Last modified November 1, 2018
Our Collection and Use of Personal Information
Personal information is information you provide us that can be used to uniquely identify or contact a single person, such as your name, email address, address, phone numbers and tax identification number.
CallEngine may supplement the personal information you provide with personal information available from other sources, such as public databases, data aggregators, and other commercially available sources.
Examples of Personal Information We Collect
The personal information we collect allows us to deliver requested products, services and information to you, to stay in contact with you, and to manage CallEngine relationship with you. By providing CallEngine with personal information, you consent to CallEngine transfer and storage of that information.
We collect information from you when you use the Website, contact or interact with us, sign up for our newsletters or other mailing lists, and voluntarily provide us with your comments and other content in connection with using the Website.
When you contact us or otherwise generally use the Website, we may collect: your name, email address, address, telephone number, best time to call, and any other information you voluntarily provide.
When you request a quote for services from other providers through the Website, we may collect: your name, address, telephone number, email address, date of birth, gender, marital status, Medicaid enrollment information, smoking information, household income, homeowner status, and number of family members.
When you request information related to auto loan applications through the Website, we may collect: your name, email address, telephone number, date of birth, address, residence type, and income.
When you request information regarding credit repair and register an account, we may collect: your name, email address, address, telephone number, credit score, household expenses, debt information, and income.
When you request information related to your credit score, we may collect: your name, email address, address, telephone number, date of birth, and your social security number.
Information We May Collect Automatically When You Use the Website
When you access and use the Website, we automatically collect information regarding you and your device, including your user name, roles/permissions for the Website, your device’s Internet Protocol address, the domain name of your Internet service provider, your location, the Website features you use and the time of your use, your mobile device information (e.g. device model and operating system version), and aggregated information that cannot be used to specifically identify you.
In some email messages, we use a Click-Through URL to link to content on our Website. When you click on one of these URLs, you pass through a separate web server before reaching our site. We use Click-Through URLs to help us determine interest in a particular topic and to measure the effectiveness of our email communications.
Additional information collected is described in the Analytics and Cookies and Other Tracking Technologies sections below.
How We Use Your Information
We may use the information that we collect for several purposes, including:
- The purposes for which you provided it;
- To provide information and services to you;
- To connect you with service providers and CallEngine partners that can provide services for you;
- To connect with your social media accounts and share information with you, should you choose to connect with CallEngine’s social media accounts;
- To process and respond to your inquiries and comments;
- To send you information about your relationship or transactions with us;
- To facilitate payment transactions (your information will be used to submit your payment information to our payment processor);
- To administer, operate, and improve the Website or develop new services;
- To personalize and enhance your experience using the Website;
- To advertise and market products and services to you;
- To send periodic emails. If you choose, the email address you provide may be used to send you occasional news, updates, etc. Note: If you would like to unsubscribe from receiving future emails at any time, we include detailed unsubscribe instructions at the bottom of each email;
- To generate and review reports and data about our user base and Website usage patterns;
- To analyze the accuracy, effectiveness, usability or popularity of the Website;
- To compile aggregate data for internal and external business purposes;
- To prevent fraud and abuse of the Website and to otherwise protect users and visitors and our organization;
- To assist law enforcement and respond to subpoenas; and
Please note that you may choose not to allow us to use your personal information for certain purposes as described in the Your Choices Regarding Your Information section below.
- Legal Bases for Processing Your Information (For Users in European Union)
A. Performance of a Contract
The use of your personal information may be necessary to perform the agreement you have with us to provide you with services, including for referrals and other services through the Website. We use your data to provide you with services, to register and maintain your account, and to respond to your requests.
B. Legitimate Interests
We use your personal information for our legitimate interests. We rely on our legitimate interest to deliver our services to our users, to administer, analyze and improve our services and the content on the Website, to operate our business including through the use of service providers and subcontractors (who may have access to your data – see further under the section How Your Information is Disclosed), to send you notifications about our services, for archiving, records keeping, statistical and analytical purposes, or to use your personal information for administrative, fraud detection, audit, training, security, or legal purposes.
Where other lawful basis are not available for the processing of your personal information, we may rely on your consent as the legal basis for the collection and use of your personal data. You are free to withdraw your consent at any time, subject to the Your Choices Regarding Your Information section below and the preceding Legal Bases for Processing Your Information in this Section.
D. Compliance with Legal Obligations
We may use your personal information to comply with legal obligations to which we are subject, including to comply with legal process.
How Your Information is Disclosed
C. Organizational Changes. If we become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our organization otherwise changes, we may transfer your information to a third party or parties in connection therewith.
F. Investigations and Law. We may disclose information about you to third parties if we believe that such disclosure is necessary to:
- Comply with the law or guidance and cooperate with government or law enforcement officials or private parties;
- Investigate, prevent or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety, and property of us, users or others, or violations of our policies or other agreements with us;
- Respond to claims and legal process (for example, subpoenas); and/or
- Protect against legal liability.
G. Aggregated Information. We may share aggregated information relating to users of the Website with affiliated or unaffiliated third parties. This aggregated information does not contain personal information about any user.
Cookies and Other Tracking Technologies
Cookies are small files that are transferred to and stored on your device through your web browser (if you allow it) that enable the website’s or service provider’s system to recognize your browser and capture and remember certain information. You can instruct your browser to stop accepting cookies. But if you do not accept cookies, you may not be able to use all portions of all functionality of the Website.
- Persistent cookies remain on the visitor’s computer after the browser has been closed.
- Session cookies exist only during a visitor’s online session and disappear from the visitor’s computer when they close the browser software.
Flash cookies (also known as local shared objects) are data files that can be created on your computer by the websites you visit and are a way for websites to store information for later use. Flash cookies are stored in different parts of your computer from ordinary browser cookies. You can disable the storage of flash cookies. For additional information about managing and disabling flash cookies, please visit http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. You can disable the ability of web beacons to capture information by blocking cookies.
Information Security and Retention
CallEngine takes precautions to safeguard your personal information from loss, theft, and misuse, as well as unauthorized access, disclosure, alternation, and destruction. These precautions include technical, physical, and managerial procedures.
Because email and instant messaging are not recognized as secure communications, we request that you not send private information to us by email or instant messaging services.
We are committed to working with appropriate regulatory authorities to resolve any complaints regarding the transfer of personal information that we cannot resolve with our customers directly.
CallEngine uses Secure Sockets Layer (SSL) encryption on all pages where personal information is collected. This protects the confidentiality of your personal information while it is transmitted over the Internet.
For your own protection, you should exercise care with the information you share over the Internet. You should always use a secure browser and exercise good judgment in using passwords, such as using a combination of upper and lower case letters, numbers, special characters, and you should avoid using the same or similar passwords across multiple sites.
Clients may access their personal information by logging into their account. We make good-faith efforts to give you ways to update or to delete your personal information quickly, unless we need to keep that information for a legitimate business or legal purpose. Some changes require personal contact with an assigned CallEngine representative.
We may reject requests to change or delete information that are unreasonably repetitive, require disproportionate technical effort (for example, requiring the development of new systems or fundamental changes to existing systems), risk the privacy of others, or would be extremely impractical (such as information stored on backups).
We work to protect data from accidental or malicious destruction. Accordingly, we may not immediately delete or change residual copies and we may not delete or change information from our backup systems. Unless a disproportionate effort is required, we will provide information access and correction without charge.
We cannot guarantee that transmissions of your personal information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS OR CAUSES BEYOND OUR CONTROL.
Any information collected through the Website is stored and processed in the United States. If you use our Website outside of the United States, You consent to have Your data transferred to the United States.
Third Party Privacy Policies
Your Choices Regarding Your Information
You have choices regarding the use of information by the Website.
- Changing Your Information – You may request to review, update, or have deleted any personal information collected from you through the Website. Just send us an email asking to review or update your personal information, or to have us delete your personal information. However, we reserve the right to retain personal information as necessary for our business purposes and to comply with federal and state laws.
- Closing Your Account –If the email account associated with your email address is not active, we may remove it from our system without notice.
- Withdrawing Consent – If you are an individual residing in the EU, and you provided your consent for any particular processing of your personal information, you have the right to withdraw your consent to our processing of your information any time by requesting that your personal information be deleted. See further under the section EU Privacy Rights This deletion is permanent and your information cannot be reinstated. To proceed with this request, please email firstname.lastname@example.org.
- Opt-Outs Available from Our Partners – Some of our partners allow users to opt-out of their collection of information. Some of our partners provide information on controlling cookies. For more information you may visit the Network Advertising Initiative’s Consumer Opt-Out Link and/or the Digital Advertising Alliance’s Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings Please note that to the extent advertising technology is integrated into the Website, You may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored to your interests. Also, we do not control any of the opt-out links above and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
EU Privacy Rights
Users based in the European Union have the following legal rights in respect of their information:
- The right to require CallEngine to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;
- The right to require CallEngine to rectify inaccurate information without undue delay;
- The right to request the erasure of their information. Subject to certain conditions, CallEngine may be required to erase the information in response to such request where:
- the information is no longer necessary in relation to the purpose for which it was collected, such as where a user chooses to terminate his or her use of the Website;
- where the processing of the information is based on the user’s consent (and the other circumstances described in the Legal Bases for Processing Your Information and How Your information is Disclosed sections above no longer apply), if the user withdraws his or her consent; or
- the user objects to the processing of his or her information and there are no overriding legitimate grounds for the processing.
- Where CallEngine has disclosed the information of a European Union user to a third party and the user requests the erasure or rectification of the data, CallEngine will take all reasonable steps to inform the third party of such request.
- The right to restrict CallEngine from processing their information in certain circumstances, such as where the accuracy of that information is disputed or an objection has been raised (see below). In such circumstances, CallEngine will only process that information with the express consent of the user, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;
- The right to receive their information from CallEngine in a structured, commonly used and machine-readable format;
- The right to object to the processing of their information by CallEngine where:
- CallEngine has relied on the ‘legitimate interest’ basis for processing that information, in which case we will immediately stop processing the user’s information unless we have compelling legitimate grounds which override the interests, rights and freedoms of the user; or
- the information is used for direct marketing purposes, in which case we will immediately stop processing the user’s information for such purposes.
- The right to lodge a complaint with the data protection supervisory authority of the EU member state where the user resides.
- The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.
We do not knowingly collect personal information from children under 18. If we learn that we have collected the personal information of a child under 18, we will take steps to delete the personal information as soon as possible. If you are under the age of 18, please do not submit any personal information through the Website. If you have reason to believe that we may have accidentally received personal information from an individual under age 18, please contact us immediately at email@example.com.
Request for Information
Your California Privacy Rights
Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing us at firstname.lastname@example.org or by writing us at CallEngine, Inc., 3780 14th Ave, Suite 209, Markham ON L3R 9Y5.