Privacy Policy

Last updated:
Jan 31, 2024
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AspireIQ, Inc., as well as any present or future affiliated or related company (“AspireIQ” or “we”), recognizes the importance of your privacy. This privacy policy tells you what personal information we collect, how we use it, and what controls we have over it. AspireIQ may change this privacy policy from time to time, in its sole discretion, as discussed in section 8 below. By registering an account with us (“Account”) or otherwise using or visiting any AspireIQ website, application, product, software, tool, data feed, and/or service (collectively, the “Service”), you understand and agree to the terms of this policy. Please read this policy carefully.

1. What Information Do We Collect?

a. Personally-Identifiable Information: We may collect personally identifiable information – that is, information which can either directly or indirectly identify a person – when you specifically and knowingly provide it to us, for example when you register an request a demo or register and provide personal information such as your e-mail address, name, phone number, year of birth, or other information. Where applicable, personally identifiable information includes “personal data”, “personal information” and/or “sensitive personal information” each as defined in applicable law. We ask that you not send us, and you do not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through Services or otherwise. If you do send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive personal data in accordance with this policy.

This policy does not apply to the privacy practices of third parties that we do not own or control, including but not limited to any third party websites, services, applications, online resources to which the Service may link or otherwise reference (collectively “Third Party Services” or “TPS”) that you may access through the Services. For example, the Services utilize the YouTube API Services as a TPS, and you are agreeing to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms), Privacy Policy ( http://www.google.com/policies/privacy), and API Services Terms of Service (https://developers.google.com/youtube/terms/api-services-terms-of-service) when engaging YouTube content and services through the Service. Our use of information received from Gmail APIs will adhere to Google’s Limited Use Requirements (https://developers.google.com/terms/api-services-user-data-policy). We take no responsibility for the content or privacy practices of any TPS. We encourage you to carefully review the privacy policies of any TPS you access.

You may have the option to register an Account with us using a TPS, and you may connect your Account to a TPS such as Instagram, Facebook, Twitter or YouTube. By authorizing us to access your TPS account, you authorize us to obtain certain information from your TPS account, which may including your name, email address, birthday, work history, education history, current city, shared media, and the names, profile pictures, relationship status, and current cities of your TPS contacts. We only obtain information from your TPS account that you specifically authorize and grant us permission to obtain. Our use of information received via Google Restricted Scopes, such as from Gmail APIs, will adhere to Google’s Limited Use Requirements (https://developers.google.com/terms/api-services-user-data-policy)

AspireIQ does not consider personally identifiable information to include information that has been anonymized so that it does not allow a third party to identify a specific individual or household. We collect and use your personally-identifiable information to: provide the Services; operate and improve our Service; provide customer service; perform research and analysis aimed at improving our products, Service and technology; and display content that is customized to your interests and preferences.

You may always choose not to provide personally identifiable information, but if you so choose, certain parts of the Service may not be available to you. If you have registered an Account with us, you will have agreed to provide your personally identifiable information in order to access the Services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Services.

b. Non-Personally-Identifiable Information: We may collect and aggregate non-personally identifiable information which is information which does not permit you to be identified or identifiable either by itself or in combination with other information available to a third party. This information may include information such as a website that referred you to us, your hardware types, geographic location, log data, and access times and durations. We also may collect navigational information, including information about the Service content or pages you view, the links you click, and other actions taken in connection with the Service. We use this information to analyze usage patterns as part of making improvements to the Service.

c. Cookies, Pixels and Local Storage: We may collect information using “cookies”, which are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience when using the Services.

i. Cookies we use

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits any site or application that is party of the Services; and (2) third party cookies, which are served by service providers on sites or applications and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

  • Essential Cookies: These cookies are essential to provide you with services available through the Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of the sites or applications and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
  • Functionality Cookies: These cookies allow the Services to remember choices you make when you use a site or application, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of your Account, or preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Services.
  • Analytics and Performance Cookies: These cookies are used to collect information about traffic to the Services and how users use the Services. The information gathered does not identify any individual user. The information is aggregated and anonymous. It includes the number of users to, the websites that referred them, the pages visited, what time of day they visited, whether they have visited before, and other similar information. We use this information to help operate the Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how the Services work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of the Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
  • Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on any site or application for the Services or you link your Account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

ii. Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you use the Services

iii Pixel Tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on the Services to track the actions of users on our sites and applications. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

iv. Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

2. What Do We Do With The Information That We Collect?

We process personal data based on the consent you provide by accepting this privacy policy under applicable law, which you are free to give or refuse. You can change your decisions at anytime. If you change your decision it will not affect the lawfulness of processing based on consent before its withdrawal.

Except as disclosed in this policy, AspireIQ does not share or sell your personal information to any outside parties.

a. AspireIQ will use the personally identifiable information directly provided by you solely for the purpose for which you have provided it, which may include:

  • to operate, maintain, and improve the Services;
  • to manage your Account, including to communicate with you regarding your Account;
  • to operate and administer any promotions you participate in on any site or application;
  • to respond to your comments and questions and to provide customer service;
  • to send information including technical notices, updates, security alerts, and support and administrative messages;
  • with your consent, to send you marketing e-mails about our about products and services. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your Account with us (if you have one) and our business dealings with you;
  • with your consent, to send you text messages about our products and services. If you do not wish to receive marketing texts, you may adjust your “Personal Information Preferences” as described below or follow the “unsubscribe” or “stop” instructions included within each text communication.
  • to process payments you make via the Services; and
  • as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce this Policy or our Terms, enforce agreements, or resolve disputes between users; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

We may share this information with service providers who perform services on our behalf either within or outside of the United States, such as those services listed above, or other services like processing information requests, providing security services, displaying stored data you access, to assist us in marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need to provide the service they provide, will be required to maintain the confidentiality of the information, and will be prohibited from using it for any other purpose.

We will only retain your personally identifiable information as long as reasonably required to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes). Data collected via the YouTube API will be retained for a maximum of 30 days unless required to provide you with the Services or a longer retention period is required by law.

You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) our collection of sensitive personal data; (iii) any new processing of your personal data that we may carry out beyond the original purpose; or (iv) the transfer of your personal data outside the European Economia Area (if it originates from the EEA). Please note that your use of some of the Services may be ineffective upon opt-out.

b. Disclosure: As a general rule, AspireIQ will not disclose any of your personally identifiable information except under one of the following circumstances: we have your permission, including the permission granted by your acceptance of this policy; we determine in good faith that it is legally required to be revealed by any relevant statute, regulation, ordinance, rule, administrative or court order, decree, or subpoena; it is information that we determine must be disclosed to correct what we believe to be false or misleading information or to address activities that we believe to be manipulative, deceptive or otherwise a violation of law; where you are otherwise notified at the time we collect the data; where we need to share your information to provide the product or service you have requested; when such disclosure is made subject to confidentiality restrictions in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by AspireIQ. AspireIQ may share the non-personally identifiable information that AspireIQ gathers, in aggregate form only, with advertisers and other partners.

3. Your Rights

Consistent with applicable law (including, for EU Data Subjects, Regulation (EU) 2016/679 know as the General Data Protection Regulation), you may exercise any of the rights described in this section. See here for information on personal data rights requests and how to submit a request. Please note that we may ask you to verify your identity and request before taking action on your request.

a. Managing Your Information. If you have an Account, you may access and update some of your information through your Account settings. If you have connected your Account to a TPS you can change your settings and remove permission for the TPS app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

b. Rectification of Inaccurate or Incomplete Information. You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Account, if any).

c. Data Access and Portability. In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

d. Data Retention and Erasure. We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:

  • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Account for fraud or safety reasons, we may retain certain information from that Account to prevent that user from opening a new Account in the future.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, for tax, legal reporting and auditing obligations.
  • Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on or through the Service, even after your Account is canceled. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
  • Because we maintain the Service to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

e. Withdrawing Consent and Restriction of Processing. If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to the next section and pending the verification whether our legitimate grounds override your own.

f. Objection to Processing. In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@aspireiq.com.

g. Additional Data Access Revocation Rights.  In addition to the foregoing Google users may be permitted to adjust their account settings to no longer allow access to their Google account data.  Information regarding account setting and management with regard to data access may be found at: https://myaccount.google.com/permissions?pli=1

h. Lodging Complaints. You have the right to lodge complaints about our data processing activities by filing a complaint with us via the “Contact Us” section below or with a supervisory authority.

4. Children’s Policy.

The Terms of Service clearly provide that Users must be (i) 18 or older, or (ii) 13 and older if either (a) an emancipated minor, or (b) he/she possess legal parental or guardian consent. AspireIQ does not knowingly collect personally identifiable information from users under 13. In the event that we learn that we have collected any personal information from a user under the age of 13, we will attempt to identify and delete that information from our database.

5. International Usage.

The Service is owned by AspireIQ and may be accessed from anywhere that Internet access is not restricted. Information collected may be retained, and may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction. If you are located outside of the United States, please note that the information you provide to us may be transferred to the United States and from the United States on to our sub-processors in other countries. By using the Service, application and/or website, you consent to such transfers. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Policy.

6. California Privacy Rights

California law permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” section below for where to send such requests.

7. Security and Encryption

We follow generally accepted industry standards to help protect your personal information. No method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while we endeavor to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that we collect online, we cannot guarantee its absolute security. Our Service has security measures in place designed to protect against the loss, misuse and alteration of the information under our control. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All Service information is maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords. You are responsible to keep your password secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Account you might have with us has been compromised), please immediately notify us of the problem by contacting us at help@aspireiq.com.

8. Changes to This Policy

We reserve the right to change the terms of this privacy policy at any time. When we make changes, we will revise the “last updated” date at the top of the policy. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. We encourage you to review this policy whenever you visit one of our websites or applications.

9. Contact Us

For general inquiries or to lodge a complaint, email us at help@aspireiq.com, or by mail to AspireIQ Inquiries, 701 Tillery Street #12 #148, Austin, TX 78702.

To opt-out of use of your data for direct marketing, email us at opt-out@aspireiq.com.

To deactivate your Account, go to your Account, click Settings, and then click Deactivate my Account.

Deactivating an Account and an Account deletion request are two different things. When you choose to deactivate your Account, you can reactivate it at a later date if you wish; when you delete your Account, no deleted information can thereafter be recovered. You can request permanent deletion of your personal data and closure of your Account at any point by submitting a deletion request to help@aspireiq.com. We may ask you to verify your identity before taking action on your request. Please include the subject line “Personal Data Right Request – Deletion Request”, and your country of residence.

To access your data, you can visit the Dashboard of your Account. If you would like to get a copy of some or all of the personal data we hold about you pursuant to applicable law, you can send us an email to help@aspireiq.com. Please note that we may ask you to verify your identity before taking further action on your request. Please include the subject line “Personal Data Right Request – Access Request”, provide us your country of residence, and provide as much information as you have regarding the data you would like a copy of.

To exercise a right to portability under applicable law, please email us at help@aspireiq.com and include the subject line “Personal Data Right Request – Portability Request” and your country of residence.

To object to our processing of some of your personal data where allowed under the laws of the jurisdiction where you reside, you may request that we not process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise, or defense of legal claims. You may exercise your rights to object to processing by sending us an email to help@aspireiq.com. Please include the subject line “Personal Data Right Request – Processing Objection” and your country of residence.

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PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT AND THE CALIFORNIA PRIVACY RIGHTS ACT

Effective date: June 30, 2023

Last Revised on: January 31, 2024

 

This Privacy Notice for California residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act (CPRA) and any implementing regulations adopted by the California Privacy Protection Agency (CPRA as amended by the CPRA, and any implementing regulations are collectively referred to as "California Privacy Laws"). Capitalized terms not defined herein shall have the same meaning as the California Privacy Laws when used in this California Privacy Policy.

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1. Categories of Information We Collect

We currently collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, we have collected the following categories of personal information from our consumers in the preceding 12 months:

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2. Business purposes for which we may use or disclose your personal information

We use the categories of personal information listed above to provide our products and services to you, to operate, manage, and maintain our business, and to accomplish the following business and commercial purposes, including the following:

  • To fulfill or meet the reason for which the information is provided.
  • To provide you with information, products or services that you request from us directly or indirectly;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing;
  • To provide customer service, maintain and servicing accounts, verifying customer information, processing payments, providing analytic services, or providing similar services on behalf of the business;
  • To improve our website and present its contents to you;
  • To establish and maintain your user account with us;
  • To authenticate you;
  • For short-term, transient use including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business;
  • To detect fraud and prevent loss, or as necessary or appropriate to protect the rights, property, or safety of us, our users and customers, or others;
  • To debug, to identify and repair errors that impair existing intended functionality;
  • To allow you to contact us and facilitate your communication with us;
  • To respond to your feedback, requests, questions, or inquiries;
  • To provide offers to eligible users or customers;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • 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 is among the assets transferred.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA and the CPRA.

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.

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3. Under this Privacy Policy, personal information does not include:

  • Publicly available information, including from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the scope of the CPRA including, but not limited to information covered by certain sector-specific privacy laws, including but not limited to Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;  the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

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4. We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete on our website.
  • Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.
  • From social media websites that you use to log in or subscribe.

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5. Sharing Personal Information

5.1. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

  • We share your personal information for a business purpose with the following categories of third parties:
  • Affiliates and subsidiaries,
  • Services providers,
  • Payment processors (e.g. Stripe) for the purposes of facilitating a payment
  • Google Analytics for website metrics,
  • Amazon Web Services. Our website is hosted on AWS,
  • Customer brands,

5.2. Sales of Personal Information in the preceding twelve (12) months - we had not sold personal information in the preceding twelve (12) months.

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6. Your California Consumer Rights

The California Privacy Laws provide California residents with specific rights regarding their personal information. You may submit these requests to us as described below, and we honor these rights where they apply.

(1) Right to know. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. 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 or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

(2) Right to delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions, listed in Sec. 7 below. 

(3) Right to Opt-Out of Sale/ Sharing. You have the right to direct a business that sells or shares personal information about you to third parties to stop doing so. We do not sell or share any personal information for commercial purposes as defined by the CPRA. Therefore, we include this disclosure of information for informational purposes only.

 (4) Right to Non-Discrimination. We will not discriminate against you, in terms of price or services that we offer, if you submit one of the rights requests listed above.

 (5) Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you. Our goal is to keep your personal information accurate, current, and complete.

(6) Right to Limit. In limited circumstances, a Consumer has the right to limit the use and disclosure of Sensitive Personal Information. Our use of your Sensitive Personal Information is solely for Business Purposes, and not for those purposes for which a Consumer may exercise right to limit the use or disclosure under the California Privacy Laws. Therefore, we include this disclosure for informational purposes only.

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7. Exercising your California consumer rights

7.1. Request Submission. To exercise your California privacy rights, you need to submit a verifiable consumer request to know, request to delete, or request to correct to us by sending us a message to our customer service to help@aspireiq.com. Only you, or a person registered with the California Secretary of State that you authorize 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.

7.2 Response Process. Upon receiving a request to know, request to delete, or request to correct, we will confirm receipt of the request within ten (10) business days and provide information about how we will process your request. The information provided will describe our verification process and when you should expect a response from us. In general, we will respond to the request within forty-five (45) calendar days from the of receipt; but, if necessary, we may take up to an additional forty-five (45) calendar days to respond to your request. If an extension is needed, we will notify you of the extension and explain the reasons that responding to your request will take more than forty-five (45) calendar days.

7.3. Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. 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 useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

7.4. Delivery. Except as otherwise provided by applicable law, the information will be provided in writing or through our website. We will respond by mail. If we do not take action on your request, we will, without delay and, at the latest, within the time period permitted for our response, inform you of the reasons that we did not take action and any rights you may have to appeal the decision.

We are committed to responding to your requests to exercise Consumer rights in accordance with applicable law and the California Privacy Laws. However, your rights are subject to certain limitations:

a.   We will respond to requests to know by the same user no more than twice in a twelve (12) month period.

b.   A response to a Request to Know may be limited to the 12-month period preceding receipt of the request if it would be impossible, involve disproportionate effort, or the request is for data for a specific time period.

c.    In response to a Right to Know request, we are prohibited from disclosing social security numbers, driver’s license numbers, other government-issued identification numbers, financial account numbers, health insurance numbers, medical identification numbers, account passwords, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. However, we will inform you whether we have collected that type of information.

d.   Other limitations to Consumer rights under the California Privacy Laws may apply. For example, we will not able to comply with your request to delete your personal information if it is necessary for certain legitimate business purposes or exercising legal obligations.

We are not required to delete your personal information if it is reasonably necessary for us, our service providers, or our contractors to maintain the personal information in order to:

a.   Complete the transaction for which the personal information was collected, provide a service that you requested, take actions reasonably anticipated by the you within the context of our ongoing business relationship with you, or otherwise perform a contract with you.

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

c.   Debut to identify and repair errors that impair existing intended functionality.

d.   Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.

e.   Comply with the California Electronic Communications Privacy Act (Ca. Penal Code § 1546 et. seq.).

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

g.   To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information.

h.   Comply with a legal obligation.

If we deny a verified request to exercise Consumer’ right under the California Privacy Laws, in whole or in part, because of a conflict with federal or state law, or an exception under applicable law, we will inform the requestor and explain the basis for the denial. We will take action, in accordance with your request and California Privacy Laws, for those categories of personal information not subject to those exceptions.

7.5. Verification procedure. We are required by the CPRA to verify the identity of individuals who submit a request to know, request to delete, or request to correct. In accordance with our internal policies and in compliance with the California Privacy Laws, we will take steps to verify your identity before granting you access to such Personal Information or acting on your request to exercise your rights, as outlined below:

To determine whether the individual making the request is the consumer about whom we collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As part of this process, you will be asked to provide your full name, address, and phone number. We will inform you if we cannot verify your identity.

a.   If we cannot verify the identity of the person making the request for specific pieces of information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer

b.   If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response an explain why we have no reasonable method by which we can verify the identity of the requestor.

If we cannot verify your identity based on the information already maintained, we may request additional information from you. We will try to limit the information collected, and we will only use this information to verify your identity and for security or fraud-prevention purposes. Except as required by law, we will delete any new personal information collected for the purposes of verification as soon as practical after processing the request.

7.6. Authorized Agents. You may designate an authorized agent to make requests on your behalf by sending us written authorization in writing at AspireIQ Inquiries, 550 Montgomery Street, Suite 800, San Francisco, CA 94111. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with written permission to do so; and (2) verify your identity directly with us. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code. We may deny a request from the agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

7.7. Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

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8. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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9. Changes to this Privacy Policy

We reserve the right to amend, add to, change, update, or modify this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will notify you by email or through a notice on our website homepage. If we make material changes to how we treat your personal information, we will also notify you through a notice on the home page of the website for a reasonable period of time. Any such changes, updates, or modifications shall be effective immediately upon posting this California Privacy Policy. The data on which this policy was last modified is identified at the beginning of this California Privacy Policy.

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10. Contact information

 If you have any questions or comments about this California Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to lodge a complaint with us, you may contact us using the information below and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by email or telephone as follows:

By email: help@aspireiq.com

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