Privacy Policy

Effective Date: XXXX

KIRCO, Inc. and its affiliates, including KIRCO II, LLC, (“KIRCO”) have created this Privacy Policy in order to comprehensively inform individuals about our privacy practices and demonstrate our firm commitment to privacy. This Privacy Policy describes how KIRCO collects, uses, discloses, transfers, stores, retains or otherwise processes your personal information when you (whether in your individual or business capacity) access or use, in any manner, any content, products, services or related activities (collectively “Services”), including through the Internet domain(s) owned or operated by KIRCO, which include, but are not limited to, the websites listed in the following webpage: www.kirco.com.

We refer to the above websites and all related sub-pages and domains as “sites” and to each of them as a “site.” When we refer to “we,” “us,” or “our,” we mean KIRCO, or the specific division, subsidiary, or affiliate that operates a site, provides its content, or processes information received through it, each as appropriate and applicable. When we refer to “you” or “your,” we mean the person accessing the site. If the person accessing the site does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.

This Privacy Policy applies to your use of our sites and the collection, processing and disclosure of your information in the provision of Services to our customers. We provide our Services to businesses and not to individual consumers. However, in the course of providing our Services, we may collect personal information of individuals, as will be described in this Privacy Policy. This may include personal information, such as your business contact information, if we provide our Services to a company that you work with or if you are a sole proprietorship and you engage with our Services. We will also collect personal information about you when you visit our sites.

Please read this Privacy Policy carefully. Our Privacy Policy includes:

General Disclosures
What Information We Collect And Disclose And For What Purposes
1. Business Customers
2. Website Visitors
3. Aggregated, Anonymized Or De-Identified Information
4. When We May Sell Information or Use Information For Targeted Advertising

Cookies Policy
Integrations And Links To Other Sites
How Long We Retain Your Information
Marketing And Promotional Communications
Children’s Online Privacy Protection Act (COPPA) Statement
Security
Your Data Rights
Data Rights For California Consumers
How To Submit A Request
How We Process Data Rights Requests

Submitting A Request Through An Authorized Agent

Appeals And Complaints

Changes To This Privacy Policy
Contact Us

This Privacy Policy is supplemented by our:

International Privacy Policy

Marketing Texting Policy

1. GENERAL DISCLOSURES

Each of the sites is hosted in the United States and their intended use is business to business. The sites are not intended for use by consumers or private individuals. If you are visiting the sites from outside of the United States, please note that by providing your information it is being transferred to, stored or processed in the United States and other countries where our data center and servers are located and operated, which may not have privacy protections as strong as those in your own country. The portion of the Privacy Policy sets forth the general privacy policy for the United States and other jurisdictions not otherwise specifically covered by the jurisdiction-specific policies in our International Privacy Policy. Depending on your U.S. state or country of residence, applicable privacy laws may provide you the ability to request access to, correction of or deletion of your information, as further outlined below.

If you are outside the United States please see the provisions in our International Privacy Policy. If you are outside the United States and do not wish to allow the transfer of your personal information to the United States, you should not use these sites and you should opt-out of the collection of cookies. For more information about the cookies we collect and how we collect them, please view our Cookies Policy.

We take your privacy and the protection of your personal information seriously. We will only store, process and disclose your personal information in accordance with applicable law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.

2. WHAT INFORMATION WE COLLECT AND DISCLOSE AND FOR WHAT PURPOSES

In the course of performing our Services and operating the sites, we collect a variety of different kinds of personal information from a variety of different individuals. What information we collect and the purposes for which it is collected will depend on the context of our activities or the Service that is being performed. Therefore, just because this Privacy Policy lists a particular data collection practice does not mean that we have necessarily collected that data from you. Instead, please review the applicable disclosures below to learn about how we may have collected personal information from you depending on how you have interacted with us.

Business Customers

When you visit our sites, interact with our Services or attend our live or online events, we may collect the below personal information from you for the specified purposes.

Categories Collected The personal information we collect may include:	Sources of Collection We may collect your personal information from:	Categories of Third Parties to Which Personal Information is Disclosed We may disclose your personal information to:	Business Purpose We collect, use and disclose your personal information in order to:
Identifier Information	you, directly our marketing, advertising and business development partners	our service providers our affiliates our marketing and advertising partners individuals or entities you authorize courts, litigants, regulators, arbitrators, administrative bodies or law enforcement a purchaser, assignee or other successor organization that acquires all or a portion of our organization or assets	respond to your questions or concerns send you information that you have requested from us or communicate with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys and/or rewards offered by us and select partners process contest and survey entries market our Services provide our Services to our customers perform analytics, enhance our Service offerings or develop new products and services comply by law or prosecute or defend actual or suspected legal claims facilitate the sale, assignment, merger or other transfer of all or a portion of our organization or assets to another entity resolve disputes, deliver information and provide assistance with our Services
The personal information we collect includes your first and last name, personal mailing address, business address, e-mail address, telephone number, fax number and office location. The category of services providers to whom we disclose your data includes our e-mail and telephone communications vendors, database providers, event planning vendors, auditors and our marketing service providers.
Demographic Information	you, directly our marketing, advertising and business development partners	our affiliates our marketing and advertising partners individuals or entities you authorize courts, litigants, regulators, arbitrators, administrative bodies or law enforcement a purchaser, assignee or other successor organization that acquires all or a portion of our organization or assets.	perform analytics, enhance our Service offerings or develop new products and services provide our Services to our customers perform analytics, enhance our Service offerings or develop new products and services comply by law or prosecute or defend actual or suspected legal claims facilitate the sale, assignment, merger or other transfer of all or a portion of our organization or assets to another entity resolve disputes, deliver information and provide assistance with our Services facilitate the sale, assignment, merger or other transfer of all or a portion of our organization or assets to another entity
The personal information we collect includes your date of birth, gender, marital status, home ownership and languages spoken. The category of services providers to whom we disclose your data includes our e-mail and telephone communications vendors, database providers, event planning vendors, auditors.
Commercial Information	you, directly	our service providers our affiliates our marketing and advertising partners individuals or entities you authorize courts, litigants, regulators, arbitrators, administrative bodies or law enforcement a purchaser, assignee or other successor organization that acquires all or a portion of our organization or assets.	send you information that you have requested from us or communicate with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys and/or rewards offered by us and select partners provide our Services to our customers perform analytics, enhance our Service offerings or develop new products and services comply by law or prosecute or defend actual or suspected legal claims facilitate the sale, assignment, merger or other transfer of all or a portion of our organization or assets to another entity resolve disputes, deliver information and provide assistance with our Services
The personal information we collect includes your details about the products and services you have purchased and the corresponding transactions, including in which store the purchase occurred; event and webinar attendance and participation and your preferences in receiving marketing from us and our third parties and your communication preferences. The category of services providers to whom we disclose your data includes our email and telephone communications vendors, database providers, event planning vendors and auditors.
Professional or Employment-Related Information	you, directly our marketing, advertising and business development partners	our service providers our affiliates our marketing and advertising partners individuals or entities you authorize courts, litigants, regulators, arbitrators, administrative bodies or law enforcement a purchaser, assignee or other successor organization that acquires all or a portion of our organization or assets.	respond to your questions or concerns send you information that you have requested from us or communicate with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys and/or rewards offered by us and select partners market our Services provide our Services to our customers perform analytics, enhance our Service offerings or develop new products and services comply by law or prosecute or defend actual or suspected legal claims. facilitate the sale, assignment, merger or other transfer of all or a portion of our organization or assets to another entity resolve disputes, deliver information and provide assistance with our Services
The personal information we collect includes your education, employment/professional information, job history and professional purchasing influence. The category of services providers to whom we disclose your data includes our email and telephone communications vendors, database providers, event planning vendors and auditors.
Financial Information	you, directly	our service providers our affiliates individuals or entities you authorize courts, litigants, regulators, arbitrators, administrative bodies or law enforcement a purchaser, assignee or other successor organization that acquires all or a portion of our organization or assets	process orders and payments record payment transactions or money transfers display your historical transactions comply by law or prosecute or defend actual or suspected legal claims facilitate the sale, assignment, merger or other transfer of all or a portion of our organization or assets to another entity resolve disputes, deliver information and provide assistance with our Services
The personal information we collect includes your bank account information, billing address and payment card details. The category of services providers to whom we disclose your data includes our email and telephone communications vendors, database providers, and auditors.
Sensitive Personal Information (account log-in information)	you, directly	our service providers our affiliates individuals or entities you authorize courts, litigants, regulators, arbitrators, administrative bodies or law enforcement a purchaser, assignee or other successor organization that acquires all or a portion of our organization or assets	provide you with access to our sites and Services respond to your questions or concerns manage your account preferences, establish your profile and registration information
The personal information we collect includes your username and password. The category of services providers to whom we disclose your data includes our email and telephone communications vendors, database providers, event planning vendors and auditors.

Website Visitors

If you visit our sites, we may collect the following information about you for the described purposes and disclose it to the described recipients:

Categories Collected The personal information we collect may include:	Sources of Collection We may collect your personal information from:	Business Purpose The purposes of our collection, use and disclosure include:	Categories of Third Parties to Which Personal Information is Disclosed We may disclose your personal information to:
Identifier Information	you, directly referring websites	our service providers our affiliates entities who operate plug-ins on our sites other entities during a corporate transaction courts, litigants, regulators, arbitrators, administrative bodies or law enforcement for legal purposes	facilitating your use of our sites enforcing any applicable terms of service or other applicable agreements or policies securing our networks, systems and databases against external threats marketing and advertising of our Services
The personal information we collect includes your internet protocol (IP) addresses and online identifiers. The category of services providers to whom we disclose your data includes marketing services vendors, security monitoring providers, data analytics providers, database hosting vendors and our auditors.
Geolocation Information	you, directly referring websites	our service providers our affiliates other entities during a corporate transaction courts, litigants, regulators, arbitrators, administrative bodies or law enforcement for legal purposes	personalizing and facilitating your use of our sites measuring, tracking and analyzing trends and usage in connection with your use or the performance of our sites marketing and advertising of our services
The personal information we collect includes your general geolocation information. The category of services providers to whom we disclose your data includes marketing services vendors, security monitoring providers, data analytics providers, database hosting vendors and our auditors.
Internet or Other Electronic Network Activity Information	you, directly referring websites	our service providers our affiliates other entities during a corporate transaction courts, litigants, regulators, arbitrators, administrative bodies or law enforcement for legal purposes	maintaining and improving our sites personalizing and facilitating your use of our sites measuring, tracking and analyzing trends and usage in connection with your use or the performance of our sites marketing and advertising of our services
The personal information we collect includes your time zone setting, auth0 logs, pages visited, pages viewed, events and page loads, browser plug-in types and versions. The category of services providers to whom we disclose your marketing services vendors, security monitoring providers, data analytics providers, database hosting vendors and our auditors.
Device Information	you, directly referring websites	our service providers our affiliates other entities during a corporate transaction courts, litigants, regulators, arbitrators, administrative bodies or law enforcement for legal purposes	maintaining and improving our sites personalizing and facilitating your use of our sites measuring, tracking and analyzing trends and usage in connection with your use or the performance of our sites marketing and advertising of our services
The personal information we collect includes your operating system and platform and other technology on the devices you use to access the sites. The category of services providers to whom we disclose your marketing services vendors, security monitoring providers, data analytics providers, database hosting vendors and our auditors.

Further, we may collect personal information from you in the form of cookies. For information regarding how we collect, process and disclose personal information in the context of cookies, view our Cookies Policy.

Aggregated, Anonymized Or De-Identified Information

We may disclose or use aggregated, anonymized or de-identified information for any purpose. Aggregated, anonymized or de-identified information is information that can no longer reasonably identify a specific individual. Although such information may be derived from your personal information, it can no longer directly or indirectly reveal your identity. We will only maintain and use this type of information in deidentified form and we will not attempt to reidentify this information, except for the purposes of validating our deidentification process.

When We May Sell Information Or Use Information For Targeted Advertising

In the past twelve (12) months, KIRCO has sold personal information to third-parties or used personal information for targeted advertising. The commercial purposes for these activities is marketing our own services and providing our advertising and marketing products and services to our customers. The categories of personal information that were sold or used for targeted advertising in the last twelve (12) months include:

Business Identifier Information
Demographic Information
Commercial Information

KIRCO does not knowingly use for targeted advertising or sell the personal information of minors under sixteen (16) years of age without affirmative authorization.

Depending on your state or country of residence, you may have the right to opt-out of KIRCO’s sale of your personal information and use of your personal information for targeted advertising. Please see the section titled Your Data Rights for more information. If you are a resident of California, please see the section Data Rights For California Consumers. If you are a resident of a non-U.S. country, please refer to our International Privacy Policy.

3. COOKIES POLICY

Like many companies, KIRCO and its vendors use server logs and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable KIRCO to understand how users interact with the sites and Services. KIRCO and its vendors may tie the information gathered by these means to the identity of users.

What is a cookie?

Cookies are small text files placed on a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about user activities. There are several types of cookies:

Session cookies provide information about how a website is used during a single browser session while a user is visiting a website. Session cookies usually expire after the browser is closed.
Persistent cookies remain on your device between different browser sessions for a set amount of time in order to enable the website to remember user preferences, settings, or actions across other sites. A persistent cookie will remain on a user’s device for a set period of time specified in the cookie.
First-party cookies are cookies set by the operator of the website you are visiting.
Third-party cookies are cookies set by third parties that are different from the operator website you are visiting.
Web beacons, tags and scripts may be used with the sites or in our emails to help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Our collection of cookies

We, our partners, affiliates, and analytics or service providers use cookies and other similar technologies across the sites. We group the cookies that we collect into the following categories based upon their function (note that all types of cookies, as described above, may be found in each category):

Category	Description
Essential Cookies	Essential cookies are sometimes called “strictly necessary” as without them we cannot operate and administer the sites.
Analytics or Performance Cookies	These cookies track information about visits to the sites so that we can make improvements and report our performance. For example: analyze visitor and user behavior so as to provide more relevant content or suggest certain activities. They collect information about how visitors use the sites, which site the user came from, the number of each user’s visits and how long a user stays on the sites. We might also use analytics cookies to test new ads, pages, or features to see how users react to them.
Functional or Preference Cookies	During your visit to the sites, cookies are used to remember information you have entered or choices you make (such as your username, language or your region) on the sites. They also store your preferences when personalizing the sites to optimize your use of the sites, for example, your preferred language. These preferences are remembered, through the use of the persistent cookies, and the next time you visit the sites you will not have to set them again.
Targeting or Advertising Cookies	These Third Party Cookies are placed by third party advertising platforms or networks in order to, deliver ads and track ad performance, enable advertising networks to deliver ads that may be relevant to you based upon your activities (this is sometimes called “behavioral” “tracking” or “targeted” advertising) on the sites. They may subsequently use information about your visit to target you with advertising that you may be interested in, on the sites and other websites. For example, these cookies remember which browsers have visited the sites.

For a particular site, you may see (and opt-out of) what specific cookies are being utilized and placed on your device by checking the “Cookie List” available through the KIRCO Privacy Preference Center, accessible through the cookie banner for the site that you are visiting. We also use clear gifs in HTML-based emails sent to our users to track which emails are opened and clicked on by recipients.

Third-Party Cookies

Third parties may use cookies on your computer or mobile device to advertise through our sites. These third-party companies may use information about your visits to the sites to advertise goods and services that may be of interest to you. They may also employ technology that is used to measure the effectiveness of the advertisements. The third-party companies can accomplish this by using cookies or web beacons to collect information about your visits to the sites. The information collected through this process does not enable us or them to identify your name or contact details unless you choose to provide them. The cookies from these third-party companies vary based on which company is providing the advertisement, therefore they may not be captured in this Privacy Policy.

How To Restrict Cookies

When you visit a site, you can see what cookies are placed or collected and for what purposes by clicking “Manage your Cookies” on the cookie banner. If you are not presented with a cookie banner, please delete your cookies and re-visit the site or click on the cookie symbol within the site, if one is available. Through the cookie banner, you may elect to disable any cookie other than “Strictly Necessary” cookies, which are required for the operation of the site.

Analytics

We use Google Analytics on the site to analyze how individuals use the site. We will package up information about how individuals interact with our site and send it to Google Analytics to be processed into reports. This information includes basic pageviews and visit data such as device type, operating system, and browser type. When Google Analytics processes data, it aggregates and organizes the data based on particular criteria like whether a user’s device is mobile or desktop, or which browser they’re using.

Advertising

We use vendors to advertise online. Their services may come from sites such as Google, Bing, Yahoo, Facebook, Instagram, Twitter, Adroll, and any other display advertising partner to advertise on third-party websites to previous visitors to our site. These vendors may show our ads on websites across the internet.

We also have partnered with third-party advertising networks that collect information about your online web browsing habits to serve you with interest-based advertisements. The information collected about you to serve these ads can include your IP address, unique online identifiers, your activity on our sites and information about your operating system, browser and platform and other technology on the devices you use to access the sites.

The Meta Pixel is a snippet of code that sends data back to Meta about people who uses these sites and allows us to provide custom advertising on Meta properties (like Facebook and Instagram). The data provided to Meta may include information about how you interact with our sites, including your search queries.

Web beacons, pixels, tags and scripts.

In addition to cookies, we use other technologies to recognize and track visitors to KIRCO’s sites. A web beacon (also known as a “tracking pixel” or “clear GIF”) is a clear graphic image (typically a one-pixel tag) that is delivered through a web browser or HTML email, typically in conjunction with a cookie. Web beacons allows us certain functionality, for example, monitoring how users move from one page within a website to another, to track access to our communications, to understand whether users have come to a website from an online advertisement displayed on a third-party website, to measure how ads have been viewed and to improve site performance.

These technologies may be used on our sites or in our emails to help us to deliver cookies, count visits, understand usage of our sites, campaign effectiveness and determine whether an email has been opened and acted upon.

Third-Party/Embedded Content.

These cookies are set by third parties whose content is embedded in KIRCO’s sites (e.g., video). They may track your online activity in order to enhance your experience or assess the success of their application. We have no direct control over the information these cookies collect. Please review the third party’s privacy policy and privacy settings before clicking on embedded content in our site.

Social Media Widgets and Plug-ins.

These plug-ins allow us to integrate social media functions into KIRCO sites and may also be used for advertising purposes by those social media companies. If you visit our site while logged into your social media accounts, information about your visit to our sites, your social media identifier and information about your browser may be provided to those third-party social media companies. You should review the privacy policy of any social media entity with whom you have an account to learn about how they may use your data.

Do Not Track

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. KIRCO does not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available external tools, we offer you the choices described in this Cookies Policy to manage the collection and use of information about you.

4. INTEGRATIONS AND LINKS TO OTHER SITES

This Policy applies only to our sites, and not to other companies’ or organizations’ websites to which we link from our sites. KIRCO is not responsible for the privacy practices or the content of such websites or organizations, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). Other linked websites may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the websites you may visit by linking from our sites. When interacting with these integrations, you should take some time to review the privacy notices contained therein. KIRCO is not responsible for the data collection practices of these third-parties.

For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you provided to them or they collected from your use of their services. This information is stored in Google’s servers according to their privacy practices.

5. HOW LONG WE RETAIN YOUR INFORMATION

We may keep a record of your personal information, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal compliance and data retention policies. Cookies are stored on your own device. You can find out more information about the retention of cookies in our Cookies Policy.

6. MARKETING AND PROMOTIONAL COMMUNICATIONS

You may opt-out of receiving marketing and promotional messages from KIRCO, if those messages are powered by KIRCO, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications relevant to your use of our Services.

7. CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION

The Children’s Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personal information through the sites. If you are under the age of 18 and have already provided personal information through the sites, please have your parent or guardian contact us immediately using the information provided under Contact Us so that we can remove such information from our files. Please delete all KIRCO related cookies and restrict further collection of cookies using the methods outlined in the section How To Restrict Cookies in our Cookies Policy.

8. SECURITY

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you both at our own premises and with the assistance of third-party service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly using the information provided under Contact Us. To ensure that our employees comply with our privacy policies, we have developed a training program that provides all employees with the tools and knowledge to protect your personal information in all aspects of their work.

9. YOUR DATA RIGHTS

There are a number of U.S. states that provide specific consumer rights to residents of those jurisdictions regarding personal information. Based upon the scope of KIRCO’s business and the privacy laws applicable to it, KIRCO will honor data rights requests submitted by residents of Nebraska, Nevada, and Texas who are entitled to them. Please note that if you a resident of California, you have access to special data rights and disclosures that are described in this Privacy Policy under a separate section titled Data Rights For California Consumers.

What Data Rights Do You Have?

If you are a consumer living in Nebraska, Nevada, or Texas you have the following rights with regards to your personal information. These rights are explained in further detail below:

	Nebraska and Texas	Nevada
Confirmation of Personal Information Processing and Access to that Personal Information	X
Correction of Personal Information	X
Portability of Personal Information	X
Deletion of Personal Information	X
Opt-Out of Targeted Advertising using Personal Information	X
Opt-Out of Sale of Personal Information	X	X
Opt-Out of Certain Profiling Using Personal Information	X

Right to Confirmation and Access. You have the right to confirm whether or not KIRCO is processing your personal information and to access such personal information. The general categories of personal information that we collect, process and disclose are listed in the general Policy under the section: What Information We Collect And Disclose And For What Purposes. If you wish to access the specific pieces of personal information that we process about you, please submit a request as directed in the section titled How To Submit A Request.
Right to Correct. You have the right to request that KIRCO correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
Right to Portability. You have the right to request to receive your personal information in a portable and readily usable format, to the extent technically feasible.
Right to Delete. You have the right to request that KIRCO delete the personal information that KIRCO maintains about you.
Right to Opt-Out of Sale/Targeted Advertising. You have the right to request to opt out of KIRCO’s “sale” of your personal information or processing of your personal information for purposes of targeted advertising. “Targeted advertising” generally means displaying advertisements where the advertisement is selected based on personal information obtained from your activities over time and across websites or online applications to predict your preferences or interests.

We may provide your personal information to third parties for “targeted advertising” purposes or in ways that constitute “sales” under applicable laws. If you would like to opt-out of the“sale” of your personal information, you may do so by filling out and submitting KIRCO’s Do Not Sell Request Form. With regards to the “selling” or use of your online browsing information for targeted advertising, you can opt-out by clicking “Manage your Cookies” on the cookie banner of the particular site that you are visiting. Please disable all cookies other than “Strictly Necessary” cookies, which are required for the operation of the site. If you are not presented with a cookie banner, please delete your cookies and re-visit the site or click on the cookie symbol within the site, if one is available. Information on how to delete cookies can be found in the sub-Section titled How To Restrict Cookies.

Even if you opt-out of targeted advertising, you may still see KIRCO ads or ads from our customers or partners because we may advertise through other methods that are not based upon your online behavior.

Right to Opt-Out of Profiling. You have the right to request to opt out of KIRCO automated profiling using your personal information that produces legal or similarly significant effects concerning you. Applicable state laws allow you to opt out of the application of automated profiling when it relates to substantive decision making, such as denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health-care services, or access to essential goods or services. However, we do not profile individuals in a manner that produces legal or similarly significant effects on those individuals.

10. DATA RIGHTS FOR CALIFORNIA CONSUMERS

The California Consumer Privacy Act (“CCPA”) provides the residents of California with the right to request the data rights as described in this section. For more information, or if you have questions, you can contact us using the information provided under Contact Us.

Right to Know: California residents have the right to know what personal information KIRCO has collected about them, including the categories of personal information, the categories of sources from which the personal information is collected in the past 12 months, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom KIRCO discloses personal information, and the specific pieces of personal information KIRCO has collected about them.

The categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for which we collect personal information and the categories of third parties to whom we disclose personal information are found in the Section What Information We Collect And Disclose And For What Purposes.

California residents have a right to know if we are “selling” or “sharing” (which is a term used under California law to address the sharing of information for targeted advertising purposes) their personal information, what categories of personal information are “sold” or “shared,” and to whom. This information is found in the sub-Section, When We May Sell Information Or Use Information For Targeted Advertising.

You may further request to know the specific pieces of personal information collected by KIRCO beyond 12 months into the past, but note that this additional time frame only applies to personal information collected by KIRCO after January 1, 2022, and KIRCO may have deleted your personal information in accordance with our data retention policy.

Right to Delete: California residents have the right to request the deletion of their personal information maintained by KIRCO.

California residents have the right to request that KIRCO delete the personal information that we maintain about them.

Right to Correct: California residents have the right to request that a business correct inaccurate personal information about them.

California residents have the right to request that a business correct inaccurate personal information maintained by the business about them. You may be required to provide documentation to support your assertion that your personal information as maintained by KIRCO is incorrect. If you fail to provide this documentation, your request may be rejected. We reserve the right to delete your inaccurate personal information instead of correcting it, if permitted by the CCPA.

Right to Non-Discrimination: California residents have the right to not be discriminated against due to the exercise of their privacy rights under the CCPA.

California residents have the right to be free from discriminatory treatment by KIRCO for the exercise of their privacy rights. However, the exercise of certain privacy rights by California residents may make it so that we are no longer able to provide those residents with certain services or communications. For example, if, at the request of a California resident, KIRCO deletes all of the California resident’s personal information that it maintains, KIRCO will no longer be able to send communications to that resident.

Right to Opt-Out: California residents have the right to opt-out of the “sale” or “sharing” of their personal information.

California residents can request that a business stop “selling” or “sharing” (which is a term used under California law to address the sharing of information for targeted advertising purposes) their personal information.

If you would like to opt-out of the “sale” or “sharing” of your personal information, you may do so by filling out and submitting KIRCO’s Do Not Sell Request Form. With regards to the “selling” or “sharing” of your online browsing information, you can opt-out by clicking “Manage your Cookies” on the cookie banner of the particular site that you are visiting. Please disable all cookies other than “Strictly Necessary” cookies, which are required for the operation of the site. If you are not presented with a cookie banner, please delete your cookies and re-visit the site or click on the cookie symbol within the site, if one is available. Information on how to delete cookies can be found in the sub-Section titled How To Restrict Cookies.

Even if you opt-out of targeted advertising, you may still see KIRCO ads or ads from our customers or partners because we may advertise through other methods that are not based upon your behavior.

Right to Limit Use and Disclosure of Sensitive Personal Information: California residents have the right to direct a business to limit its use and disclosure of their “sensitive” personal information.

California residents can request that a business limit its use or disclosure of their “sensitive” personal information to that use or disclosure which is necessary to perform the services or provide the goods reasonably expected by an average consumer, or to those uses or disclosures otherwise authorized by California law in CCPA regulation § 7027(m).

However, we do not use or disclose your “sensitive” personal information for any purpose other than for the specific purposes described under the CCPA regulation § 7027(m) and always in a manner reasonably necessary and proportionate for these permitted purposes. For information on how we use or disclose your “sensitive” personal information, please see the applicable disclosures in the section titled: What Information We Collect From You And For What Purposes.

Right to Make Requests Through an Authorized Agent: California residents can designate an authorized agent to make a request under the CCPA on their behalf.

California residents can designate an authorized agent to make requests under the CCPA on their behalf relating to the residents’ personal information. Only you as a California resident, or a person you have designated in writing as your authorized agent, may make a consumer request related to your personal information.

If you wish to have an authorized agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your authorized agent, such as a power of attorney pursuant to California Probate Code sections 4000 to 4465. We will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we have collected personal information.

We can deny any request made by a purported authorized agent who does not submit proof that they has been authorized by the California resident to act on the California resident’s behalf.

Notice of Financial Incentives: California residents are entitled to certain information about KIRCO’s financial incentive programs.

KIRCO may offer you certain financial incentive programs connected to the collection of your personal information that can result in different price, rate, or service levels available to you. We offer these financial incentive programs because the benefits you receive through our programs relate to your personal information’s value to us. Participation in a financial incentive program is voluntary and requires your prior opt-in consent. The details and terms of our various programs will be presented to you in the respective documentation when you enroll in these programs.

You are only enrolled in these programs with your consent, which you may revoke at any time. We collect and use the information that we obtain through these programs to further our business in accordance with our Privacy Policy.

While we do not assign a monetary value to the data that we collect, based on our current estimate, we believe that the value you receive from our financial incentive programs is reasonably related to the value KIRCO receives from your personal information related to these programs. In determining the value of your information to KIRCO, we consider the value to our business, which is reasonably correlated to the value provided to you through both monetary and nonmonetary rewards.

You can opt-out of participation in any of our financial incentive programs at any time. If you wish to opt-out, please submit a request to delete the personal information that KIRCO maintains about you via KIRCO’s Data Rights Request Form. If you submit a request to delete, we will no longer be able to offer the service or product tied to the financial incentive program that you have enrolled in.

11. HOW TO SUBMIT A REQUEST

You can submit your request to exercise your data rights through the below:

Filling-out and submitting KIRCO’s Do Not Sell Request Form;
Filling-out and submitting KIRCO’s Data Rights Request Form;
E-mailing us at info@kirco.com; or
Calling us toll-free number at 833-691-0257.

12. HOW WE PROCESS DATA RIGHTS REQUESTS

Once we receive your request to exercise a right, we will confirm receipt and begin to evaluate, and if appropriate, process the request. Please note that:

We may require that you provide additional information to confirm your identity, including providing us with at least two or more pieces of personal information to match against personal information that we currently maintain about you. We reserve the right to reject your request if we are unable to verify your identity to a sufficiently high level of certainty. The information you provide to verify your identity will only be used for verification purposes, and a record of your request, including certain information contained within it, will be maintained by KIRCO for our files.
To authenticate any request to correct personal information, you may be required to provide authentication information.
Certain laws or other legal requirements might prevent some personal information from being disclosed or deleted.

If you fail or refuse to provide the necessary information, we may not be able to process your request.

If we reject a request for any reason, we will inform you of the basis of the rejection. Not all individuals about whom we possess information will have access to these rights and we may not be able to provide these rights to everyone due to legal and jurisdictional limitations. We may not be able to comply with your request for a number of reasons, including:

you do not live in a state that grants you the specific right that you have requested;
the information that you’ve requested is not subject to the regulation that grants you the right to make a request in relation to your personal information;
we are prevented or exempted by law, regulation or rule from complying with your request;
we do not maintain your personal information in a manner that is connected to your identity;
we are not the owner or controller of the data about which you are requesting;
we are not able to comply with your request without incurring disproportionate burden or expense; or
if complying with your request conflicts our proper and reasonable ability to administer our sites, to administer our business and related relationships or to establish, defend or administer legal claims.

If any of the above reasons apply, we will let you know in our response to your request.

Submitting A Request Through An Authorized Agent

Some states allow you to designate an authorized agent to make a request on your behalf. An authorized agent should make a request through the same mechanisms that are available to individuals as described in this Privacy Policy. The request should clearly identify that the request is being made by an authorized agent and must include evidence of authorization. If we receive a request from an individual or an entity purporting to make the request on behalf of another individual, we can only comply with the request if we are allowed by applicable state law and able to sufficiently authenticate both the identity of the individual as well as the authorized agent’s authority to act on that individual’s behalf.

California has special rules regarding submitting requests through agents, so please review the appropriate disclosure in the section titled Data Rights For California Consumers.

Appeals And Complaints

If you disagree with our decision to reject your request or with any portion of our response, you have the right to appeal within a reasonable period of time. If you wish to appeal, please clearly and plainly describe your basis of disagreement with our decision by responding through the same means by which we communicated our refusal or by submitting your appeal through the information provided under Contact Us. We will review your appeal and either change our decision or reject your appeal, and in either case, we will provide a written explanation of the reason for the decision. This decision will be final.

However, if you still disagree with our decision, you have the right to submit a complaint to your attorney general of your state of residence. Your attorney general may have an online portal with details regarding how to submit complaints.

13. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be revised from time to time as we add new features and Services, as laws change and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide notice on our sites. Changes will apply to information collected after the change is effective. Please check this Privacy Policy periodically for changes. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of the sites constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the sites immediately. If you have any questions about this Privacy Policy, the practices of the sites or your dealings with the sites, you can contact us by using the information provided under Contact Us.

14. CONTACT US

Please contact KIRCO with any questions or concerns regarding this Privacy Policy.

KIRCO
101 W. Big Beaver, Suite 200,
Troy, MI 48084
Email: info@kirco.com
Phone: (248) 680-7180

If you have any questions or concerns regarding our Privacy Policy, or if you believe our Privacy Policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with KIRCO using the contact information listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.

INTERNATIONAL PRIVACY POLICY

The above general Policy still applies to those individuals who reside outside of the United States or who have had personal information collected by KIRCO or its agents in a country other than the United States. However, due to various international regulations, those individuals may be entitled to additional disclosures and rights. This International Privacy Policy (the “International Privacy Policy”) applies to those visiting the site(s) or have interacted with our Services from countries other than the United States except that, for such persons (and only for such persons), where the provisions of the general Privacy Policy and the International Policy cannot be construed consistently, the International Policy will govern.

Please note that by visiting the sites or by having personal information collected by KIRCO, your personal information is being stored or processed in the United States where our data center and servers are located and operated. The United States may not have privacy laws that are as strong or comprehensive as the privacy laws in your own country.

International privacy regulations, such as the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”), the European Union General Data Protection Regulation (“GDPR”), the Australian Privacy Act 1988 (“APA”), and the Brazil General Data Protection Law (Lei Geral de Protecao de Dados Pessoais “LGPD”, collectively with other international privacy laws that are applicable to KIRCO are referred to as “Applicable International Law” ) impose requirements regarding the collection, use, and disclosure of personal data in relation to our commercial activities, as does private-sector privacy legislation in their local jurisdictions, provinces and territories.

THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL DATA ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH A SITE OR OTHERWISE).

In this International Policy, “personal data” or “personal information” is as defined by Applicable International Law. It generally means any information about an identifiable individual.

Our International Policy includes:

Collection Of Personal Data
How We Use Personal Data
The Basis On Which We Process Your Personal Data
Withdrawing Your Consent
Disclosure Of Personal Data And Third-Parties
Limitations
Retention Of Personal Data
Access And Rights To Your Personal Data
Response Time
Costs
Identifying You In Connection With Requests
Opt-Out And Unsubscribe
Accuracy
Safeguards
Contact Us

1. COLLECTION OF PERSONAL DATA

We collect the following categories of personal data about you:

Identifier Information
Demographic Information
Commercial Information
Professional or Employment-Related Information
Financial Information
Sensitive Personal Information (identity information)
Geolocation Information
Internet or Other Electronic Network Activity Information
Device Information

You can find more specific details about the personal data that we collect from you in the section titled What Information We Collect From You And For What Purposes of our general Privacy Policy.

Where we are the data controller with regards to the personal information that we process, you may exercise your rights as a data subject, including the right to object to the processing of your personal information when it is processed based on legitimate interests, as described in this International Policy. Where we are collecting your personal information on behalf of another entity (i.e., we are not the data controller), we will provide you with the identity of the data controller to the extent we are required to do so by law.

2. HOW WE USE PERSONAL DATA

We collect your personal data for the reasons stated in the sections titled What Information We Collect From You And For What Purposes.

3. THE BASIS ON WHICH WE PROCESS YOUR PERSONAL DATA

As allowed by Applicable International Laws, we will only collect and process your personal data as is reasonably necessary for, or directly related to, one or more of KIRCO’s functions or activities.

Where required by Applicable International Laws, we will obtain your consent before processing your personal data. We will only collect, process and share your personal data appropriate to the type of consent that we have received from you. You may provide explicit consent orally, in writing, by electronic communication or any other means reasonably capable of conveying your consent. You may provide your consent impliedly through the continued use of our sites or Services after being presented with this International Privacy Policy or through our customers and partners who have lawfully obtained your consent. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided personal data to us and you maintain your relationship with us or where you provide our representatives with your phone number so that we can contact you. Except when otherwise permitted by law, we will only use the data for the purpose for which it was given.

Where required by Applicable International Laws, and when we act as the controller of your personal data, we rely on the following legal grounds to process your personal data, namely:

Performance of a contract: We may need to collect and use your personal information to enter into a contract with you or to perform a contract or provide services that you have requested from us.
Consent: Where required by law, we will obtain your explicit or implicit consent for collecting and processing of your personal information.
Legitimate interests: We may use your personal information for our legitimate interests of our direct marking, the proper administration and operational of our business, detecting and preventing fraud as well as maintaining the security of KIRCO’s network and information systems.
Legal matters: We may process your personal information when its collection, use or disclosure is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim.

We will only process personal data for a specific purpose or for any other purposes specifically permitted by applicable data protection legislation.

4. WITHDRAWING YOUR CONSENT

As a resident of a country subject to Applicable International Laws, you may have the right to withdraw your consent to KIRCO processing your personal data, subject to certain limitations allowed by applicable law. You can withdraw your consent by filing out the Request Form and send it to KIRCO using the information provided under Contact Us. However, the withdrawal of your consent may adversely affect our ability to provide services to you, keep sending you materials and e-mails or otherwise maintain our relationship.

When your consent is required, you may withdraw your consent at any time (unless withdrawing the consent would frustrate the performance of legal obligations) upon providing to us a 30-day notice.

5. DISCLOSURE OF PERSONAL DATA AND THIRD PARTIES

We may disclose your personal data:

to our marketing and advertising partners
to our payment processing vendors or relevant financial institutions
to our data analytics partners
to database hosting vendors
to our auditors
as part of a corporate transactions
as required for legal purposes
in aggregated, anonymized or de-identified format
to our service providers and vendors
to our affiliates
individuals or entities you authorize

We remain responsible for all personal data communicated to other entities for processing on our behalf. As such, we ensure that other entities that are engaged to provide products or services on our behalf and are provided with personal information are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclose the personal information for any purpose other than the purpose for which the personal information was communicated. You can find more specific details about who we disclose your personal data to the section titled What Information We Collect From You And For What Purposes of our general Privacy Policy.

6. LIMITATIONS

We only collect the personal data necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law. We do not use or disclose your personal data, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.

We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal data beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law.

7. RETENTION OF PERSONAL DATA

We may keep a record of your personal data, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. When personal data is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention practices.

8. ACCESS AND RIGHTS TO YOUR PERSONAL DATA

There are a number of data privacy laws that provide specific data subject rights to residents of certain jurisdictions. This section of this International Policy describes the rights available to those individuals who are entitled to them. Not all individuals about whom we possess information will have access to these rights and we may not be able to provide these rights to everyone due to legal and jurisdictional limitations. We may not be able to comply with your request for a number of reasons, including:

you do not live in a jurisdictions that grants you the specific right that you have requested;
the information that you’ve requested is not subject to the regulation that grants you the right to make a request in relation to your personal information;
we are prevented by law, regulation or rule from complying with your request;
we are not able to comply with your request without incurring disproportionate burden or expense; or
if complying with your request conflicts with the integrity of our services or the ability to administer our business, to administer our business and related relationships or to establish, defend or administer legal claims.

If any of the above reasons apply, we will let you know in our response to your request. Note that we may be required to gather additional information from you in order to process your request. We will only use this information in the context of evaluating and responding to your request. If you fail or refuse to provide the necessary information, we may not be able to process your request.

Subject to the exceptions provided by applicable law or regulation, and depending on your country of residence, you may have the following rights regarding your personal data:

The right to access information maintained about you;
The right to ensure your data is accurate and complete;
The right to erasure, or the right to be forgotten;
The right to restriction or suppression of personal data;
The right to data portability;
The right to withdraw consent if consent was previously provided; and
The right to raise a complaint to the relevant supervisory authority.

You can request to exercise these rights by using the information provided under Contact Us. Please be as specific as possible in your request so that we can meet the applicable handling timelines.

Finally, you have the right to raise a complaint with KIRCO or the appropriate data protection authority of your country of residence if you feel that KIRCO’s processing of your personal information violates your individual rights, is not in line with this International Policy or violates the privacy principals, laws or regulations of your country of residence.

You can contact KIRCO’s data protection office by using the information provided under Contact Us. We will promptly investigate any complaint and will respond within the timeframes describe in this International Policy.
If you are a resident of the European Union, you can find your appropriate data protection authority by following this link.
If you are a resident of Switzerland, you can contact your data protection authority through the information provided in this link.
If you are a resident of the United Kingdom, you can contact your data protection authority through the information provided in this link.
If you are a resident of Australia, you can contact your data protection authority through the information provided in this link. You can view the Australian Privacy Principles through this link.
If you are a resident of Brazil, you can contact your data protection authority through the information provided in this link.
If you are a resident of Canada, you can contact your data protection authority through the information provided in this link.

An interactive map showing the various Data Protection Authorities around the world and how to contact them can be found here.

9. RESPONSE TIMES

We will make every reasonable effort to respond to each of your written requests not later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority with respect to this time limit.

10. COSTS

We expect to be able to respond to your request without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request for transcription, reproduction or transmission of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request

11. IDENTIFYING YOU IN CONNECTION WITH REQUESTS

We may require that you provide to us additional information to identify yourself before we provide information about the existence, use or disclosure of your personal information in our possession. Any such information that you provide to us shall be used only for this purpose.

12. OPT-OUT AND UNSUBSCRIBE

You may opt-out of receiving marketing and promotional messages from us, if those messages are powered by us, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications that are necessary to maintain the existing business relationship between you and KIRCO, to the extent there is one.

We use remarketing services to advertise on third party websites to you after you visited the sites. We and our service providers use cookies to inform, optimize and serve ads based on your past visits to our sites. We only engage in remarketing with your consent through the acceptance of a cookie banner when you access appropriate webpages. You can opt-out of this marketing by deleting all KIRCO related cookies and restrict further collection of cookies using the methods outlined in the sub-Section titled How To Restrict Cookies in our Cookies Policy.

13. ACCURACY

We will use reasonable efforts to ensure that your personal information is kept as accurate, complete and up to date as possible. We do not routinely update your personal information in our possession, unless such a process is necessary. In order to help us maintain and ensure that your personal information is accurate and up to date, you must inform us, without delay, of any change in the data that you have provided to us.

You can at any time, challenge the accuracy or completeness of the personal information we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal information we have on you is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended data to third parties to whom we have communicated your personal information.

14. SAFEGUARDS

We use security safeguards appropriate to the sensitivity of personal data to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment; organizational measures, such as security clearances (limiting access on a “need to know” basis) and publishing this policy to appropriate personnel with instructions to act in accordance with its principles; and technological measures, such as the use of passwords and/or encryption.

15. CONTACT US

You can contact the privacy office of KIRCO at info@kirco.com.