Privacy Policy for Wendy De Rosa, LLC

Effective as of:  April 22, 2024

Last Modified:  April 22, 2024 

Wendy De Rosa, LLC, along with its affiliates, service providers, agents and designees (“We,” “Us,” or “our”), respect your privacy and are committed to protecting the privacy of your personal information.  We have strict policies (this “Privacy Policy”) to ensure that the privacy of your personal information is protected while still enabling you to make use of our website (the “Site”) and our online services (collectively with the Site, the “Services”). This policy details how We use information gathered during your interaction with our Services and the Site.  By using our Services or continuing to do so after any updates to this Privacy Policy, you consent to the practices outlined herein, which also extends to our Terms and Conditions and REFUND AND PAYMENT POLICIES.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how We will treat it. If you do not agree with our policies and practices, you may not use the Services. By accessing or using this Site and/or the Services, you agree to this Privacy Policy.  

What information do We collect?

We may collect personal information from you when you voluntarily provide it to us, such as when you register for our services, make a purchase, or sign up for newsletters.  “personal information” generally means information that may be used, alone or in combination with other information, to personally identify a business or individual.

This information includes, but is not limited to:

  • Basic details:  Name, e-mail address, mailing address, and phone number.
  • Financial and sensitive details:  Social security number, bank account, and credit card processing information.
  • Other:  Any other information you choose to provide Us or details We may gather, either specified in this Privacy Policy or automatically through the use of technologies such as cookies.

Personal Information does not include publicly available information or information that has been de-identified, aggregated, or in a form that is not capable of being associated with or linked to you.

If you provide, or make available, any personal information about any business personnel, administrators, employees, owners, and other authorized persons you must first obtain their consent to disclose such information to Us.  You must inform all such other persons how We process personal information and all other terms of this Privacy Policy.

What do We do with the information We collect?

Any of the information We collect from you may be used in one of the following manners:

  • To compile, save, use, and analyze your information to enhance and optimize our services and ensure We can fulfill our promises and obligations to you, in both personally identifiable and aggregated, non-personally identifiable forms;
  • To operate, maintain, improve, and provide our Services to you, conduct our business, and process transactions;
  • To verify your identity;
  • To register you as a user and identify you when you sign-in to your account;
  • To conduct background checks and determine your eligibility for our products;
  • To personalize your experience and improve customer service (your information helps Us to better respond to your individual needs, your service requests, to send marketing communications and send account update notifications);
  • To provide you with information about our products, services, third-party offers, and other opportunities that We believe may be of interest to you, including on other platforms, and to personalize, measure, and improve such offers;
  • To continually enhance the Site based on the information and feedback We receive from you);
  • To detect, prevent, and address potential fraud, identity theft, security incidents, or other illegal activity; and
  • To comply with our legal obligations; respond to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defense against legal claims.

Security – how do We protect your information?

We prioritize your security and use commercially reasonable efforts to implement reasonable security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. 

It is essential to note that while We strive to protect your personal information, no online transmission or electronic storage method is impervious. Therefore, We cannot ensure or warrant the absolute security of any data or content you transmit to Us. 

In the event of a suspected breach of the security of your personally identifiable information, We will, to the extent required by law, notify you so you can take appropriate protective steps and to inform you of the steps that We are taking with respect to any such suspected breach.

Cookie Policy

We may employ tracking technology (i.e., cookies and similar technologies) to enhance the functionality, efficiency, and security of the Site and our Services. These technologies would also support our advertising efforts, including presenting you with ads on other platforms influenced by your online activities. Rest assured, cookies will not harm your computer or mobile device and do not contain viruses. 

You can control cookies through your browser settings but please note that blocking cookies may negatively impact your experience on the Site, potentially limiting some functionalities.  

We also encourage you to visit the Network Advertising Initiative and/or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for information about opting out of seeing targeted digital advertisements related to cookies.

Do We disclose any information to outside parties?

We do not sell, trade, or otherwise transfer your personal information to third parties without your consent, except as described in this Privacy Policy. 

Below are the following categories of third parties with whom We may share your information:

  • Affiliates, subsidiaries, advisors, and agents;
  • Our service providers, which may include but are not limited to payment processors, advertising and marketing companies, social media companies, technology companies, background check and screening companies, fraud prevention agencies, and credit bureaus;
  • Entities with which We have a business relationship, which may include our partners and collection agencies;
  • Third-party advertising platforms that enable Us to serve targeted digital ads to you about our products and services (“Third Party Advertising Platforms”);
  • Regulatory bodies, governmental authorities, and law enforcement;
  • Any other third-party, but only after obtaining your prior consent to do so.

In addition, We may also disclose your information:

  • As required by law, such as to comply with a subpoena, judicial or administrative order or warrant, and/or any similar legal process;
  • When We believe in good faith that disclosure is necessary to (i) protect our rights or the rights of third parties, (ii) protect our property and safety or the property and safety of others, or (iii) investigate fraud or respond to a request from a governmental entity;
  • If We are involved in a merger, acquisition, transfer, auction (including in a bankruptcy proceeding), or sale of all (or substantially all) of our assets or equity, or of assets related to the divestiture of a particular division or product, in connection with such a transaction;
  • In connection with the sale of delinquent debt for collections purposes; 
  • To affiliates or particular third parties in relation to any of our Services you agree to use; or
  • For business-related purposes, such as for marketing, advertising, or research. 

 Using Third-Party Services and Data Retention

You allow Us to receive information when you use the Services to log in to a third-party website or application (the “Third-Party Platform”).  Please note that We retain the information We receive from your personal profile on the Third-Party Platform while you are logged-in to the Services and even after you have logged-out from the Services if such retention is reasonably necessary to enforce this Privacy Policy and our Terms of Use, in our sole discretion.

We retain personal information for only as long as is needed to deliver the products and services for which it was collected, as consistent with your expressed preferences, or as otherwise needed to achieve the purposes described in this Privacy Policy or required by law.  Users may request to delete data consistent with the rights described throughout this Privacy Policy, including the Your California Privacy Rights section.

DMV INFORMATION

We may collect information about you from state departments of motor vehicles (“DMVs”) for use in the normal course of business to verify the accuracy of information you may submit to Us.  We may redisclose such DMV information only for a permitted use, including for collection purposes.

Data Collection from Minors

This Site is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Site. We do not knowingly collect personal information from anyone under the age of 18. If you believe We may have such information, please contact Us. California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights, below, for more information. 

Links to Other Websites

Our Site may contain links to external websites operated by third parties.  We are not responsible for the privacy practices or content of such third-party websites.  These external websites have their own privacy policies, and We have no control over their content.  We recommend reviewing their privacy policies before providing any personal information.

Your California Privacy Rights

This section applies to any California residents about whom We have collected personal information from any source, including through your use of our Site, by using our Services, or by communicating with Us electronically, in paper correspondence, or in person. For purposes of this section only, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household.  Personal information does not include publicly available information or information that has been de-identified, aggregated, or in a form that is not capable of being associated with or linked to you.

Further, this section does not apply to the personal information We collect that is exempt under California law, including information that is already protected by federal privacy laws (such as the Fair Credit Reporting Act or the Gramm-Leach-Bliley Act).

  1. What Information We Collect

We may collect the following categories of personal information about you:

  • Identifiers, which may include real name and alias; mailing address; unique personal identifier; online identifiers as detailed below; Internet Protocol (“IP”) address; email address; telephone number; account number, name, and password; Social Security number; driver’s license number, passport number, state or other government-issued identification card number; and/or other similar identifiers;
  • Commercial information, which may include records of personal property; products or services purchased, obtained, or considered; account balances, payment history, or account activity; bank account information and other information relating to your financial institution; credit application, credit checks, and information from credit reporting agencies; and/or other purchasing or consumer histories or tendencies;
  • Information relating to Internet activity or other electronic network activity, which may include cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics.
  • Geolocation data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s);
  • Audio, electronic, or visual information, which may include records of calls to or from our customer service centers; and/or video surveillance information; and/or photos of you and your government-issued ID;
  • Professional or employment-related information, such as your current and previous employers; job title and responsibilities; assets; income; and/or other information related to your work history and/or prospective employment;
  • Education information;
  • Inferences about you;
  • Information not listed above and related to characteristics protected under California or federal law; which may include gender; race and ethnicity; nationality; marital status; military service / veteran status; and/or date of birth;
  • Other personal information not listed above and described in California Civil Code § 1798.80(e), which may include signature; physical characteristics or description; insurance policy number; and/or bank account number credit card number, debit card number, and other financial, medical, and/or health insurance information.

Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information We collect may be reasonably classified under multiple categories.

Sensitive personal information.  Certain of the personal information that We collect, as described above, may constitute “sensitive personal information” under California law, including: 

  • Social security number, driver’s license, state identification card, or passport number; 
  • Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account; and
  • Biometric information for the purpose of uniquely identifying a consumer.
  1. What We Do with Your Information

We may collect or use personal information from you for the following purposes:

  • Internal analytics
  • Assessing third-party vendors / service providers
  • Audit, compliance, policy, procedures, or regulation
  • Billing, payment, and fulfillment
  • Customer claims and fraud investigation and prevention
  • Customer communications (including, but not limited to, customer support, surveys or questionnaires, and notifications or information about your account and our products and services)
  • Customer relationship management
  • General business administration
  • Marketing our products and services
  • Marketing the products and services of others
  • Financial reporting and accounting
  • Website optimization and maintenance
  • Systems and data security
  • Maintaining and/or servicing accounts
  • Verification purposes
  • Evaluating applications for employment
  • Identifying, fixing, and troubleshooting bugs and errors
  • Understanding how you use our services so We can make improvements
  • Facilitate business relationships or comply with contractual obligations

Our collection, use and disclosure of sensitive personal information (as defined in the California Consumer Privacy Act Regulations) is generally limited what is reasonable and proportionate for the following purposes: (a) to comply with our legal, regulatory and reporting obligations; (b) to provide services requested by you, to respond to your requests, to make reasonable accommodations where necessary, to verify the information you provide to Us (for fraud prevention, underwriting decisions, and where otherwise necessary to manage and administer your customer relationship); (c) in support of our equal opportunity and diversity and inclusion efforts (on a voluntary basis); (d) where necessary to protect the health and safety of an individual; and (e) to prevent, protect, and take action against malicious, deceptive, fraudulent, or illegal actions, and security incidents. We do not use or disclose your sensitive personal information for any other purpose except as described herein or otherwise permitted pursuant to California law. 

Additional uses are outlined above in the section titled What do We do with the information We collect?

  1. Sources of Collected Information

We may collect personal information from the following categories of sources:

  • Our applicants, prospective customers, existing customers, and their authorized agents, including via our websites, mobile applications, telephone, text message, postal mail, social media, forums, message boards, live chat, chatbot, or other means;
  • Our affiliates, which may include our subsidiaries;
  • Our service providers, which may include customer relationship management providers, analytics providers, website hosting providers, risk and verification service providers, systems administrators, and communications delivery services;
  • Nonaffiliated companies with which we have a business relationship, which may include referral, promotional, and joint marketing partners;
  • Other third parties, which may include technology companies, social media platforms, other websites and mobile applications, online advertising partners, state departments of motor vehicles, and other data suppliers;
  • Things that other third parties may post publicly about you or otherwise provide to Us, which may include review platforms, public forums, and testimonial websites; and
  • Employees and job applicants.

We may supplement the personal information collected from the categories of sources described above with personal information We obtain from other sources.

  1. With Whom We Disclose Information

We will provide your information to our trusted business partners who assist Us in operating the Site, conducting our business (including partners referring you to Us), or servicing your account, so long as those parties agree to keep this information confidential and to limit their use of our information to the requested services.  We also may disclose your information to third parties to whom We may refer you, including our payments processing, banking and financial institution partners, consistent with our notice to you and/or consent from you.  In addition, We may disclose our transactions and experiences with you to credit bureaus.  In the preceding twelve (12) months, We have disclosed each of the categories of personal information described in Section A above for the business purposes described in Section B above.

We do not sell personal information, or otherwise provide personal information to third parties without your prior consent to do so, other than to the extent our use of third-party tracking technologies for advertising purposes may constitute “selling”/ “sharing” as those terms are defined by the CCPA (as described further below).  As with nearly every e-commerce company, We do share a limited set of personal information that is gathered when you visit and interact with our Site, such as cookies and pixels, with Third Party Advertising Platforms in order to allow you to see tailored digital advertisements on those platforms.  We have provided you with opt-out rights as to that “selling”/ “sharing” activity as described in subsections (E) and (F) below. 

In the last twelve (12) months, We have disclosed (or “shared”) the following categories of personal information to advertising partners for cross-context behavioral advertising purposes:  

  • Commercial activity information
  • Identifiers
  • Internet or other electronic network activity information

For more information on who We share information with, please see the above section titled Do We disclose any information to outside parties?

  1. Your Privacy Rights

If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal information:

  • Right to Know (Access). You have the right to request what personal information We collect, use, disclose, and/or sell, as applicable.  You may request We disclose the following to you:
    • categories of personal information collected;
    • categories of sources of personal information;
    • categories of personal information about you We have sold, shared, or disclosed for a business purpose;
    • categories of third parties to whom We have sold, shared, or disclosed for a business purpose your personal information;
    • the business or commercial purposes for collecting, selling, or sharing personal information; and
    • a copy of the specific pieces of personal information We have collected about you.
  • Right to Correct. You have the right to request We correct any inaccurate personal information We maintain.
  • Right to Delete. You have the right to request the deletion of your personal information that is collected or maintained by Us, subject to certain exceptions.
  • Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale/sharing of your personal information by Us.  As described elsewhere in this Privacy Policy, We “sell”/“share” personal information when We participate in behavioral ad networks, and We have provided instructions on how you can opt-out in subsection (F) below.
  • Right to Non-Discrimination. You have the right not to receive discriminatory treatment by Us for the exercise of the privacy rights described above.
  • Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for Us to provide goods or services to you.  We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes. 

The above rights are subject to various exclusions and exceptions under applicable laws. 

If you wish to exercise one of the above rights, We will need to verify your identity and authority, including by providing, at a minimum, your first name, last name, and email address.  Identity verification requires matching pieces of personal information you provide with the information We maintain.  In addition, We may require additional information or steps such as a signed declaration that the requestor is the consumer whose personal information is the subject of the request. 

You may also authorize someone to exercise the above rights on your behalf.  To designate an authorized agent, please submit a request through our support form.  As may be necessary, We will verify that the agent has proper authorization to exercise the above rights on the consumer’s behalf.  

If you are a California resident and wish to seek to exercise these rights, please reach Us in one of the following ways:

  • By emailing Us: info@wendyderosa.com

Direct marketing by third parties. We do not disclose personal information to third parties for their own direct marketing purposes. However, California residents additionally have the right to request information regarding such practices under California’s “Shine the Light” law. Under California Civil Code Section 1798.83, such requests may be made only once a year. If you are a California resident and would like to inquire further, please email info@wendyderosa.com

We will continue to update our business practices as direct regulatory guidance becomes available.

  1. Notice of Right to Opt-Out

We do not currently sell your personal information in the traditional sense, but We do sell/share your personal information, as those terms are defined under the CCPA, by participating in behavioral advertising networks, as described in Section D above.  You may opt-out of such sales/sharing in one of the following ways:

  • By emailing Us: info@wendyderosa.com

We also encourage you to visit the Network Advertising Initiative and/or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements.

Please consult the other sections of this Privacy Policy for further information on our practices regarding your personal information.

Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Colorado, disregarding any conflict of law principles.

Your Consent

By using the Site, you consent to this Privacy Policy and the Site’s Terms of Use and Refund and Payment Policy found here: Terms and Conditions and REFUND AND PAYMENT POLICIES.

Changes to our Privacy Policy

From time to time, We may update this Privacy Policy.  We recommend checking this page periodically to stay informed about any changes. Continued use of the Site and Services after any updates signifies your acceptance of the revised terms. In the event of significant changes to this Privacy Policy, We may, but are not required to, provide advance notice on the Site.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, or if you wish to exercise any of your privacy rights, please contact Us using the methods provided below:

Email: info@wendyderosa.com

Contact Form: https://wendyderosa.com/contact/

Please note that these links are the primary channels for privacy-related matters. For other contact methods or more urgent concerns, refer to our general ‘Contact Us’ page.