PRIVACY POLICY
Last updated May 11, 2020
Thank you for choosing to be part of our community at [Breaking free from employment
LLC], a California limited liability company (“Company”, “we”, “us”, or “our”). We are
committed to protecting your personal information and your right to privacy. If you have
any questions or concerns about our policy, or practices with regards to your personal
information, please contact us at info@breakingfreefromemployment.com.
When you visit our website https://breakingfreefromemployment.com/, mobile
application, or use our services, you trust us with your personal information. We take
your privacy very seriously. In this privacy notice, we describe our Privacy Policy. We
seek to explain to you in the clearest way possible what information we collect, how we
use it, and what rights you have in relation to it. We hope you take some time to read
through it carefully, as it is important. If there are any terms in this Privacy Policy that
you do not agree with, please discontinue our Sites, Apps, and our services.
This Privacy Policy applies to all information collected through our website (such as
https://breakingfreefromemployment.com/), mobile application (“Apps”), and/or any
related services, sales, marketing, or events (we refer to them collectively in this Privacy
Policy as the “Sites”).
Please read this Privacy Policy carefully as it will help you make informed decisions
about sharing your personal information with us.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES?
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS POLICY?
12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address,
contact information, passwords and security data, and payment information.
We collect personal information that you voluntarily provide to us when registering at the
Sites or Apps, expressing an interest in obtaining information about us or our products
and services, when participating in activities on the Sites, Apps, or otherwise contacting
us.
The personal information that we collect depends on the context of your interactions with
us and the Site or Apps, the choice you make, and the products and features you use. The
personal information we collect can include the following:
Name and Contact Data. We collect your first and last name, email address, postal
address, phone number, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used
for authentication and account access.
Payment Data. We collect data necessary to process your payment if you make
purchases, such as your payment instrument number (such as credit card number), and
the security code associated with your payment instrument. All payment data is stored by
our payment processor, and you should review its privacy policies and contact the
payment processor directly to respond to your questions.
All personal information that you provide to us must be true, complete and accurate, and
you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device
characteristics – is collected automatically when you visit our Sites or Apps.
We automatically collect certain information when you visit, use, or navigate the Sites or
Apps. This information dies not reveal your specific identify (like your name or contact
information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences, referring
URLs, device name, country, location, information about how and when you use our
Sites or Apps and other technical information. This information is primarily needed to
maintain the security and operating of our Sites or Apps, and for our internal analytics
and reporting purposes.
Like many businesses, we also collect information through cookies and similar
technologies.
Information collected through our Apps
In Short: We may collect information regarding your geo-location, mobile device, push
notifications, when you use our apps.
If you use our Apps, we may also collect the following information:
Push Notifications. We may request to send you push notifications regarding your
account for the mobile application. If you wish to opt-out from receiving these types of
communications, you may turn them off in your device’s settings.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, and
other outside sources.
We may obtain information about you from other sources, such as public databases, joint
marketing partners, as well as from other third-parties. Examples of the information we
receive from other sources include: social media profile information; marketing leads,
and search results and links, including paid listings (such as sponsored links).
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business
interests, the fulfillment of our contract with you, compliance with our legal obligations,
and/or your consent.
We use personal information collected via our Sites or Apps for a variety of businesses
purposes described below. We process your personal information for these purposes in
reliance on our legitimate business interests, in order to enter into or perform a contract
with you, with your consent, and/or for compliance with our legal obligations. We
indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
• To facilitate account creation and logon process. If you choose to link your
account with us to a third-party account, such as your Google or Facebook
account, we use the information you allowed us to collect from those third-parties
to facilitate account creation and logon process.
• To send you marketing and promotional communications. We and/or our
third-party marketing partners may use the personal information you send to us
for our marketing purposes, if this is in accordance with your marketing
preferences. You can opt-out of our marketing emails at any time (see WHAT
ARE YOUR PRIVACY RIGHTS below).
• To send administrative information to you. We may use your personal
information to send you product, service, and new feature information and/or
information about changes to our terms, conditions, and policies.
• Fulfill and manage your orders. We may use your information to fulfill and
manage your orders, payments, returns, and exchanges made through the Sites or
Apps.
• To protect our Sites. We may use your information as part of our efforts to keep
our Sites or Apps free and secure (for example, of fraud monitoring and
prevention).
• To enforce our terms, conditions, and policies.
• To respond to legal requests and prevent harm. If we receive a subpoena or
other legal request, we may need to inspect the data we hold to determine how to
respond.
• For other Business Purposes. We may use your information for other Business
Purposes, such as data analysis, identifying usage trends, determining the
effectiveness of our promotional campaigns and to evaluate and improve our Sites
or Apps, products, services, marketing, and your experience.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to protect
your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
• Consent: We may process your data if you have given us specific consent to use
your personal information in a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary
to achieve our legitimate business interests.
• Performance of a Contract. Where we have entered into a contract with you, we
may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally
required to do so in order to comply with applicable law, governmental requests, a
judicial proceeding, court order, or legal process, such as in response to a court
order or a subpoena (including in response to public authorities to meet national
security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is
necessary to investigate, prevent, or take action regarding potential violations or
our policies, suspected fraud, situations involving potential threats to the safety of
any persona and illegal activities, or as evidence in litigation in which we are
involved.
More specifically, we may need to process your data or share your personal information
in the following situations:
• Vendors, Consultants, and Other Third-Party Service Providers. We may
share your data with third-party vendors, service providers, contractors or agents
who perform services for us or on our behalf and require access to such
information to do that work. Examples include: payment processing, data
analysis, email delivery, hosting services, customer service, and marketing efforts.
We may allow selected third-parties to use tracking technology on the Sites or
Apps, which will enable them to collect data about how you interact with the Sites
or Apps over time. This information may be used to, among other things, analyze
and tack data, determine the popularity of certain content, and better understand
online activity. Unless described in this Policy, we do not share, sell, rent, or trade
any of your information with third-parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection
with, o during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
• Business Partners. We may share your information with our business partners to
offer you certain products, service, or promotions.
• Offer Wall. Our Apps may display a third-party hosted “offer wall.” Such an
offer wall allows third-parties advertisers to offer virtual currency, gifts, or other
items to users in return for acceptance and completion of an advertisement offer.
Such an offer wall may appear in our mobile application and be displayed to you
based on certain data, such as your geographic area or demographic information.
When you click on an offer wall, you will leave our mobile application. A unique
identifier, such as your user ID, will be shared with the offer wall provider in
order to prevent fraud and properly credit your account.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with the following third-parties.
We only share and disclose your information with the following third-parties. We have
categorized each party so that you may easily understand the purpose of our data
collection and processing practices. If we have processed your data based on your
consent, and you wish to revoke your consent, please contact us.
• Advertising, Direct Marketing, and Lead Generation:
• Affiliate Marketing Programs:
• Allow Users to Connect to their Third-Party Accounts:
• Communicate and Chat with Users:
• Content Optimization:
• Data Backup and Security:
• Functionality and Infrastructure Optimization:
• Invoice and Billing:
• Retargeting Platforms:
• Social Media Sharing and Advertising:
• User Account Registration and Authentication:
• User Commenting and Forms:
• Web and Mobile Analytics:
• Website Hosting:
• Website Performance Monitoring:
• Website Testing:
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your
information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to
access or store information. Specific information about how we use such technologies
and how you can refuse certain cookies is set out in our Cookie Policy.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes
outlined in this Privacy Policy, unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the
purposes set out in this Privacy Policy, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements) No purpose in this
policy will require us keeping your personal information for longer than the period of
time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymize it, or, if this is not possible (for example, because your
personal information has been stored in backup achieves), then we will securely store
your personal information and isolate it from any further processing until deletion is
possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your parties will not be able to defeat our security, and
improperly collect, access, steal, or modify your information. Although we will do our
best to protect your personal information, transmission of personal information to and
from our website is at your own risk. You should only access the website within a secure
environment.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you have rights that
allow you greater access to and control over your personal information. You may review,
change, or terminate at any time.
In some regions (like the European Economic Area), you have certain rights under
applicable data protection laws. These may include the right (i) to request and obtain a
copy of your personal information; (ii) to request rectification or erasure; (iii) to restrict
the processing of your personal information; and (iv) if applicable, to data portability. In
certain circumstance, you may also have the right to object to the processing of your
personal information. To make such a request, please see HOW CAN YOU CONTACT
US ABOUT THIS POLICY below. We will consider and act upon any request in
accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right
to withdraw your consent at any time. Please note however, that this will not affect the
lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully
processing your personal information, you also have the right to complain to your local
data protection supervisory authority. You can find their contact details here: http://
ec.europa.eu/justice/data-protection/bodies/authoriteis/index_en.htm
Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:
• Log into your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account
and information from our active databases. However, some information may be retained
in our filed to prevent fraud, troubleshoot problems, assist with any investigations,
enforce our Terms of Use and/or comply with legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by
default. If you prefer, you can usually choose to set your browser to remove cookies and
to reject cookies. If you choose to remove cookies or reject cookies, this could affect
certain features or services of our Sites or Apps. To opt-out of interest-based advertising
by advertisers on our Sites or Apps visit https://www.aboutads.info/choices/ .
Opting out of email marketing: You can unsubscribe from our marketing email list at
any time by clicking on the unsubscribe link in the emails that we send or by contacting
us using the details provided below. You will then be removed from the marketing email
list – however, we will still need to send you service-related emails that are necessary for
the administration and use of your account. To otherwise opt-out, you may:
• Access your account settings and update preferences.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most Web browsers and some mobile operating systems and mobile applications include
a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities monitored and
collected. No uniform technology standard for recognizing and implementing DNT
signalized has been finalized. As such, we do not currently respond to DNT browser
signals or any other mechanism that automatically communicates your choice not to be
tracked online. If a standard for online tracking is adopted that we must follow in the
future, we will inform you about that practice in a revised version of this Privacy Policy
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights
regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits
our users who are California residents to request and obtain from us, once a year, and free
of charge, information about categories of personal information (if any) we disclosed to
third-parties for direct marketing purposes and the names and addresses of all thirdparties with which we shared personal information in the immediately preceding calendar
year. If you are a California resident and would like to make such a request, please submit
your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with
the Sites or Apps, you have the right to request removal of unwanted data that you
publicly post on the Sites or Apps. To request removal of such data, please contact us
using the contact information provided below, and include the email address associated
with your account and a statement that you reside in California. We ill make sure the data
is not publicly displayed on the Sites or Apps, but please be aware that the data may not
be completely or comprehensively removed from our systems.
11. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant
laws.
We may update this Privacy Policy from time to time. The updates version will be
indicated by an updated “Revised” date and the updated version will be effective as soon
as it is accessible. If we make material changes to this Privacy Policy, we may notify you
either by prominently posting a notice of such changes or by directly sending you a
notification. We encourage you to review this Privacy Policy frequently to be informed of
how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this Privacy Policy, you may contact our Data
Protection Officer (DPO) by email at info@breakingfreefromemployment.com, by phone
at (408) 640-5845, or by post to:
Mailing Address:
3700 Lillick Drive, Apt. 326
Santa Clara, California 9505