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Deliberate Online Privacy Policy

Last Updated 02/04/2023

 

INTRODUCTION

Deliberate Solutions, Inc. (“Deliberate,” “we,” “us,” and “our”) understands the importance of your privacy and protecting your personal information.  This Privacy Policy (the “Policy”) describes how Deliberate collects, uses, maintains, protects and shares information about you, as well as how you can access, change, and remove your information.  This applies to information we may collect about you through our website, social media, email and text exchanges, mobile apps, and other online services on which this Policy is posted (collectively referred to in this Policy as the “Site”). It also applies when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.  It does not apply to offline activities and communications or any third-party websites that may be linked from our website.

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Please read this Policy carefully to understand what we do. If you do not understand or agree to any aspects of our Policy, please contact us before using our Site.  If you use our Site, you agree to this Policy. 

 

This Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Policy. To the extent that any translated versions of this Policy conflict with the English language version, the English language version of this Policy controls.

 

CHILDREN’S PRIVACY

Our Site is not intended for children.  If you are under the age of 18, please do not register with us at this Site, engage our Site, or provide any personal information about yourself to us. If we learn that we have collected personal information from someone under 18, we will promptly delete that information. If you believe we have collected personal information from someone under the age of 18, please contact us.

 
COLLECTION OF PERSONAL INFORMATION

We may collect several types of information from and about users of our Site, including:

 

  • Information from which you can be identified, such as name, postal address, e-mail address, telephone number, driver’s license number, and social security number; 

  • Authentication information, including the username, password and date of birth that you use to register an account on the Site; 

  • Financial information, including your bank account number or debit or credit card number, its expiration date, and its security code, for payment processing purposes;

  • Information about your education, employment, employment history;

  • Medical information and health insurance information;

  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;

  • Biometric information;

  • Comments, reviews, and suggestions; 

  • Personal preferences including product preferences, online preferences, and interests; 

  • Online behavior information including online activity, preferences, and time spent viewing features and browsing history and search history; and 

  • IP address, mobile network information, or device information. 

 

Information listed above that identifies you is referred to in this Policy as “Personal Information.”  Personal Information does not include information that is publicly available. 

 

We collect this information in different ways:

 

  • Information you provide to us:  We collect information you provide to us when you create or modify your account; register to use our Site; purchase products or services from us; post comments or reviews on our Site; request information from us; contact customer support; or otherwise communicate with us.

  • Information we obtain from third parties: We may receive certain information about you through our business partners.

  • Information we collect automatically:  When you use our Site, we collect certain information about you automatically through our use of cookies and similar technologies.  These are described in more detail below in the section on cookies and other technologies.  

 

Deliberate only collects and processes the minimum amount of Personal Information from you that is necessary for purposes of our information processing activities. 

 

HIPAA

Some of the information we collect about you is protected by the Health Insurance Portability and Accountability Act (“HIPAA”).  Deliberate provides services to health care providers that are subject to HIPAA.  For example, Deliberate administers patient surveys on behalf of health care providers.  The protected health information (PHI) that Deliberate receives from or collects on behalf of your health care providers has special protections that are described in your health care providers’ HIPAA Notice of Privacy Practices.  Deliberate’s use and disclosure of your PHI is governed by our HIPAA “business associate agreement” with your health care providers.

 

USE OF PERSONAL INFORMATION

Deliberate uses and retains information we collect about you or that you provide to us, including any Personal Information, for the following information processing activities:

  • To present our Site and its contents to you, and to improve the Site and its contents;

  • For user verification;

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

  • To improve the information, products, and services we provide;

  • For customer communications and support;

  • To provide you with notices about your account, including expiration and renewal notices;

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

  • For our compliance with legal requirements;

  • To notify you about changes to our Site or any products or services we offer or provide though it;

  • Advertising –see section on use for advertising below;

  • To otherwise conduct our business;

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

  • For any other purpose with your consent.

 

DISCLOSURE OF PERSONAL INFORMATION  

  • No Sale of Personal Information:  Deliberate does not trade, rent, or sell your Personal Information to third parties.

  • Vendors and Services Providers: We may provide your information to third party vendors and service providers that perform services and functions on our behalf to help us operate and manage our Site and to provide products and services that you may purchase from us. These vendors and service providers will have access to your Personal Information to provide these services.  We implement reasonable contractual and technical protections to their use of that information.

  • Legal Disclosure: We will share Personal Information with third party companies, organizations, or individuals outside of Deliberate when we believe in good faith that it is reasonably necessary to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our agreements, terms of use, or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of Deliberate, third parties, visitors to our Site, or the public, as required or permitted by law.

  • Transfer in the Event of Sale or Change of Control: If the ownership our business changes, or if we transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding, or otherwise, we may transfer Personal Information to the new owner. In such a case, unless prohibited by applicable law, your Personal Information would remain subject to the privacy policy applicable at the time of such transfer, unless you discontinue use of our Site. 

  • To Fulfill an Intended Purposes:  We will share your Personal Information to fulfill the purpose for which you provided it.

  • With Your Consent: In addition to the sharing described elsewhere in this Policy, we may share Personal Information with companies, organizations, or individuals outside of Deliberate when we have your consent to do so.

 

COOKIES AND OTHER TECHNOLOGIES

We and our service providers use cookies, web beacons, and other technologies (collectively, “cookies”) to receive and store certain types of information whenever you interact with our Site through your computer or mobile device to improve the quality of our services, including for storing user preferences, tracking user trends, and providing relevant advertising to you. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site again, the cookie allows the Site to recognize your browser. Cookies may store unique identifiers, user preferences, and other information. Cookies can be set by Deliberate or they can be set by third parties (e.g., Facebook, Google, etc.) Third party cookies may also be used to enable analytics (e.g. Google Analytics) or advertising functionality (e.g., ad re-targeting on third-party websites) that enables more customized services and advertising by tracking your interaction with our Site and collecting information about how you use the Site.

 

The information we collect through cookies does not include Personal Information, but we may maintain the information collected and associate it with Personal Information we collect in other ways. This helps us to improve our Site by enabling us to do things like estimate our audience size and usage patterns; store information about your preferences, to customize our Site according to your individual interests; speed up your searches; and recognize you when you return to our Site.

 

You can reset your browser to refuse all cookies or to alert you when a cookie is being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website However, some Site features or services may not function properly without cookies. Please keep in mind that your browser settings may not permit you to control the technologies utilized by third-party companies. If you would like more information about these practices, please click: http://optout.aboutads.info/#!/

 

Deliberate may use Google Analytics. Google Analytics is a web analytics service provided by Google, Inc. to collect certain information relating to your use of the Site. Google Analytics uses cookies to help the Site analyze user activity. We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity.

 

Deliberate may also use Hotjar. Hotjar is a technology service that helps us better understand our users' needs and optimize user experience. Hotjar allows us to determine how much time users spend on which pages, which links users choose to click, and what users do and do not like, among other things.  Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices. This includes a device's IP address, which is processed during your session and stored in a de-identified form; device screen size; device type (unique device identifiers); browser information; geographic location (country only); and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile.

 

ADVERTISING

We may use information about how you browse in order to show you ads for Deliberate or our advertising partners that are relevant to your interests.  These interest-based ads are ads are tailored to your interests and are based on your browsing behavior.  We may use cookies and other information to provide relevant interest-based ads to you, and ad networks to which we belong may use your browsing activity across participating websites to show you interest-based ads on those websites. These interest-based ads may be presented to you while you are browsing our Site or third-party sites not owned by Deliberate.

 

Currently, our Site does not recognize if your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads. If you would like more information about these practices, please click: http://optout.aboutads.info/#!/

 

YOUR RIGHTS RELATED TO YOUR INFORMATION 

In compliance with California and other state laws, we provide individuals with certain information and access upon request (a “Consumer Request”). If you would like to submit a Consumer Request, you or your authorized agent can contact Deliberate at contact us.  

 

If you submit a Consumer Request, you must provide us with enough information to identify you and specifics about your request.  To verify your identity, we will request your name, Account username, and date of birth.  If you have an authorized agent submit a Consumer Request on your behalf, we will ask for that same information, plus we will ask you to verify that the agent has been authorized by you. Deliberate will not be able to disclose information if Deliberate cannot verify that the person making the Consumer Request is the person about whom we collected information, or that the person making the Consumer Request is someone authorized to act on such person’s behalf. 

 

Request to Access. You may submit a Consumer Request to obtain a copy of or access to the Personal Information that Deliberate has collected about you.

 

Request to Correct Inaccurate Personal Information. You may submit a Consumer Request to correct inaccurate Personal Information. Deliberate will use commercially reasonable efforts to comply with such request and correct inaccurate personal information.  We may not be able to accommodate a request to change your information if we believe the change would violate any law or legal requirement or cause the information to be inaccurate. 

 

Request to Know. You may submit a Consumer Request to receive information about Deliberate’ data collection practices. You may request information on the categories of Personal Information Deliberate has collected about you; the categories of data collection sources; the specific pieces of Personal Information we have collected about you. Deliberate’ business or commercial purpose for collecting, using, or selling that Personal Information; the categories of Personal Information that Deliberate has shared; and the categories of third parties with whom Deliberate shares Personal Information.

 

Deliberate is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. Deliberate is also not required to re-identify Personal Information if it is not stored in that manner already, nor is it required to provide the Personal Information to you more than twice in a twelve-month period.

 

If you would like to know if Deliberate has disclosed information about you to specific third parties, you may also contact us to receive information about the categories of information that we disclosed to third parties for their direct marketing purposes. You may receive the names and addresses of those third parties, and you may request this information for the year before your request. Note that these requests may only be made once per calendar year. 

 

Request to Delete. You may request that Deliberate delete your Personal Information. Subject to certain exceptions set out below we will, on receipt of a verifiable Consumer Request, delete your Personal Information from our records and direct any service providers to do the same. We will also notify all third parties with whom Deliberate has shared your Personal Information of your request to delete your Personal Information.

 

Please note that we may not delete your Personal Information if it is necessary to:

  • complete the transaction for which the Personal Information was collected; 

  • provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; 

  • detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk;

  • debug and repair internal information technology as necessary;

  • undertake internal research for technological development and demonstration;

  • 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 and other similar state and federal laws;

  • engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

  • enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

  • comply with an existing legal obligation; or

  • otherwise internally use your Personal Information in a lawful manner that is compatible with the reason for which you provided the Personal Information.

 

YOUR CHOICES

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:

 

  • Cookies and Other Technologies.  For more information on how to disable cookies and other technologies, see the section on cookies and other technologies.

 

  • Promotional Offers from Deliberate. If you do not wish to have your contact information used by Deliberate to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form).  You can also opt-out after registration by logging into the Site and adjusting your user preferences in your account profile or you can contact us.  If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. 

 

  • Targeted Advertising. If you do not want us to internally use your Personal Information to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form). You can also opt-out after registration by logging into the Site and adjusting your user preferences in your account profile or you can contact us. 

 

  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form). You can also opt-out after registration by logging into the Site and adjusting your user preferences in your account profile or you can contact us.

 

  • Social Media Account Sign On: To the extent that you choose to use a social media account application (such as Google, Facebook, or Apple) to create your online account on the Site or to otherwise sign into the Site, you understand that if another person has access to your social media account, they will also have access to your account on the Site. That means that other person could access any Personal Information contained on the Site. It’s your decision about whether to give another person access to your social media account and whether to use that account to sign on to the Site. Also, if you use a social media account application to sign into the Site, you understand that the social media account application may send information from your social media account to Deliberate.

 

Deliberate may not, and will not, treat you differently because of your Consumer Request or for any of the choices you make. Deliberate may not and will not deny goods or services to you; charge different rates for goods or services; or provide a different level quality of goods or services. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your Personal Information.  Some Site functionality and features may change or become unavailable upon deletion or restriction on use of your Personal Information.

 

SECURITY OF YOUR INFORMATION

We use industry standard physical, technical, and administrative security measures and safeguards to protect the confidentiality and security of your personal information. While we take reasonable security measures to protect your Personal Information, we cannot guarantee the security of your Personal Information. Deliberate cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your Personal Information. Accordingly, it is your responsibility to protect the security of your login information, including your username and password. Additionally, please note that emails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

 

LINKED SITES

The Site may contain links to third-party owned or operated websites, including, without limitation, social media websites (each a “Linked Site”), as a convenient method of accessing information that may be useful or of interest to you. This Policy and the practices that we follow under this Policy do not apply to Linked Sites. We are not responsible for the content, accuracy, or opinions expressed on any Linked Site or for the privacy practices or security standards used by third parties on such Linked Sites. These Linked Sites have separate privacy and data collection practices, and we have no responsibility or liability relating to them.

 

Accordingly, if you use Linked Sites through our Site, to login to our Site, or to share information about your experience on our Site with others, these Linked Sites may be able to collect information about you, including information about your activity on our Site. In accordance with their own privacy policies, the Linked Sites may further notify your social media connections about your use of our Site.

 

You understand and agree that by clicking on a link to a Linked Site or using a Linked Site as described above, this Policy, as stated on the Site, is no longer in effect because you have either left our Site or used a Linked Site to interact with our Site.

 

USER CONTENT

Some features of the Site may now or in the future allow you to provide content, such as written comments or reviews, to be published or displayed on public areas of the Site (“User Content”). Be careful about giving out information in public areas of the Site. The information you share in public areas may be read, collected, or used by any user of the Site. We cannot control the actions of other users of the Site with whom you may choose to share your User Content.

 

CONSENT TO PROCESSING OF PERSONAL DATA IN UNITED STATES

This Site is intended for use only by residents of the United States. If you are a citizen of the European Economic Area (EEA) or other jurisdiction outside of the U.S., please note that in order to provide our Site, products, and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the U.S. Accordingly, your Personal Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

 

CHANGES TO OUR PRIVACY POLICY

This Policy may change from time to time.  We will post any changes to the Policy on this page.  Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

 

QUESTIONS AND HOW TO CONTACT US

If you have any questions, concerns, complaints, or suggestions regarding this Policy, please contact Deliberate at:

 

Tel: (213) 510-6031

Email: contact@deliberate.ai

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