Your privacy is important to GoodCitizen Public Benefit Corporation (collectively, “GoodCitizen,” “we,” or “us”) and we are committed to protecting the privacy of your Personal Information.

This privacy policy (the “Privacy Policy”) describes how GoodCitizen collects, uses, maintains, transfers, and shares Personal Information gathered through our website located at http://www.GoodCitizen.com (the “Website”). By visiting the Website you accept and consent to the collection, use, and disclosure of your Personal Information described in this Privacy Policy.

“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 natural individual or a household. We do not consider Personal Information to include information that has been aggregated or de-identified so that it does not allow a third party to easily identify a specific individual.

CANDIDATE PRIVACY POLICY

If you are a candidate or potential candidate whose Personal Information we hold in our database, our Candidate Privacy Policy will apply to you. You may review our Candidate Privacy Policy here: http://www.GoodCitizen.com/candidate-privacy.

WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?

The Personal Information we collect falls into two categories: (1) information you voluntarily supply us when you visit our Website or otherwise interact with us; when you submit your information, such as via a contact form or by corresponding with us by telephone, e-mail or otherwise; when we collect your information in connection with your candidacy; and when you otherwise use our services and (2) tracking, usage, and other information gathered as you visit our Website.

Personal Information You Provide

We obtain certain Personal Information when you provide it to us. The following Personal Information about you may be collected when you interact with us or use our Website or services:

  • Identifying and contact details: Name, phone number, email, physical address, electronic signature, federal or state issued professional identification, date of birth, and demographic information (including age and gender).
  • Employment Information: Job title, professional experience, education, performance history, training records, income, salary, and compensation.
  • Household Information: Number of children and spouse.

This information may be supplied by you in response to specific questions, when you sign up for communications from us, communicate with us in person or by email, participate in our programs, or use our Services. You can always refuse to supply Personal Information in response to requests, except that it may prevent you from engaging in transactions, Website-related activities or receiving responses to your inquiries or other information of interest such as our employment placement programs. Information that is optional at these collection points will generally be noted and marked as such.

Passive Information

GoodCitizen may use third party analytics tools, including Google Analytics, to help us measure traffic, and usage trends by your use of our Website. These tools use various technologies, including cookies or similar technologies, to collect certain information sent by your devices to the Website, including:

  • Your browser name;
  • Demographic data about you;
  • The pages you visit on the Website;
  • Your existing applications;
  • Whether you have previously accessed the Website;
  • The IP (Internet Protocol) address for your computer;
  • Your mobile network information;
  • Navigational data, also known as log files, server logs or clickstream data; and
  • Anonymous IDs for advertising.

Note that these third-party service providers have their own privacy policies addressing how they use such information. To opt out of Google Analytics on the Website go to https://tools.google.com/dlpage/gaoptout.

HOW DO WE USE PERSONAL INFORMATION?

We will only use your Personal Information to the extent allowed by applicable laws. Such use may include, without limitation, to respond to your contact inquiries, provide you with services you have requested and/or customer support, communicate with you about services that may be of interest to you, and develop and improve our services.

Additionally, we analyze Personal Information to help us determine how users access parts of the Website and who our users are. We may use Personal Information to make our Website more interesting and useful to you; for analyzing and improving the value of the material available on our Website; to increase the effectiveness of the Services we will offer to you in the future; and to help our partners and service providers, or our Website design teams, to create, serve, and track promotions our customers might like.

We may use Personal Information we have collected to [enforce our Terms of Use], prevent or respond to fraud, and fulfill legal obligations, such as responding to court orders, subpoenas, or government requests.

By using the Website or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Website or sending an email to you.

HOW DO WE SHARE INFORMATION?

You agree that we have the right to share your Personal Information with selected third-parties including our clients and potential clients, suppliers and sub-contractors for any purpose which relates to the services we provide to you. We will only share your Personal Information for the purposes described in this Privacy Policy. We do not sell your Personal Information to third parties. We may, however, share the Personal Information we collect from you in limited circumstances, including:

  • We may disclose to our service providers and other third parties who process your Personal Information to provide services to us or you including, without limitation, market research; fraud protection; data analysis; email management; and customer service. In some instances, these service providers and third parties may have access to Personal Information, but they are contractually obligated to maintain the confidentiality of the information and to use it only for purposes of carrying out the business of GoodCitizen. These service providers and other third parties can be classified in the following categories:
    • Marketing partners, which we use to send you promotional communications;
    • IT service providers, such as our data hosting provider and companies we employ to manage our Website and to provide Website-related services and/or to assist us in analyzing how our Website is used; and
    • Other service providers that we may engage to provide services to us or on our behalf.
  • We may disclose to any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, in order to enforce or apply our other agreements, or otherwise to protect our rights/property or the rights/property of any third party.
  • We may disclose your Personal Information while negotiating or in relation to a change of corporate control, such as a restructuring or sale of assets. We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.
  • We may share Personal Information with third parties, including but not limited to our clients, potential clients, advisors, advertisers, analytics providers, and investors, for the purpose of conducting our business.

We reserve the right to disclose to third parties non-Personal Information, such as aggregated or de-identified information, for any lawful purpose.

SECURITY

GoodCitizen cares about the security and confidentiality of your Personal Information. We seek to maintain commercially reasonable administrative, technical, and physical security, collection, storage, and processing measures to protect against the unauthorized access, alteration, disclosure or destruction of the Personal Information you submit to us. However, no website is completely secure, error free, or “hacker proof.” You are responsible for taking reasonable steps to protect your Personal Information against unauthorized disclosure or misuse. We cannot guarantee that your use of our Website will be completely safe, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. We are not responsible for third-party circumvention of any privacy settings or security measures.

CHILDREN

We do not knowingly collect or store Personal Information from anyone under the age of 13 unless or except as permitted by law. ANY PERSON WHO VISITS ANY OF THE WEBSITE REPRESENTS TO US THAT HE OR SHE IS 13 YEARS OF AGE OR OLDER. If we are made aware that we have received Personal Information from someone under 13, we will use reasonable efforts to remove that information from our records.

COOKIES AND DO NOT TRACK

Cookies

GoodCitizen uses cookies and similar technologies to collect information for the purposes outlined in this Privacy Policy. A cookie is a small data file that our server sends to your browser when you visit the Website. The use of cookies helps us to assist your use of certain aspects of the Website. You may be able to set your Internet browser to disable, turn the cookie feature off, or reject cookies entirely by changing the settings. Changing these settings, however, may affect your ability to use certain features and functions of the Website. Please note that by visiting the Website you are consenting to the use of cookies.

The Website may also use other technologies including but not limited to JavaScript tags or tracking pixels to collect, process, and store browsing information as described above. Tracking pixels and tags assist in delivering cookies and allow us to collect browsing information about you. Tracking pixels or tags may also be included in the emails we send you in order to determine whether the emails have been opened and if you have clicked on links with the email.

The Website uses first party cookies (set by GoodCitizen) and third-party cookies (set by web analytics partners). The cookies used on our Website may be persistent or session based. A session cookie is a piece of information that is enabled only during a particular Website session. Session cookie files are deleted after logging off the internet browser or powering off your computer. In contrast, a persistent cookie is not deleted after logging off an internet browser or powering off your computer, but “persists” between sessions. Both types of cookies provide statistical information as well as help make improvements in Website navigation.

Do Not Track

Some browsers offer a “Do Not Track” feature, which allows you to signal a website not to track you. Our Website does not currently respond to browser Do Not Track signals.

WHERE WE STORE YOUR INFORMATION

The information collected by GoodCitizen is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing the Website from other jurisdictions, please be advised that you are transferring your Personal Information to us in the United States where data protection and privacy laws may be less stringent than the laws of your country. BY USING OUR WEBSITE, YOU CONSENT TO THE TRANSFER AND USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

DATA RETENTION

Except to the extent prohibited by law, and subject to this privacy notice, we will retain your information for as long as needed to provide you with the Services, for GoodCitizen’s valid business purposes, and as necessary to comply with our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements.

Where we process Personal Information for marketing purposes or with your consent, we process the data until you make us aware by unsubscribing to future contact. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your Personal Information so that we can respect your request in the future.

Where we process Personal Information to meet legal requirements, we hold this for as long as the law requires (for example, we may hold records to help prevent fraud and other prohibited or illegal activities).

PRIVACY RIGHTS

Nevada Privacy Rights

We do not sell Personal Information for monetary consideration.  Nevada residents have the right to submit a verified request directing us not to sell their Personal Information. If you are a Nevada resident, and would like to submit such a request, please send your request to info@goodcitizen.com.

California Privacy Rights 

We do not share personal information (as defined by California Civil Code §1798.83) with other people or non-affiliated businesses for their direct marketing purposes. We are not currently selling your Personal Information and have not sold your Personal Information since January 1, 2020, the date the California Consumer Privacy Act of 2018 (“CCPA”) went into effect.

Under the CCPA, California consumers have the right to request:

  • the deletion of the Personal Information we have about them;
  • additional information about whether and how we have collected, used, disclosed, and sold Personal Information about them; and
  • the specific pieces of Personal Information we have about them.

California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed above.

California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agent must follow the process described below to make a request. The authorized agent must also verify his/her own identity. We will confirm the agent’s authority with the California consumer about whom the request was made.

As required by the California Online Privacy Protection Act (“California Act”) and the California Business and Professions Code, this Privacy Policy identifies the categories of personally identifiable information (as that term is defined above and in the California Act) that we collect through our Site about individual consumers who use or visit our Site and the categories of third-party persons or entities with whom such personally identifiable information may be shared. See more about the California Act at http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

Privacy Rights for Residents of the European  Economic Area (“EEA”)

EEA residents have certain rights regarding their Personal Information under the GDPR. These rights include:

Right to Request Access

You may request details of Personal Information which we hold about you. Upon request, we will provide a copy of such personal information within a reasonable timeframe, generally within 1 month.

Right to Rectification

If you believe that any Personal Information we are holding on you is incorrect or incomplete, please contact us as soon as possible, at the address below. We will promptly correct any personal information found to be incorrect.

Right to Object

You may choose to object to the collection or use of your Personal Information:

  • whenever information is processed for the legitimate interest of GoodCitizen.
  • whenever information is processed for a task carried out in the public interest or in the exercise of official authority vested in GoodCitzen.

Please note that your objection may be overridden by the legitimate interests of GoodCitizen to process and collect your Personal Information.

You also have the right to object to the processing or your Personal Information for direct marketing purpose.

Right to Erasure

To the extent legally permissible, you may be entitled to have certain Personal Information erased in the following circumstances:

  • The Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.
  • You object to the collection or use of your Personal Information and there are no overriding legitimate grounds for the processing.
  • The Personal Information has been unlawfully processed.
  • The Personal Information has reached the defined retention period to be erased or for compliance with a legal obligation to which GoodCitizen is subject.

Right to Restriction of Processing

You may have the right to restrict further processing of your Personal Information in the following situations:

  • You contest the accuracy of the Personal Information.
  • The processing of the information is unlawful.
  • The Personal Information has reached the defined retention period of GoodCitizen and we no longer needs the personal information for the purposes of the processing, but you require the Personal Information to establish, exercise, or defend legal claims.
  • Your objection to the processing may be restricted pending the verification of whether GoodCitizen’s legitimate grounds override your rights as a data subject.

Right to Portability

You have the right to receive your Personal Information in a structured, commonly used and machine-readable format. GoodCitizen will assist in the transmission of such data to another entity, upon request, to the extent technically feasible.

Right not to be subject to Automated Decision-Making or Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

How You Can Exercise Your Rights

GoodCitizen takes reasonable steps to help ensure that the Personal Information we collect from you is accurate, complete and current. You may submit a privacy rights request to us by:

When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will only use the information received in a request for the purposes of responding to the request.

PRIVACY POLICY CHANGES

We may, in our sole discretion, change this Privacy Policy from time to time. Any and all changes to this Privacy Policy will be reflected here and the date new versions are posted will be stated at the bottom of this Privacy Policy. If we make material changes in how we use Personal Information, we will notify you by means of a notice on this Website or, where appropriate, by email if you have provided your email address to us.

LINKS TO THIRD-PARTY WEBSITES

Our Website may contain links to other third-party websites. This Privacy Policy does not apply to the practices of other websites, and GoodCitizen is not responsible for the actions and privacy policies of third parties. We encourage you to be aware of when you leave our Website and to read the privacy policies of each website that you visit.

CONTACT US

If you have any questions, comments, or requests regarding this privacy policy and how we process Personal Information, please contact us at info@goodcitizen.com.

This Privacy Policy was last updated on, and is effective as of, October 22, 2020.