the Effective Date of this Privacy Policy. Please feel free to contact us with questions or concerns regarding our privacy policy and practices by emailing us at legal@smartboost.com or calling us at (800) 990-2429.

Children’s Privacy

We do not knowingly collect personally identifiable information from children under the age of 13. When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old. Fair Information Practices The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
  • We will notify you via email within 7 business days
  • We will notify the users via in-site notification within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors. If we decide to change our Privacy Policy, in whole or in part, we will inform you by posting the changed Privacy Policy here. Those changes will go into effect on the date posted in the notice. The new policy will apply to all current and past users of the Service and will replace any prior policies that are inconsistent. If there are any questions regarding this privacy policy, you may contact us using the information below. SMARTBOOST 3950 Sorrento Valley Blvd, suite 400 San Diego, California 92121United States legal@smartboost.com (800) 990-2429 Last updated: March 13th, 2020