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Your privacy is important to us. It is Pompa Program LLC’s (Pompa) policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website, https://pompaprogram.com/, and other sites we own and operate. This Policy does not apply to information collected or obtained by or through any other means, including from third parties whose website are not owned and operated by Pompa.
Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.
INFORMATION WE COLLECT
Information we collect includes both information you knowingly and actively provide us when using or participating in any of our services and promotions, and any information automatically sent by your devices in the course of accessing our products and services.
Log Data
When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.
Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
Device Data
When you visit our website or interact with our services, we may automatically collect data about your device, such as:
Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
Use of Cookies
We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.
Personal Information
We may ask for personal information which may include one or more of the following:
User-Generated Content
We consider “user-generated content” to be materials voluntarily supplied to us by our users for the purpose of publication on our website and/or social media channels. All user-generated content is associated with the account or email address used to submit the materials.
Please be aware that any content you submit for the purpose of publication will be public after posting (and subsequent review or vetting process). Once published, it may be accessible to third parties not covered under this privacy policy.
COLLECTION AND USE OF INFORMATION
We only collect and use your personal information when we have a legitimate reason for doing so. We only collect personal information that is reasonably necessary to provide our services to you.
We may collect personal information from you when you do any of the following on our website:
We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
Please be aware that we may combine information we collect about you with general information or research data we receive from other trusted sources.
SECURITY OF YOUR PERSONAL INFORMATION
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. We will comply with laws applicable to us in respect of any data breach.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services.
THIRD PARTY WEBSITES
Our Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our Services may provide a link or otherwise provide access to third party websites. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for third party websites, their content, or any goods or services available through the third party websites. Our Policy does not apply to third party websites, and for any data you provide to third party websites, you agree that you are providing at your own risk. A link to a third party’s website, products or services should not be construed as an endorsement. We encourage you to investigate and ask questions before disclosing personal information to third parties and review the privacy policies of any third party websites with which you interact.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We retain and use your personal information for an appropriate period of time as is necessary to fulfill the purposes, for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our Services, to pursue legitimate business purposes, to enforce our agreements, and other business or commercial purposes to the extent provided in this Privacy Policy. We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, or (3) if you ask us to delete your personal information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Data is contrary to our legal obligations or business objectives. When we delete your Personal information, it will be removed from our active servers and databases; but it may remain in our archives when it is not practical or possible to delete it.
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We may disclose personal information to:
LOCATION OF PROCESSING
We have operations in the United States, and personal information may be transferred to, stored, and processed in the United States as well as other countries in which we or our, affiliates, partners, service providers, or agents maintain facilities. By sending us personal information or using the Site or Apps, you agree and consent to the processing of your personal information in locations such as the United States, which may not offer the levels of protection required in other countries. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information, such as express consent, when transfer is necessary for us to deliver services pursuant to an agreement, or when the transfer is subject to safeguards that assure the protection of the personal information. If you are located in Australia and consent to the international disclosure of your personal information pursuant to this Policy and your use of the Site, Apps, or our services, we will not be required to take reasonable steps to ensure the international recipient does not breach the Australian Privacy Principles contained in the Privacy Act.
YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION
You always retain the right to withhold personal information from us, with the understanding that your experience of our website may be affected. We will not discriminate against you for exercising any of your rights over your personal information. If you do provide us with personal information, you understand that we will collect, hold, use and disclose it in accordance with this privacy policy. You retain the right to request details of any personal information we hold about you.
If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time. We will provide you with the ability to unsubscribe from our email-database or opt out of communications. Please be aware we may need to request specific information from you to help us confirm your identity.
If you believe that any information, we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
RESIDENTS OF THE UNITED STATES
Right to Confirmation and Access. Residents of Colorado, Connecticut, Utah, and Virginia have the right to confirm whether we process their personal information and to access such personal information.
Right to a Copy. Residents of Colorado, Connecticut, Utah, and Virginia have the right to access their personal information, including a right to obtain a copy of the consumer’s personal information in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hindrance.
Right to Know. Residents of California have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold or shared and the categories of third parties to whom the personal information was sold or shared; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, selling, or sharing personal information; and (7) the categories of third parties to whom we disclose personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request unless a longer period is requested by you.
Right to Delete. Residents of California, Colorado, Connecticut, Utah, and Virginia have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described herein, we will delete your personal information from our records and notify any service providers or contractors (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.
Right to Correct. Residents of California, Colorado, Connecticut, and Virginia have a right to correct inaccuracies in their personal information, considering the nature of the personal information and the purposes for which we process the personal information. We will use commercially reasonable efforts to correct the inaccurate personal information as directed by you.
Rights Regarding Sensitive Data. We only process sensitive data with your consent or where otherwise permitted by applicable law. Where you have provided consent to this processing, you may revoke your consent or opt out of the processing of your sensitive data at any time. For residents of California, this includes your CCPA right to limit the processing of sensitive personal information to that processing permitted by the CCPA.
Right to Opt-Out. Residents of California, Colorado, Connecticut, Nevada, Utah, and Virginia have the right to direct us to stop selling, and for residents of California, sharing, your personal information to third parties and to refrain from doing so in the future. Residents of Colorado, Connecticut, Utah, and Virginia also have the right to opt of targeted advertising and profiling based on your personal information.
Submission Process. You may submit a request to exercise one of the above rights by emailing info@pompaprogram.com. If a request is submitted in an incorrect manner or if it is deficient, we will either (1) treat the request as if it had been submitted via the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies, as applicable.
Verification Process. We are required to verify the identities of those who submit requests to exercise certain of the above rights. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, email address, address, and/or telephone number. We will inform you if we cannot verify your identity.
If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.
If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.
If we cannot verify the identity of the person making a request to delete, we may deny the request.
If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor. In such cases we may not be required to comply with the request or may request additional information reasonably necessary to verify the request.
Authorized Agents. Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we may not require these actions with respect to confirmed guardianship, conservatorship, power of attorney, or other protective arrangement in accordance with applicable law.
Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.
Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the above rights. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers, employees, applicants, or independent contractors for exercising their rights under applicable law.
Appeals Process. Residents of Colorado, Connecticut, Utah, and Virginia have the right to appeal a refusal to act on a request within a reasonable time after your receipt of the decision. You may submit an appeal to a decision on your request by emailing us at info@pompaprogram.com. We will inform you of any action taken or not taken in response to the appeal, along with a written explanation of the reasons in support of the response.
RESIDENTS OF CALIFORNIA
All terms used in this section shall have the meanings given in the California Consumer Privacy Act (“CCPA”), when applicable.
CCPA Notice at Collection. We collect and process personal information for as described in the “How Do We Collect and Use Personal Information” section of this Policy. The relevant CCPA categories for this information are indicated above. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes.
Data Practices During the Last 12 Months: The disclosures below describe our data practices during the last twelve months:
Personal Information Collected: We have collected the categories of personal information listed below during the preceding 12 months:
Categories of Sources: We have collected the personal information identified in this Policy from you.
Business and Commercial Purposes for Collecting: We have collected the categories of personal information listed above for the following purposes:
Personal Information Sold or Shared: We have sold or shared the categories of personal information listed below during the preceding 12 months. We have sold or shared each category of personal information to the following categories of third parties: (1) subsidiaries and affiliates; (2) distribution partners; (3) advisors (accountants, attorneys); (4) service providers and contractors (data analytics, data storage, mailing, marketing, shipping fulfillment, payment processing, Site and App administration, technical support); and (5) operating systems and platforms. We do not knowingly sell or share the personal information of consumers under 16 years of age.
Business and Commercial Purposes for Selling/Sharing: We have sold or shared to the identified categories of third parties the categories of personal information listed above for the following purposes:
Personal Information Disclosed for a Business Purpose: We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months. We have disclosed each category of personal information to the following categories of third parties: (1) subsidiaries and affiliates; (2) distribution partners; (3) advisors (accountants, attorneys); (4) service providers and contractors (data analytics, data storage, mailing, marketing, shipping fulfillment, payment processing, Site and App administration, technical support); and (5) operating systems and platforms.
Business and Commercial Purposes for Disclosing: We have disclosed to the identified categories of third parties the categories of personal information listed above for the following purposes:
Notice of Right to Opt-out of Sale/Sharing. As a California resident, you have the right to direct us to stop selling or sharing your personal information to third parties and to refrain from doing so in the future.
California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at info@pompaprogram.com.
RESIDENTS OF AUSTRALIA
If you are located in Australia, you have the following rights under the Privacy Act 1988 (Cth) and Australian Privacy Principles. All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.
Right of Access. To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.
Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.
Right to Complain. If you believe we have not processed your personal information in accordance with applicable provisions of the Privacy Principles, we encourage you to contact us. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.
Process. You or your representative may establish your legal right to exercise the above rights by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, account number, address, and telephone number. Within 30 days of your request, we will provide you notice of our determination and act as required under your exercise of rights. Where applicable, we will provide a copy of your personal information in compliance with applicable law.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of Personal information from and about children on the Internet. The Services is restricted to the use of adults over the age of majority in their place of residence. No portion of the Services is directed to children under the age of 18, and no one under the age of 18 may access, browse, or use the Services or provide any information to or on the Services. Consequently, we do not knowingly collect personal identifying information from any person under the age of 18. If we learn that we have collected Personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete that information as quickly as possible. If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with Personal Data, please contact us by following instructions at the “Contact Us” section below.
For more information about COPPA, please visit the Federal Trade Commission’s website at:https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
CHANGES TO THIS POLICY
At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
CONTACT US
For any complaints, questions or concerns regarding your privacy, you may contact us using the following details:
Info | Pompa Program
info@pompaprogram.com
Effective Date: 04/23/2024
Terms & Conditions | Privacy Policy | Cookie Policy | POMPA PROGRAM 2023