Last Updated: March 12, 2022
Commitment to Clients
- We will use reasonable technical, administrative, and physical safeguards to protect client confidential information.
- We will never sell client confidential information.
- We will only disclose client confidential information as permitted by our agreement with our client (typically with your permission, in response to legal requests, to fulfill our ethical obligations, to a vendor that provides services to us and needs to know the information, or to a buyer of our firm).
- If you become a former client, we will continue to honor our commitment so long as we possess your confidential information.
Conflict Between this Policy and Laws and Regulations
Information We Collect
We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
- Unique Identifiers such as name, client number;
- Contact Information such as mailing address, billing address, email address, phone number;
- Financial Information such as credit card number, bank account number and routing number, transaction history;
- Internet and Network Information such as IP address, device ID, browsing/search history, cookie preferences, browser type;
- Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (g., consumer response models, propensity to purchase models).
The specific Personal Information we collect about you may vary based on how you use the Sites and/or Services and your relationship with us.
We also collect information about businesses that engage with us such as EIN, TIN, address, phone number, email address, and credit card or bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business rather than an individual.
Usage Data and Sites Activity
We automatically collect information in connection with the actions you take on the Sites (“Usage Data”). For example, each time you visit our website, we may automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Sites, and the duration of your visits to the Sites. If this information is reasonably capable of being associated with you, we treat it as Personal Information under the category Internet and Network Information. If this information is not reasonably capable of being individually associated with you, we treat it as Usage Data.
We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.
How We Collect Information
We may ask you to provide us with Personal Information when you communicate with us (online or offline), use the Sites, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Sites or Services or we may not be able to fulfill your requested interaction/request.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as marketing/advertising agencies, consumer reporting agencies, government-authorized databases, and third parties recommended by you.
Cookies and Other Automated Tools
We use the following types of cookies:
- Session Cookies: Session cookies keep track of you or your information as you move from page to page within the Sites and are typically deleted once you close your browser. For example, session cookies allow online calculators and communication forms to function properly.
- Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the Sites. For example, persistent cookies may allow us to remember your preferences.
- Functional Cookies: Functional cookies allow our Sites to work as intended such as by facilitating online forms and chat features.
- Advertising Cookies: Advertising cookies allow us to market our Services and track interactions with our Sites for marketing and advertising purposes.
Information from Advertisements
If you arrive at the Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date, and time).
How We Use and Share Information
We use Personal Information for internal purposes, such as:
- Provide you with the Sites and Services,
- Account creation, fulfillment, servicing and customer support: to create client accounts, provide services, keep clients informed about the status of their services, respond to questions and address client concerns, and deliver updates, upgrades, and service improvement information;
- Marketing and market research: to send communications and offers and place advertisements for our services, including offers based on the client’s or potential client’s interests, personal and business characteristics, and location, perform analytics for market and client research, trend analysis, financial analysis, and anonymization of Personal Information;
- Other company communications: to provide clients and potential clients with information that may be of interest such as company newsletters, announcements, reminders, and service bulletins;
- Sites and Services use and analytics: to provide you with access to and use of our Sites and Services, analyze use of our Sites and Services, including the use of third-party web analytics services which may utilize automated technologies to collect data (such as email and IP addresses);
- Eligibility and pricing: to determine if clients or potential clients are eligible for certain services or offers and the pricing related to such services/offers;
- Product research: to conduct research and analysis for maintaining, protecting, and developing our services, increase client satisfaction with our services, and prevent misuse;
- Business operations: to evaluate, develop, and improve business operations and services offered, perform business administration and other normal business activities;
- Compliance: to comply with applicable legal and ethical requirements, government requests, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others; and
- Information security and fraud prevention: to operate information security and anti-fraud programs.
Testimonials and Stories
If you provide a testimonial or story, we may post it publicly on the Sites or in other advertising material. By providing a testimonial or story, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications, without any compensation to you. Unless prohibited by applicable law, we may also use your likeness and story on the Sites or in other advertising material.
We may establish a relationship with other businesses to provide services to us (“Service Providers”), including for:
- Provision of the Sites and Services;
- Facilitating marketing and non-marketing communications;
- Marketing design and development;
- Business analytics (both marketing and non-marketing related);
- IT and network administration such as mobile application development, data storage and management, website hosting, and data security;
- Identity verification;
- Obtaining credit reports and other financial information;
- Payment processing;
- Professional services such as legal and accounting;
- Obtaining legal records;
- Collection of accounts; and
- Day-to-day business operations such as courier services, facilities management, and document destruction.
We only provide our Service Providers with the Personal Information reasonably necessary for them to perform these services on our behalf. You may also be asked to provide Personal Information directly to a Service Provider. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
We do not sell your Personal Information to third-party companies for their direct marketing purposes or for any other purpose.
OTHER PRIVACY AND SECURITY PROVISIONS
We recognize the importance of safeguarding Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.
Please be aware that third-party websites accessible through the Sites or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
How Long We Retain Your Data
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations, and our document retention policies.
The Sites and Services are not intended for children under the age of 18 and we do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.
California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites and Services do not respond to “do not track” signals.
Keep Financials, LLC
1201 Dublin Road
Columbus, Ohio 4312
Email address: firstname.lastname@example.org