Updated and Effective Date: January 1st, 2020
OUR COMMITMENT TO PRIVACY
- INFORMATION WE COLLECT
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username, or similar identifiers.
- Contact Data includes billing or shipping address, email address, or telephone number.
- Transaction Data includes details about payments to and from you and other details of services that we have provided to you.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Referral-Worx Website.
- Profile Data includes your username and password, subscriptions made by you, your interests, preferences, or feedback responses.
- Usage Data includes information about how you use the Referral-Worx Website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Referral-Worx Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
Providing Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel the service you have with us, but we will notify you if this is the case at the time.
- HOW WE COLLECT YOUR INFORMATION
- Cookies and Beacons
Most web browsers automatically accept cookies, but you can configure your browser to stop accepting new cookies, to notify you when you a new cookie is received, and to disable existing cookies. If you choose to disable cookies in your browser, however, you may be unable to take full advantage of some or all of the Site’s features.
Third-party services and tools we use may also send you cookies to collect certain information from users which includes Google +, Facebook, Twitter, LinkedIn, WhatsApp and Pinterest, you can review their privacy policies at:
If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs.
To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Please note that if you exercise the choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.
At times, we may present links in a format that allows us to discern whether these links have been followed.
- Log Files
- Information About You That You Provide
When you register with Referral-Worx, we may collect your name, company information and payment information. Some of this information may be viewed by registered users of the Site.
- HOW WE USE YOUR INFORMATION
We will never sell, share, or transfer your information to third parties without your permission.
However, you agree that we may use your information: to enhance or improve our users’ experiences; to understand how you use our Service; to process transactions; to send you email newsletters and respond to inquiries; to provide the Service; to register your account and allow you to use our Service; to promote our products or services and other marketing efforts; to develop and improve our Service and associated technology; to develop new products; to maintain and ensure the viability and integrity of our network; to protect the rights or property of you, Referral-Worx, our users or our partners; and to share with other users.
Data Retention Policies: Length of Time Personal Information is Retained
Referralwx.com retains personal information for as long as necessary to fulfill the business purpose for which you provided it to us and any other legitimate business purpose, including without limitation, for the purposes of satisfying any legal, accounting, or reporting requirements. We may also retain offline archival copies of data for the applicable statutory periods. If you would like more details about our data retention policies, please contact us.
Referralwx.com periodically reviews its collection, storage and processing procedures and policies to ensure that it is in compliance with applicable law.
Third Party Contractors
We employ third party suppliers, contractors and service providers to facilitate our services and may need to share your information with them to provide information, products or services to you. Examples may include processing credit card payments, hosting, supplementing the information you provide us to provide you a better service, or analyzing data. In all cases where we share your information with such agents, we require the agent to acknowledge and adhere to our privacy and customer data handling policies.
- REQUIRED DISCLOSURES
We make every reasonable effort to preserve your privacy, but may need to disclose your PII when required by law or if we have a belief that such action is necessary to:
Referral-Worx, its members, you or others.
We may be required to disclose personal data in response to lawful requests by public authorities including to meet national security and law enforcement requirements.
You authorize us to disclose any information about you to law enforcement or government officials as we, in our sole discretion, believe is necessary or appropriate.
Choices Relating to Use of Personal Information
Referralwx.com will give you choices about the ways we use and share your personal information, and we’ll respect the choices you make. Although signing up for some or all of our services may require you to submit personal information, we will ask for your consent if we intend to use that information for any purpose other than providing you with the services requested or as provided for in this document. You may object, restrict or withdraw consent for us to use your personal information at any time.
You may choose to decline to submit any personal information for any of our products or services. Please note that this may result in our being unable to provide said service, including, without limitation, subscription services, even if time remains for your subscription.
Your Right to Access, Review, Change and Otherwise Control your Personal Data
We acknowledge the EU individual’s right to access their personal data that is stored by Referralwx.com and to ensure that such personal data is accurate and relevant for the purposes for which Referralwx.com collected it. You may control the information you provide to us in various ways. If you would like to change any of your information in our database, you can do so by logging onto your account and following the directions.
If you would like to review your personal data, but you do not have an account or no longer have access to your account, you may contact us at firstname.lastname@example.org. However, where such access is unreasonable, requires a disproportionate effort, jeopardizes the privacy of other referralwx.com users, or contravenes the law, our policies, or reasonable business practice, requests to access data may be declined. User identification is required to access data for these reasons, and the process and procedures for various types of access may differ. Please contact us for further information at email@example.com.
To cancel your account, send an email request to firstname.lastname@example.org from the email address you provided us in your registration. We will generally endeavor to remove your user information once we have received a cancellation request, but we cannot guarantee that your information has been or will be removed immediately. After cancellation of your account, you agree that we may retain non-accessible archival copies of your information for a commercially reasonable amount of time for internal and legal purposes.
Do Not Track Notice.
Your browser may provide you with the option to send a “Do Not Track” signal to websites you visit. This signal is used to request that websites not send the requesting device cookies, but websites have no obligation to respond to such signal or to modify their operation. At the current time, the Site is not programmed to recognize Do Not Track signals, so this Site will not treat you differently if we receive such signals from your browser and we may not comply with Do Not Track settings on your browser.
Notice Concerning Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.
Any person who provides information through the Site represents that they are 18 years of age or older. We do not knowingly collect PII from anyone under the age of 18. Our Site and Service are not designed for users under 18.
Children’s Privacy Protection
Referral-Worx takes special care to protect the privacy needs of children under the age of 13 and encourages parents to be an active participant in their child’s online activities. Referral-Worx abides by the United States Children’s Online Privacy Protection Act (COPPA) and other relevant laws. The website does not target and is not intended for children under the age of 13 and, in fact, is not intended for children under the age of 18. referralwx.com will not knowingly collect personal information from children. If Referral-Worx discovers personal data from a child under the age of 13 gathered through the website, without parental consent, Referral-Worx will eliminate that data.
Can-Spam Compliance Notice
Referralwx.com complies with the Federal CAN-SPAM Act. You may use your account features on the Site to opt-out of notifications, promotional emails and newsletters. You will also have the ability to opt-in in the event that we share your information with other third-party organizations for their marketing or promotional uses or various other programs or features. If you wish to be removed from any communications simply respond to the link provided in the email or email us at email@example.com.
Referralwx.com will comply with your request to obtain a copy of the information you have shared through our services. You have rights to obtain a copy of some of the personal information that we hold on you and reuse or share it for your own purposes (“right to data portability”).
The right to data portability only applies:
- to personal information you have provided to us (i.e. not any other information);
- where we are processing your personal information because you have provided your consent for us to do so, or under a contract with you; and
- when processing is carried out by automated means.
Referralwx.com can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the personal information concerns more than one individual, we may not be able to transfer the information to you if doing so would prejudice the other person’s rights.
- THIRD PARTY WEBSITES
Referral-Worx or others may post links to third party websites on our Site or Service, which may include information that we have no control over. When accessing a third-party site through our Site or Service, you acknowledge that you are aware that these third party websites are not screened for privacy or security issues by us, and you release us from any liability for the conduct of these third party websites.
To protect your privacy and security, we take reasonable steps to verify your identity before granting profile access. You are responsible for maintaining the secrecy of your unique password and account information at all times.
The Site uses SSL certificates to help secure your information. However, as this is the Internet, we make no assurances or guarantees that your information will be safe. For this reason, we recommend you take appropriate measures such as protecting your passwords, using firewalls or downloading anti-virus software. If we learn of a security systems breach, then we may attempt to notify you electronically through our Site or by email so that you can take appropriate protective steps. By using the Site or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site.
EU-U.S. Privacy Shield
Referralwx.com is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Referralwx.com complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Referralwx.com is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, referralwx.com may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Referralwx.com has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Finally, as a last resort and in limited circumstances, EU individuals with unresolved complaints may invoke a binding arbitration option before a Privacy Shield Panel.
Commitment to GDPR
Referralwx.com is committed to complying with the requirements of the GDPR.
NOTICE TO INTERNATIONAL USERS: CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION AND PROCESSING OF INFORMATION IN THE UNITED STATES OF AMERICA
The Site is hosted in the United States. All information that is submitted by you is stored and processed within the US, which may not have the same data protection and privacy laws as your country. For your personal information, you agree to:
Please be aware that your information may also be processed by us in the country where it was collected as well as other countries where laws regarding processing of information may be less stringent than the laws in your country.
- ACQUISITION OR CHANGE OF CONTROL
- PRIVACY NOTICE FOR RESIDENTS OF CERTAIN U.S. STATES
Some U.S. state laws (e.g., California and Nevada) provide state residents with additional privacy rights. Please read to learn more about such state privacy rules and whether they apply to you.
California Privacy Rights
Referralwx.com permits residents of the State of California to use its Services and complies with the California Business and Professions Code §§ 22575-22579.
Under §1798.83 of the California Civil Code, residents of California can obtain certain information from companies with whom they have an established business relationship. That information is about the personal information those companies have shared with third parties for direct marketing purposes during the preceding calendar year. The law requires companies to inform consumers about the categories of personally information shared with third parties, the names and addresses of those third parties, and examples of the services or products marketed by those third parties. To request a copy of the information disclosure provided by referralwx.com under Section 1798.83 of the California Civil Code, please contact us.
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
- Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers);
- Commercial information (such as transaction data);
- Financial data (such as credit card information);
- Internet or other network or device activity (such as browsing history and information on interaction with a website, application, or advertisement);
- Geolocation data (at an IP-based or city/state/zip level);
- Professional or employment-related information (if volunteered in a job application);
- Education information (if volunteered in a job application);
- Inference data about you drawn from the data in this section (based on user profile information and classes taken);
- Legally protected classifications (such as age and gender);
- Physical characteristics or description (if personal photo is volunteered in a user profile); and
Other information that identifies or can be reasonably associated with you (e.g., information you voluntarily provide as you use the Services, such as additional profile information or user-generated content).
The sources from which the categories of personal information are collected. We collect the personal information from the following categories of sources:
- Directly from the information you provide to us;
- Indirectly from our affiliates, service providers, and third parties with whom you have a direct relationship; and
- Indirectly through your interaction with a website, application, or advertisement.
Business purposes for collecting categories of personal information. We collect personal information for the various business purposes below:
- Complete a purchase or provide the Services you have requested, including invoicing and accounting;
- Respond to your request for information and provide you with more effective and efficient customer service;
- Provide you with updates and information about Referral-Worx;
- Contact you by email, postal mail, or phone regarding Referral-Worx and third- party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you;
- Customize the advertising and content you see on the Services;
- Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services;
- Secure our websites and applications, and resolve app crashes and other issues being reported;
- Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others;
- Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others; and
- Consider and process your job application
Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity.
Your California privacy rights.
CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:
- Inform you about the categories of personal information we collect or disclose about you and the categories of sources of such information;
- Provide you with the specific pieces of personal information we collect about you; and
- Delete personal information we have about you.
Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. You may only make such a request twice within a twelve-month period. Requests are generally free; however, we may charge a reasonable fee or deny your request if it is manifestly unfounded, excessive, or repetitive.
The CCPA further provides you with the right to receive information about the financial incentives that we offer to you, if any, and the right not to be discriminated against for exercising your rights under applicable law.
Shine the Light Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
Privacy Information for Nevada Residents
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us at firstname.lastname@example.org. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
- CONTACTING REFERRAL-WORX OR THE APPROPRIATE SUPERVISORY AUTHORITY
Enforcement and Independent Dispute Resolution
For EU residents:
To access your information, ask questions about our privacy practices, or issue a complaint, contact us at:
13119 Moorpark Street, Suite 8
Sherman Oaks, Ca 91423
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. The following is the contact information for the supervisory authorities in each member state: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
For non-EU residents:
To access your information, ask questions about our privacy practices, or issue a complaint, contact us at:
13119 Moorpark Street, Suite 8
Sherman Oaks, Ca 91423
Referralwx.com regularly reviews, self-assesses, and verifies that the attestations and assertions made about our Privacy Shield privacy practices are true and these privacy practices have been implemented as represented and in accordance with the GDPR and/or Privacy Shield Principles. As part of the annual compliance verification process, referralwx.com will follow the steps below in an independent manner:
- Ensure that individuals are informed of any in-house arrangements for handling complaints and of the independent mechanisms through which they may pursue complaints.
- Ensure that referralwx.com has implemented processes and procedures for training our employees in the execution of Privacy Shield policies and the GDPR, including appropriate disciplinary action for failure to follow it.
We undertake not to reduce your rights to privacy as set out in this policy without your consent. If you have any complaints or queries, please do not hesitate to contact us.
Last updated: January 1st, 2020. Effective date: January 1st, 2020.