INFORMATION WE COLLECT
We collect information from you when you:
- use the Site,
- create an Account,
- change the contact information or other credentials associated with an Account,
- download and/or purchase any ServiceXRG Content or other content,
- register for a Service,
- pay a Service Fee,
- use a Service,
- submit a Site Form,
- apply for a position or submit your resume to ServiceXRG,
- participate in surveys and evaluations,
- request information or materials, and
- contact ServiceXRG by any means.
The information we collect may include Personal Information. “Personal Information” is data that reasonably can be used to identify or describe an individual. Personal Information includes, but is not limited to:
- your first and last name,
- your home, billing, work, or other physical address (including street name, city/town, state/province, postal code, and country),
- your e-mail address,
- your telephone number,
- your IP address,
- any other identifier that permits us to make physical or online contact with you, and
- (if you pay a Service Fee) your financial information, including credit card account information.
HOW WE USE YOUR PERSONAL INFORMATION
We also use your Personal Information to communicate with you. We may send certain mandatory service communications such as welcome letters, billing information, information on technical service issues, and security announcements. We may also contact you to inform you of industry events and activities, promotional materials, and other products or services available from ServiceXRG.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about you, and information that does not personally identify you. We do not share Personal Information you provide to us through the Site with any third party for any reason except:
- To contractors, service providers, and other third parties to support our business and who are bound by contractual or other legal obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
- Vendors engaged by ServiceXRG to provide services on behalf of ServiceXRG, such as marketing services, email services, shipping services, content management, data storage, payment processing, customer satisfaction assessment, and research services.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
We may access or disclose your Personal Information if we believe such action is necessary to: (a) comply with the law or legal process served on ServiceXRG; (b) protect and defend the rights or property of ServiceXRG (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety of users of Services or members of the public.
ServiceXRG retains Personal Information for as long as we have a legitimate business relationship with you or with an organization with which you are affiliated (such as your employer). We may also retain Personal Information about prospective customers or prospective employees until we determine that it is unlikely that we will provide you with services and/or employ you. We also may retain your Personal Information for as long as necessary to comply with our legal, regulatory, compliance, or contractual obligations.
YOUR RIGHTS TO OPTOUT
If you do not want to receive promotional or marketing communications from ServiceXRG, you may opt-out at any time by clicking the “unsubscribe” link at the end of our emails or surveys. If you choose to unsubscribe, we will retain your contact information to ensure that we do not contact you again.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We have adopted reasonable data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information, transaction information and data stored on the Site. When you transmit sensitive information, such as credit card information, to us through the Site, we may provide you access to a third party server that allows encryption across the Internet. Browsers offer varying degrees of security, particularly in regard to encryption. Even the same version of a browser can come with different levels of encryption. For your protection, make sure your browser is set and configured to support Secure Socket Layer (SSL) 2.0/3.0 and employs 128-bit encryption. All acceptable browsers do provide detailed information on security levels in “Properties” or “Document Information” from the browser’s menu bar. See your browser’s “Help” tab or documentation for more information.
Despite our efforts to protect your Personal Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted, and you acknowledge these inherent risks before using the Site.
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 the Site, 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 Site.
ServiceXRG uses several security technologies and procedures to ensure your Personal Information is protected from unauthorized access, use, or disclosure. However, we cannot guarantee that third parties will not overcome these measures and gain access to your information. To the fullest extent permitted by law, ServiceXRG does not make any representations, warranties or guarantee that your information will be protected from misuse, appropriation, alteration, or loss.
LINKS TO EXTERNAL WEBSITES
THE SITE AND SERVICES ARE INTENDED FOR ADULTS. WE DO NOT KNOWINGLY OR INTENTIONALLY COLLECT PERSONAL INFORMATION FROM ANYONE UNDER THE AGE OF 18. IF YOU ARE UNDER THE AGE OF 18, PLEASE DO NOT PROVIDE ANY PERSONAL INFORMATION TO US. IF YOU KNOW OF ANYONE UNDER THE AGE OF 18 WHO HAS PROVIDED US WITH INFORMATION, PLEASE CONTACT US IMMEDIATELY AND WE WILL REMOVE THE INFORMATION.
With or without cookies, our web site keeps track of usage data, such as the source address from which a page request originates (i.e., your IP address, domain name), date and time of the page request, the referring web site (if any), and other parameters in the URL (e.g., search criteria). We use this data to better understand web site usage in the aggregate so that we know what areas of our web site users prefer (e.g., based on the number of visits to those areas). This information is stored in log files and is used for aggregated and statistical reporting. It is not attributed to you as an individual.
SPECIFIC PROVISIONS FOR CALIFORNIA RESIDENTS
California Notice of Collection
In the past twelve (12) months, we or our service providers have collected the following categories of information enumerated in the CCPA in connection with the Site:
- First and last name, home, billing or other physical address (including street name, city/town, state/province, postal code, and country of origin), e-mail address, and telephone number, to the extent you are interacting with our Site;
- Information, services and products considered, accepted, rejected and other use data;
- Any other identifier that permits ServiceXRG to make physical or online contact with you;
- Internet activity, including history of visiting and interacting with the Site, browser type, browser language and other information collected automatically; and
- Any other information you have chosen to provide to us through the Site.
ServiceXRG does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA would be interpreted to include any of the activities described in the “DISCLOSURE OF YOUR INFORMATION” section, we will comply with applicable law as to such activity.
Right to Know and Delete
If you are a California resident, you have the right to delete Personal Information we have collected about you and you have the right to know certain information about our data practices in the preceding twelve (12) months. In particular, you have the right to request the following:
- Categories of Personal Information we have collected about you;
- Categories of sources from which the Personal Information was collected;
- Categories of Personal Information about you we disclosed for a business purpose or sold;
- Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose;
- Business or commercial purpose for collecting or selling the Personal Information; and
- Specific pieces of Personal Information we have collected about you.
To exercise any of these rights, please submit a request to us at email@example.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process your request. Please note that, in many instances, ServiceXRG does not collect types of information that enable us to identify you. As such, if we do not have information that permits us to verify your identity, we may deny your requests to know or delete. A request for access can be made by you only twice within a twelve (12) month period.
Right to Opt Out
Under the CCPA, you have the right to opt out of the sale of your Personal Information to third parties at any time. ServiceXRG does not “sell” your Personal Information as it is currently defined under the CCPA. You may contact us by emailing us at firstname.lastname@example.org if you have any questions or concerns.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
Right to Non-Discrimination
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
California Do-Not-Track Notice
We do not track our Site users over time and across third party websites and therefore do not respond to Do Not Track (DNT) signals.
NOTICE TO INTERNATIONAL RESIDENTS
The Site is primarily operated and managed on servers located and operated within the United States. In order to use our Site or Services, including but not limited to submit a Site Form or purchase or register to use the Services, you may be sending your Personal Information outside of your country of residence, including to the United States. Accordingly, if you reside outside of the United States, your Personal Information may be transferred outside of your country of residence, including to countries that may not or do not provide the same level of protection for your Personal Information. We are committed to protecting the privacy and confidentiality of Personal Information when it is transferred.
ADDITIONAL INFORMATION FOR USERS IN THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM
ServiceXRG is established in the United States and has operations and service providers in the United States and throughout the world. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide levels of data protection equivalent to those in your country of residence. By using our Site or Services, or otherwise interacting with us, regardless of where you live or where you provide information to us, you consent to our use and our service providers’ use of your Personal Information worldwide and to the transfer of your Personal Information to countries outside of your country of residence, including the United States. In certain circumstances, courts, regulatory agencies, law enforcement agencies, or security authorities in those other countries may be entitled to access your Personal Information.
ServiceXRG is aware of the July 16, 2020 ruling by the European Court of Justice invalidating the EU-US Privacy Shield Framework. Accordingly, ServiceXRG will take adequate measures designed to protect the transfer of Personal Information of individuals in the European Economic Area (EU Member States, Iceland, Liechtenstein and Norway) (“EEA”), such as relying on the European Commission-approved Standard Contractual Clauses (“EU SCCs”) as a legal mechanism for such transfer, or other adequate transfer mechanism as required under relevant data protection laws, as well as additional safeguards, where appropriate. A copy of these clauses may be obtained by contacting us at the email address listed below.
For transfers to or from the United Kingdom (“UK”), we make use of the EU SCCs, as modified by the UK’s International Data Transfer Addendum (collectively, the “UK SCCs”). For individuals located in the EEA or the UK, the term “Personal Information,” as used in this section, is equivalent to “personal data” under applicable European and UK data protection legislation.
If you are located in the EEA, the UK, or Switzerland, you have certain rights and protections under applicable law regarding the processing of your Personal Information, as defined by the General Data Protection Regulation (“GDPR”), and this section applies to you.
Legal Basis for Processing
When we process your Personal Information, we will do so in reliance on the following lawful bases:
- To perform our responsibilities under our contract with you (e.g., providing the services you requested).
- When we have a legitimate interest in processing your Personal Information to operate our business or protect our interests (e.g., to provide, maintain, and improve our Services, conduct data analytics, and communicate with you).
- To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of non-administrative communications).
- When we have your consent to do so (e.g., when you opt in to receive non-administrative communications from us). When consent is the legal basis for our processing your Personal Information, you may withdraw such consent at any time.
We store Personal Information associated with your Account for as long as your account remains active. , unless reasonably necessary to comply with our legal, regulatory, or other compliance obligations. We store other data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
For users in the European Union and UK, you have the following statutory rights:
- Access. You have the right to obtain confirmation as to whether or not Personal Information concerning you is being processed, and, where that is the case, all necessary information to make the process transparent. You also have the right to obtain a copy of your Personal Information being processed.
- Rectification. You have the right to require rectification of inaccurate data about you.
- Erasure. You have the right to ask for the deletion of your data in certain circumstances.
- Restrict processing. You have the right to restrict processing of data under certain specified circumstances.
- Data portability. You have the right to request for the receipt or the transfer to another organization, in a machine-readable form, of your Personal Information.
- Object to processing. You have the right to ask us to stop using all or some of your Personal Information under certain specified circumstances.
- Right to withdraw consent. When you have given your explicit consent for the processing of your data, you can withdraw it at any time without justification. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
If would like to exercise your rights, please let us know by sending an email to email@example.com.
You also have the right to lodge a complaint with your local Data Protection Authority or to the Data Protection Authority where an alleged infringement took place.
If you have additional questions about how we handle your Personal Information, please contact us at firstname.lastname@example.org or call (800) 475-0089 or by mail at: Service Excellence Research Group, LLC, Northwoods Road, Groton Massachusetts 01450.