Privacy Policy | CareerSmart Learning

CAREERSMART LEARNING

PRIVACY POLICY

(Website)

Last modified as of: July 5, 2024

Introduction

Careersmart Learning, a division of ISYS Solutions, Inc. (“Company” or “We”), respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide the Company in the course of your interactions with us, including when engaging with the Company website, https://careersmart.com/, or the Absorb LMS platform we make available to you (collectively, our “Website“), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

On this Website.

In email, text, phone, and other electronic messages between you and this Website and the Company.

When you interact with our advertising or applications on third-party websites and services, if those applications or advertising include links to the Website.

When you contact us through any means including in person (e.g., at a conference), in writing, or via telephone.

Except as may be provided in the “Your California and Texas Privacy Rights“ section below, this policy does not apply to information collected:

through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website; or

from a publicly available source.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or engage our services. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website to exchange information after we provide notice of the changes is deemed to be acceptance of those changes, so please check the policy periodically for updates and keep your contact information up to date.

Third-Party Payment Processor

We may use a third-party payment processor, such as PayPal, Inc. and/or Stripe, to conduct payment transactions.  We do not collect or retain any payment card or financial information related to your transaction.  We may share your personal information (such as name and address) with third-party payment processors so they can assist with the operation of our Website and Services.  If you authorize a payment using our third-party payment processor, then you acknowledge that we may disclose payment transaction data and related information to the third party that provides the authorized transaction.  The use of your information by that third party will be subject to their applicable privacy policy, which you should review carefully. You may find information about PayPal, Inc.’s privacy policy on their website at www.paypal.com.  You may find information about Stripe’s privacy policy on their website at www.stripe.com.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at inquiries@isyscm.com or 800-992-8100.

Information You Voluntarily Provide to Us.

The information we may collect from you on or through our encrypted Website, in the course of providing you services, or when communicating with you includes:

Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, inquiring about products or services, subscribing to our service, completing your profile, or posting material. We may also ask you for information when you report a problem with our Website.

Information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, company name, job title, professional license number, certification numbers, and any other personally-identifiable information you choose to provide us.

Records and copies of your correspondence (including email addresses), if you contact us.

Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.  We do not store the personal financial information you provide in order to place an order or make payments.  For more information, please see the Third-Party Payment Processor” section of this policy.

Information necessary to carry out Company services.

Your search queries on the Website

Information contained in emails exchanged in the course of your interactions with us.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“), such as a personal testimonial or review of Company services. Your User Contributions are posted on and transmitted to others at your own risk. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, read pages, download information, or view courses or other content, we 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 traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

Information about your computer and internet connection, including your IP address, operating system, internet service provider (for example “ompany.com”) and browser type.

The information we collect automatically is aggregated with data collected automatically from other users. We may maintain automatically collected data 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 by enabling us to:

Estimate our audience size and usage patterns.

Store information about your preferences, allowing us to customize our Website according to your individual interests.

Speed up your searches.

Recognize you when you return to our Website.

Market and advertise our products and services.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting 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.

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

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

For additional information about our use of cookies and other tracking technologies, please see our Cookie Policy.

Do Not Track

“Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Website is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.

Third-Party Use of Cookies and Other Tracking Technologies.

Some content on the Website may occasionally have links to external websites run by third parties over which the Company has no control. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you. Information they 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. 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 a third-party site you should contact the responsible third party directly.

Third-Party Platforms & Data Sharing Practices

Social Media Links

This Website may contain links to other sites, including, but not limited to, Facebook, Instagram, YouTube, LinkedIn, and X We are not responsible for the privacy of such other sites. Please read the policy statements on those sites for information about the data privacy practices of the organizations that operate them.

Google Analytics

We use Google Analytics to analyze traffic to this Website. Google Analytics works by automatically sending certain information to Google. This includes, for example, the web address of the page that you’re visiting and your IP address. Google may also set cookies on your browser or read cookies that are already there. For more information on how Google obtains and uses data when you use this Website, please review Google’s policy at: https://www.google.com/policies/privacy/partners/.

Cloud-Based Video Conferencing Services

The Company is integrated with or may otherwise interact with third party applications, websites, and services (“Third Party Applications”) such as Zoom to make interactions or education more accessible to you. These Third-Party Applications may have their own terms and conditions of use and privacy policies and your use of these Third-Party Applications will be governed by and subject to such terms and conditions and privacy policies. You understand and agree that the Company does not endorse and is not responsible or liable for the behavior, features, or content of any Third Party Application or for any transaction you may enter into with the provider of any such Third Party Applications, nor does Company warrant the compatibility or continuing compatibility of the Third-Party Applications with the Service.

Webinars and other live or virtual interactions may be recorded for internal quality control purposes and may also be rebroadcast, with express permission of participants.

Absorb LMS

The Company utilizes a third-party platform, Absorb LMS, to provide you learning content, transcripts, and other continuing educations resources. For information about Absorb LMS’s data privacy practices, please review its privacy policy, available here.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.

To provide you with information, products, or services that you request from us.

To fulfill any other business-to-business or personal professional service transaction or purpose for which you provided personal information.

To provide you with notices about your account status.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

To notify you about changes to our Website or any products or services we offer or provide though it.

To allow you to participate in interactive features on our Website.

In any other way we may describe when you provide the information.

For any other purpose related to our provision of services to or interactions with you

For any other purposes not described here with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please “unsubscribe” from any emails you receive.  For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

The Website is operated from our offices in the United States using network hosted servers in United States. When you provide information to us, it may be transferred to a jurisdiction with different privacy rules than those in the jurisdiction in which you are located.

Disclosure of Your Information

We may disclose personal information that we collect, or you provide, as described below:

To our subsidiaries and affiliates.

To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

On certain occasions, we may provide your contact information (First and Last Name and email address) to third-party sponsors in exchange for that party offering educational content at no additional charge to the user (“Sponsored Content”).  In such cases, your contact information will be shared only if you agree to the terms of use for access to that free educational content.  For more information, see Choices About How We Use and Disclose Your Information.

To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.

To a successor in interest in the event we are bought, sold, or otherwise transferred to a new owner.

For any other purpose disclosed by us when you provide the information.

To other parties at your request.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Disclosure of Your Information for Sponsored Content. If you do not want us to disclose your personal information to unaffiliated or non-agent third parties in exchange for access to Sponsored Content, you can opt-out by emailing us at info@careersmart.com or by clicking on the “unsubscribe” button at the bottom of any email. By opting out, you may not be granted access to the Sponsored Content.

Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own products or third party products or services, you can opt-out by emailing us at inquiries@isyscm.com by clicking on the “unsubscribe” button at the bottom of any email. If we have sent you a promotional email, you may also send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or in the course of exchanging information related to providing services.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Absorb LMS and visiting the Profile section on your learner dashboard. You may also request help with changing your profile information by emailing inquiries@isyscm.com. Users are not permitted to change their names in the edit profile section for transcript security reasons. If a user wishes to use a different name, they must create a new account via the CareerSmart website.

Those visiting the company website residing in California and Texas may also send us an email at inquiries@isyscm.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change or delete information if we believe it would violate any law or legal requirement or cause the information to be incorrect. To protect your information, if the authenticity of the request cannot be reasonably verified, the request will be denied.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use.

Your California and Texas Privacy Rights

This section applies only to California and Texas residents. It supplements and amends the information contained in this privacy policy with respect to such individuals. The other provisions of the policy continue to apply, except as modified in this section.

This section does not apply to individuals who are employees, applicants, or contractors of the Company. Employees, applicants, and contractors residing in California may refer to our notice at collection and privacy policy for those individuals.

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 individual or household (“personal information”).

We may have collected the following categories of personal information. . Personal information excludes, without limitation: (i) publicly available information from government records; (ii) deidentified or aggregated consumer information; (iii) personal information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations, the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the Financial Code), or protected health information that is collected, processed, sold, or disclosed pursuant to the federal Health Insurance Portability and Accountability Act, and implementing regulations.

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. 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).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
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.	YES
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
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.	YES
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES
L. Sensitive personal information	Sensitive information means a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; citizenship or immigration status; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information concerning a consumer’s mental or physical health; personal information related to a child; and personal information concerning a consumer’s sex life or sexual orientation.	YES

We retain your personal information for as long as necessary to provide you products and services, maintain our business relationship, other related activities and in accordance with the Company’s data retention schedule, unless we have deidentified or deleted your personal information in response to a request to delete. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, collect fees, or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; and applicable legal requirements.

Use of Personal Information

We may collect or use the personal information 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 ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we will use that information to process your payment and facilitate delivery.

To contact you and/or provide you with email alerts and other notices concerning our products, services, events, or news that may be of interest to you. For example, we may send you announcements, surveys, and newsletters using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means. Of course, if at any time you no longer wish to receive such communications, you have the option of unsubscribing from our mailing list for that communication.

To provide, support, personalize, and develop our Website, products, and services.

To create, maintain, customize, and secure your account and subscription with us.

To process your requests, 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 service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email.

To report to certain state boards and/or state boards that use CE Broker to find, track, and approve continuing education/contact hours. As an education provider, the Company reports to CE Broker on User activity in applicable states at the close of each calendar month. For this reporting, the User’s name, state, and license number are required. It is the responsibility of the User to provide the Company this information and keep it up to date. If User does not provide this information, the Company may be unable to complete reporting to the appropriate state boards via CE Broker. User is also responsible for confirming reporting has been received by the appropriate boards and that all applicable requirements have been met.

To help maintain the safety, security, and integrity of our Website, 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 California Consumer Privacy Act, as amended (“CCPA”), or the Texas Data Privacy and Security Act (“TXDPSA”).

To manage our recruiting efforts and employment and workforce relationships. These activities include, for example, sourcing and processing employment applications, onboarding employees and contingent workers, and carrying out a range of employments activities relating to the employment relationship, such as compensation, benefits, promotion, discipline, termination, and certain post termination activities.

As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.

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 Website 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.

Sources of Personal Information We Collect

You. We may collect personal information that you provide during your interactions with us, such as through our Website, by email, or when you communicate with our professionals online, by phone, at one of our locations, or through social media. We may also collect information when you attend an event, or participate in a program we sponsor. We collect information when you are an applicant for employment with us and employed by us.

Related Entities and Affiliates. We may collect information about you from our related parties and affiliates, including joint ventures (if any).

Social media and related services.

Service providers and contractors. When you obtain products and services from us, we may collect your personal information from service provider and contractors who collected information about you that is needed to provide those products and services.

News outlets, social media, surveys, and certain third parties. In the course of performing our services or marketing activities, we or third parties on our behalf may conduct research and other activities resulting in the collection of personal information about you.

Information Collected Automatically. As you navigate through and interact with our Website, we may compile statistical information concerning your usage of the Website through analytics services, such as those provided by Google Analytics. To do so, we may collect certain information about your equipment, browsing actions and patterns, including:

Details of your visits to our Website, such as traffic data, location data, logs and other communication data and the resources that you access and use on the Website.

Information about your computer and internet connection, including your IP address, operating system, and browser type.

Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, and the website that referred you to our Website.

Information about your preferences to make your use of the Website more productive, via the use of cookies. For more information on cookies, please see our Cookie Policy. While all of this information can be associated with the IP address your computer had while you visited the Website, it will not be associated with you as an individual or with any other information you may submit through the Website or that we may store about you for any other purposes. We may use this information to generate aggregate statistics about visitors to our Website. Please check your web browser if you want to learn what information your browser sends or how to change your settings.

Disclosures of Personal Information for a Business Purpose

We may disclose your personal information to service providers and contractors who help us provide the products and services, such as, payment processing, marketing and advertising, email, text and other communications, applications, business support, and website, software, platform, cloud, data storage and other technical services.

We may also disclose your personal information if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.

Lastly, we may transfer to a third party personal information as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires of all or part of the assets of our business.

Of the categories of PI noted above, we may have disclosed the following:

Categories of Personal Information	Categories of Third Parties to Whom Disclosed & Purposes for Disclosure
Address and other identifiers Protected status – such as citizenship, ethnic background, gender, or other similar identifiers Financial information – such as bank account details, credit history, income details or other similar identifiers Education or professional information, including veteran status or other similar identifiers Sensitive Personal Information	Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose your personal information to one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose personal information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Governmental entities, legal service providers. We may disclose your personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement Geolocation data Audio, electronic, visual, thermal, olfactory, or similar information.	Third parties as directed by you. We may disclose your personal information to third parties to whom you direct. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf. Governmental entities, legal service providers. We may disclose personal information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Biometric Information Inferences drawn from personal information – such as individual profiles, preferences, characteristics, behaviors or other similar identifiers	Third parties as directed by you. We may disclose your personal information to those third parties to whom you direct. Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf.

Your Rights and Choices

You may have certain rights related to your personal information, subject to certain exceptions. Specifically:

Right to Know. You may have the right to request that we disclose certain information to you about our collection and use of your personal information. 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 to whom we disclose that personal information.

The categories of personal information we sold or disclosed for a business purpose.

The specific pieces of personal information we collected about you (also called a data portability request).

If you previously provided us your personal information, and that information is available in a digital format, you may have the right to obtain a copy of the information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another person without hindrance.

Right to Delete. You may 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 and contractors, as applicable, 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 the personal information was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.

Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.

Debug to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when the Company’s deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.

To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which the consumer provided the information.

Comply with a legal obligation.

Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to correct. You may have the right to request that the Company correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable consumer request (see below), we will provide a response to such requests.

Right to Opt-Out of Selling, Sharing, Targeted Advertising, and/or Profiling. With your consent, we may disclose limited personal information related to you to third parties for the purpose of them offering you free Sponsored Consent. To opt-out of these disclosures, please contact us at 800-992-8100 or you may complete the webform available at the following link. We do not otherwise disclose your personal information in ways that qualify as the “sale” or “sharing” of that information, or use of it for “targeted advertising” or “profiling”, under applicable law. We also treat Global Privacy Control browser signals as opt-out of sale/sharing/targeted advertising/profiling requests and process these requests in a “frictionless manner” (as defined under applicable law). To opt-out via the Global Privacy Control, please follow the instructions available here. 

Right to Consent to or Limit Use or Disclosure of Sensitive Personal Information. You may have the right, subject to certain exceptions, to consent to or request limitations on the use and disclosure of your “sensitive personal information,” as that term is defined under applicable law. We do not use sensitive personal information to infer characteristics about data subjects nor for purposes other than those set forth in Section 7027(m) of the regulations implementing the CCPA. Upon receipt of a verifiable consumer request, and as required by applicable law, we will take appropriate steps to respond to your request. Additionally, where required by applicable law, we will process your sensitive personal information only with your consent.

Exercising the Rights to Know, Delete, and Correct. To exercise the know, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 800-992-8100

Emailing us at inquiries@isyscm.com

Completing the webform available here [link to form]

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 make up to two verifiable consumer requests for access or data portability within a 12-month period, free of charge. We will verify your identity before responding to your request. To enable us to respond to your request, you must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collect 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. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to the personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Time 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.

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 usable and should allow you to transmit the information from one entity to another entity without hindrance. Data portability request format will be determined upon request.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Authorized Agent. You may authorize a natural person or a business (the Agent) to act on your behalf with respect to the rights under this section. When you submit a Request to Know, Correct, or Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

Appeal of Our Response. In the event you believe we have erroneously denied your request, in full or in part, you may, within 60 days of receipt of that denial, submit an appeal at 1-800-992-8100 or webform. In your appeal submission, please explain why you believe our decision to deny your request was incorrect and please provide any additional information you believe we should consider in connection with your appeal. Within 60 days of receipt of your appeal, we will advise you in writing of any action we have taken, or refrained from taking, in response to your appeal, along with an explanation of why we have taken, or refrained from taking, such action.

Nondiscrimination. We will not discriminate against you for exercising any of your rights under this policy. The right to nondiscrimination also includes, for California residents, an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their rights.

California 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 send an email to inquiries@isyscm.com or write us at: P.O. Box 189, Brea, CA 92822. After taking reasonable steps to verify the authenticity of your request, we will provide the requested information within a reasonable period of time.

Financial Incentives

We offer free access to certain Sponsored Content to customers who opt-in to our disclosure of their email address or phone number to the third-party providers of this content. This financial incentive is reasonably related to our good faith estimate of the value of the data you provide. You can opt-out of receiving Sponsored Content from us at any time by following the instructions in the Choices About How We Use and Disclose Your Information section above.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use secure socket layer (SSL) technology to help protect the security of transactions. All information you provide to us is stored on secure servers behind firewalls. No system for safeguarding personal or other information is 100% secure. However, we take a number of steps to reasonably safeguard the security of personal information obtained through the Website. Our employees are trained to understand the importance of confidentiality and are required to adhere to our privacy policies and procedures. Please see the “Third Party Payment Processor” section regarding the data security of your financial transaction.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat personal information, we reserve the right to amend this policy at our discretion and at any time. When we make material changes to this policy, we will post the updated policy on the Website and update the policy’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

ISYS Solutions, Inc.

P.O. Box 189

Brea, CA 92822

Email: inquiries@isyscm.com

Phone: 888-992-8100