Last Updates: September 13, 2023
Overview
This supplemental Privacy Policy (the “Supplemental Policy”) supplements and is expressly made part of the information contained in the Eight Eleven Group Privacy Policy and applies to our collection and use of Personal Information of residents in California, Colorado, Connecticut, Utah and Virginia, including where such use is governed by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Protection Act (“CTDPA”), the Virginia Consumer Data Protection Act (“VCDPA”) and the Utah Consumer Privacy Act (“UCPA”). To the extent applicable, those laws will be referred to as the “applicable state laws” in this Supplemental Policy. References to “Eight Eleven Group,” “we,” “us” or “our” means and refers to Eight Eleven Group and all of our divisions and family of companies and other terms have the meaning set forth in the main Privacy Policy. Any terms defined in the applicable state laws have the same meaning when used in this Supplemental Policy.
Personal Information We Collect
We collect, process and retain various types of personal information. “Personal Information” means 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. It does not include de-identified or aggregate information, or public information lawfully available from government records.
The following chart describes, by category, the types of Personal Information covered by this Supplemental Policy that we have collected from our consumers within the last twelve (12) months.
| Category of Personal Information | Purpose(s) for Collection | Categories of Source(s) | Categories of Third Persons With Which PI Was Shared | Categories of Third Parties To Which PI was Sold |
|---|---|---|---|---|
| Identifiers, information and PI categories such as name, email address, postal address, telephone number, social security number, unique personal identifier, online identifier, Internet Protocol address, email address, account credentials (username and password). | To provide Services, improve Websites. | Account set up during onboarding, on site forms. | Analytics platforms, marketing agencies. | N/A |
| Internet or other similar network activity including analytics information on a User’s interaction with the Websites. | Improving Websites. | Analytics cookies. | Analytics platform, email provider. | N/A |
We may collect this Personal Information directly from you and automatically via cookies when you visit our website.
Additional Information About Use and Sharing of Personal Information
In addition to the sharing of Personal Information as reflected on the chart above, we may disclose any information, including Personal Information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, including to respond to subpoenas or warrants served on us, or in connection with detection, prevention or investigation of fraud. In addition, we may disclose information about you when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
We may share some of your Personal Information with third party service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that provide web hosting, analytics and marketing services.
We also reserve the right to transfer Personal Information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
How We Use Personal Information
We may use personal information you provide to:
- Analyze, manage and improve our Websites so that we may continually strive to provide you with the best services that we possibly can;
- Send you periodic communications and respond to your inquiries;
- Provide and improve upon the Services;
- Create and manage your online account;
- Operate, evaluate and improve our business (including developing new services; managing our communications; analyzing our Services; performing data analytics; and performing accounting, auditing and other internal functions); and
- Comply with applicable legal requirements, relevant industry standards and our policies
Disclosure of Personal Information
We may disclose Personal Information for the purposes outlined in our Privacy Policy. Sales of Personal Information As described in our Privacy Policy, some of our activities may be considered “selling” or “sharing” of your personal information under California law. For more information on this, see our Privacy Policy.
California Privacy Rights
To the extent you are a resident of California, you may have the following rights with respect to your Personal Information:
Right To Access
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. When we receive your request to know what Personal Information we have collected from you, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources from which that information was collected; (iii) our purpose for collecting or selling that personal information; (iv) the categories of third parties with whom we share that personal information; (v) the specific items of personal information that we collected about you; and (vi) if we sold or disclosed your personal information for a business purpose, we will identify for sales of information, the personal information categories that each category of recipient purchased; and, where we have disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained. You may request these disclosures twice within a twelve month period.
Right To Delete Personal Information
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. Once we receive and confirm your request to delete your personal information, we will delete (and direct our service providers to delete) such information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Enable solely internal uses that are reasonably aligned with user expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CPRA. Accordingly, by way of example, we will not deny you services; charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties; give you a different level or quality of services; or suggest that you may receive a different price or rate for services or a different level or quality of services.
Right to Correct Inaccurate Information
You have the right to request that we correct any inaccuracies that appear in the personal information that we collect from you and retain. Once we receive and confirm your request to correct your personal information, we will correct such information in our records and will alert you to the changes that were made.
Right to Opt-Out of the Sale or Sharing of Data
You have the right to opt-out of the “sale” or “sharing” of your personal information. Where applicable, to opt-out from the sharing or sale of information described above, please click the “Do Not Sell or Share My Personal Information” link on the bottom of the website homepage OR email your request to support@eightelevengroup.com.
Right to Limit Use or Disclosure of Sensitive Personal Information (“SPI”)
We collect certain SPI, including driver’s license numbers, social security numbers and/or tax identification numbers in connection with providing our Services to you. You have the right to limit the use or disclosure of your SPI if we are using your SPI beyond what is reasonable and proportionate to provide the requested Products or services. You can make a request for us to limit the use or disclosure of your SPI by visiting the Do Not Sell or Share My Personal Information link on our homepage.
Verifiable Consumer Requests
If you submit a request to us to disclose how we collect and use your personal information or to delete your personal information from our records, we must be able to verify your request. To be “verifiable,” you must provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information or that you are an authorized representative of that person and you must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it (a “verifiable consumer request”). Please indicate that you are making a request pursuant to your state privacy rights. You must provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We cannot respond to your request if it is not a verifiable consumer request. 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. You may also make a verifiable consumer request on behalf of your minor child. To make a verifiable consumer request for disclosure of our collection and use of your personal information or to delete your personal information, you can call us at our toll free number: 800-611-3995 email us at support@eightelevengroup.com or write to us via mail at 6215 N College Avenue, Indianapolis, IN 46220.
We will try to respond to a verifiable consumer request within 45 days of its receipt. If we need more time (up to 90 days), we will let you know in writing, either by email or mail, why we need more time and when we will provide our response. There is no charge to you for us 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.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Security of Your Personal Information
Eight Eleven Group takes reasonable precautions to protect the security of your personal information. Our Website is hosted on servers that utilize SSL server software. We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances, including the security of your data during transmission to us or the security of data on your mobile device.
Other California Privacy Rights
Because we value your privacy, we will not provide personal identification information about you to third parties for their solicitation or marketing purposes.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@eightelevengroup.com.
Colorado Privacy Rights
To the extent you are a resident of Colorado, you may have the following rights with respect to your Personal Information:
Colorado residents have the right to receive certain disclosures regarding a business’ processing of personal data, as well as certain rights with respect to our processing of such personal data. To the extent that you are a resident of Colorado, and we collect personal data subject to the applicable Colorado law, the following applies:
Right to Access
You have the right to confirm whether or not we are processing your personal information and to access such personal information, including: (i) the categories of personal information we collect about you; (ii) the categories of sources from which we collect such personal information; (iii) the business or commercial purpose for collecting, selling or sharing personal information about you; (iv) the categories of third parties with whom we shared or disclosed such personal information; and (v) the specific pieces of personal information we have collected about you.
Right to Correction
You have the right to correct inaccuracies in any personal information we have collected about you, taking into account the nature of the personal data and the purposes for processing your personal data.
Right to Deletion
You have the right to delete the personal data that has been provided to us by you.
Right to Data Portability
You have the right to obtain a copy of the personal information that you previously provided to us in a structured, commonly used and machine-readable format, so that you can transfer it to another party, if you have given us permission to process your data and where the processing was carried out by automated means.
Right to Opt-Out of Sale, Targeted Advertising and Profiling
For purposes of Colorado law, a “sale” includes disclosing personal information to a third party in exchange for monetary compensation or other valuable consideration. Colorado residents have the right to opt-out of the processing of your personal information by us for decisions that produce legal or similarly significant effects concerning you. We do not process personal information for such profiling.
Right to Appeal
If we decline to take action regarding your request, you have the right to appeal our decision. We will notify you providing our reasons and instructions for how you can appeal the decision. You have the right to contact the Colorado Attorney General if you have concerns about the result of the appeal.
Connecticut Privacy Rights
To the extent you are a resident of Connecticut, you may have the following rights with respect to your Personal Information:
Connecticut residents have the right to receive certain disclosures regarding a business’ processing of personal data, as well as certain rights with respect to our processing of such personal data. To the extent that you are a resident of Connecticut, and we collect personal data subject to the applicable Connecticut law, the following applies:
Right to Access
You have the right to confirm whether or not we are processing your personal information and to access such personal information.
Right to Correction
You have the right to correct inaccuracies in any personal information we have collected about you, taking into account the nature of the personal data and the purposes for processing your personal data.
Right to Deletion
You have the right to delete the personal data that has been provided to us by you.
Right to Data Portability
You have the right to obtain a copy of the personal information that you previously provided to us in a structured, commonly used and machine-readable format, so that you can transfer it to another party, if you have given us permission to process your data and where the processing was carried out by automated means.
Right to Opt-Out of Sale, Targeted Advertising and Profiling
For purposes of Connecticut law, a “sale” includes disclosing personal information to a third party in exchange for monetary compensation or other valuable consideration. Connecticut residents have the right to opt-out of the processing of your personal information by us for decisions that produce legal or similarly significant effects concerning you. We do not process personal information for such profiling. To opt out of targeted marketing, where applicable, please see our online form.
Right to Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CTDPA. Accordingly, by way of example, we will not deny services; charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties; give you a different level or quality of services; or suggest that you may receive a different price or rate for services or a different level or quality of services.
Right to Appeal
If we decline to take action regarding your request, you have the right to appeal our decision. We will notify you providing our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you to contact the Connecticut Attorney General to submit a complaint.
Utah Privacy Rights
To the extent you are a resident of Utah, you may have the following rights with respect to your Personal Information: Utah residents have the right to receive certain disclosures regarding a business’ processing of personal data, as well as certain rights with respect to our processing of such personal data. To the extent that you are a resident of Utah and we collect personal data subject to the applicable Utah law, the following applies:
Right to Access
You have the right to confirm whether or not we are processing your personal information and to access such personal information.
Right to Correction
You have the right to correct inaccuracies in any personal information we have collected about you, taking into account the nature of the personal data and the purposes for processing your personal data.
Right to Deletion
You have the right to delete the personal data that has been provided to us by you.
Right to Data Portability
You have the right to obtain a copy of the personal information that you previously provided to us in a structured, commonly used and machine-readable format, so that you can transfer it to another party, if you have given us permission to process your data and where the processing was carried out by automated means.
Right to Opt-Out of Sale, Targeted Advertising and Profiling
For purposes of Utah law, a “sale” includes disclosing personal information to a third party in exchange for monetary compensation. We do not “sell” personal information under this definition. Utah residents have the right to opt-out of the processing of your personal information by us for decisions that produce legal or similarly significant effects concerning you. We do not process personal information for such profiling. To opt out of targeted marketing, where applicable, please see our online form.
Right to Non-Discrimination
We will not discriminate against you for exercising any of your rights under the UCPA. Accordingly, by way of example, we will not deny you Services; charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties; give you a different level or quality of services; or suggest that you may receive a different price or rate for services or a different level or quality of services.
Virginia Privacy Rights
To the extent you are a resident of Virginia, you may have the following rights with respect to your Personal Information:
Virginia residents have the right to receive certain disclosures regarding a business’ processing of personal data, as well as certain rights with respect to our processing of such personal data. To the extent that you are a resident of Virginia and we collect personal data subject to the applicable Virginia law, the following applies:
Right to Access
You have the right to confirm whether or not we are processing your personal information and to access such personal information.
Right to Correction
You have the right to correct inaccuracies in any personal information we have collected about you, taking into account the nature of the personal data and the purposes for processing your personal data.
Right to Deletion
You have the right to delete the personal data that has been provided to us by you.
Right to Data Portability
You have the right to obtain a copy of the personal information that you previously provided to us in a structured, commonly used and machine-readable format, so that you can transfer it to another party, if you have given us permission to process your data and where the processing was carried out by automated means.
Right to Opt-Out of Sale, Targeted Advertising and Profiling
For purposes of Virginia law, a “sale” includes disclosing personal information to a third party in exchange for money. We do not “sell” personal information under this definition. Virginia residents have the right to opt-out of the processing of your personal information by us for decisions that produce legal or similarly significant effects concerning you. We do not process personal information for such profiling. To opt out of targeted marketing, where applicable, please see our online form.
Right to Non-Discrimination
We will not discriminate against you for exercising any of your rights under the VCDPA. Accordingly, by way of example, we will not deny you services; charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties; give you a different level or quality of services; or suggest that you may receive a different price or rate for services or a different level or quality of services.
Right to Appeal
If we decline to take action regarding your request, you have the right to appeal our decision. We will notify you providing our reasons and instructions for how you can appeal the decision. You have the right to contact the Virginia Attorney General if you have concerns about the result of the appeal.
We do not collect or process personal information considered "sensitive" that is subject to the VCDPA, including information pertaining to racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation or citizenship or immigration status.
Changes to this Supplemental Policy
We will review and update this Supplemental Policy as we deem necessary and/or as required to remain in compliance with rules and regulations, and to keep current with new technologies and security standards. When we make changes to the Supplemental Policy, we will post the updated Notice on the Websites and update the Supplemental Policy’s effective date. Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this Supplemental Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California, Colorado, Connecticut, Utah or Virginia law, please do not hesitate to contact us at:
Phone: 800-611-3995
Contact Us: support@eightelevengroup.com.