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Privacy Policy - Your Privacy Rights

This Privacy Policy (“Policy”) describes how Paciolan, LLC treats personal information on our websites and platforms where the Policy is located (the “Platform”). This Platform is operated in the United States and Canada and intended for use by individuals who are located in those countries.

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This Policy does not apply to personal information collected directly by the organizations to which we provide our products and services, including colleges and universities, or any personal information that we collect on behalf of our customers. We do not control how these organizations collect, use and share your personal information. If you have questions about the privacy practices of those organizations, please contact them directly.

  • We collect, and in the past 12 months have collected, the following categories of information from and about you: identifiers; commercial information; internet or similar network activity; professional information; and education information. We collect these categories of information from you in order to provide our services to you, to run our business, to communicate with you, and as required by law. We may have disclosed each of these categories of personal information for a business purpose as described below. We have not “sold” or “shared” personal information in the past 12 months, as those terms are defined by the CCPA. 

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    We will retain each of these categories of personal information based on several factors, including as reasonably necessary to (i) provide our products and services or administer our relationship with a consumer; (ii) protect our business, employees, organization, and others; (iii) fulfill our legal and regulatory obligations; and (iv) investigate and address issues which may include safety concerns, potential security incidents or policy violations.

  • We collect information from you and about you. Here are some examples of the information we may collect:

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    • Contact Information. For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.

    • Information You Submit. We may collect information when you send us a message through the “Contact Us” page or similar features on our Platform.

    • Employment Information. For example, we may collect your resume, employment history, and references.

    • Commercial Information. We may collect personal information that could identify you and relates to the services in which you are interested or have considered.

    • Professional Information. For example, we may collect the name of your company, your title, and your professional contact information.

    • Account Information. Certain portions of the Platform allow you to create a user account. In connection with that account, we may collect your username and password.

    • Device Information. For example, we may collect the type of device you use to access our Platform. We may also collect your device identifier, IP address or mobile operating system. We may collect information relating to your general location based on your IP address.

    • Other Information. If you use our website, we may collect information about the browser you are using. We might look at what site you came from, or what site you visit when you leave us.

  • We collect your information in different ways. Below are some examples of how we may collect your information.
     

    • Directly From You. For example, when you:

      • Register for an account.

      • Become a client.

      • Sign up to receive our communications.

      • Contact us.

      • Submit information on the Platform.

      • Interact with our social media pages.

      • Apply for a job.

    • Passively. For example, when you visit and navigate our Platform on any device. We may also collect information about users over time and across different websites and devices when you use the Platform.

    • From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from our business partners, including analytics vendors.

    • By Combining Information. For example, we may combine information that we collect offline with information we collect through our Platform. We may also combine information we collect about you from the different devices you use to access our Platform.

  • Examples of how we may use your information include:

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    • To Run and Improve Our Platform and Business. We may use your information to make our Platform and business better. This may include compiling demographic statistics to better understand our clients.

    • To Respond to Your Requests or Questions. This may include responding to your feedback.

    • To Communicate With You. We may communicate with you about your account or our relationship. This may include providing you with the products, promotions, services, newsletters, and information you request. We may also contact you about this Policy or our Platform terms and conditions.

    • For Marketing Purposes. We may provide you with information about our company and our business initiatives. For more information about your choices related to these communications, see the Choices section below.

    • For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform.

    • As Otherwise Permitted By Law or As We May Notify You.

    • As Requested or Directed By You.

  • We may share your information in the following ways:
     

    • Internally. We may share your information with our parent, subsidiary, and affiliate entities.

    • With Our Service Providers. We may share your information with third parties who perform services on our behalf. For example, this may include companies that send emails on our behalf or help us run our Platform.

    • With Our Business Partners. For example, we may also share personal information with social media sites, advertisers, media buying agencies, advertising networks and advertising service providers for the purposes described in this Policy. We may also share personal information with companies that help us learn more about our customers.

    • With Any Successors to All or Part of Our Business. For example, if we merge with, are acquired by, or sell part of our business to another entity. This may include an asset sale, corporate reorganization or other change of control.

    • To Comply With the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests. We might share information when we are investigating a potential fraud.

    • For Other Reasons We May Describe to You.

    • As Requested or Directed By You.

  • The Platform where this Policy is located is meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 13, and strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). If you are a parent or legal guardian and think your child under 13 has provided us with information, please contact us at legal@paciolan.com. You can also write to us at the address listed at the end of this website Policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.

  • You have certain choices about how we use your information. Certain choices you make are browser and device specific.
     

    Marketing Communications:

    You can opt out of receiving our marketing communications. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.

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    Cookies & Other Tracking Technologies:

    • Cookies: You can adjust your browser to control cookies to require your affirmative acceptance for new cookies, automatically reject cookies and/or delete or disable existing cookies. How you do so depends on the type of cookie and the browser that you are using. For more information on how to control browser cookies, click here. If information about your browser is not available through this page, please search your browser for instructions about how to opt-out of cookie collection.

    • Flash Cookies: You may need to take an additional action to manage flash cookies, which you can learn more about here. Why? Because flash cookies cannot be controlled through your browser settings.

    • Google Analytics: We may use Google Analytics on our Platform to help us understand how you use our Platform. You can learn about how to opt-out of Google Analytics here.

    • Social Media: We may use cookies or pixels from social media platforms to help us understand how you use our Platform or to target ads to you. For example, these may include cookies or pixels from YouTube, Meta, Instagram, LinkedIn, X, and TikTok. For more information about how to control tracking from these platforms, please click the provided links.

    • Email Tools: You can also change your email settings to block the automatic download of images in email messages, as such images may contain technologies that help us understand how you interact with the message.

    • Note that deleting or blocking cookies may impact your experience on our website, as some features may not be available. Certain options you select are browser and device specific.
       

    Our Do Not Track Policy:

    • Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.  If you block cookies, certain features on our sites may not work.  If you block or reject cookies, not all of the tracking described here will stop.

    • Options you select are browser and device specific.

  • Based on your state of residence, you may have the rights listed below with respect to the personal information that we maintain about you. We may take steps to verify your identity, as permitted or required under applicable law, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.

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    • Notice. This means that you can request that we disclose what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we have disclosed personal information, and the specific pieces of personal information we have collected about you.

    • Deletion. This means that you can request that we delete personal information about you which we have collected from you.

    • Correction. This means that you can request that we correct inaccurate personal information that we maintain about you.

    • Limit the Use or Disclosure of Sensitive Personal Information. The California Consumer Privacy Act (“CCPA”) provides a right for consumers to request that business limit the use or disclosure of their “sensitive” personal information. In our normal business operations, we do not process “sensitive personal information” as that term is defined under CCPA. Please do not submit this information to us.

    • Opt-Out of the Sale or Sharing of Personal Information. You may have the right to opt out of the “sale” or sharing of personal information with third parties for cross-contextual marketing purposes. We do not knowingly “sell” or “share” any personal information, including any personal information relating to consumers under the age of 16, as we understand those terms to be defined under applicable law.

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    Agents that you have authorized to act on your behalf may also submit requests as instructed below. The agent must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.

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    Individuals who wish to exercise their rights under this section can contact us at legal@paciolan.com. Please include your name, email address, state of residence, and indicate you are making a “Privacy Rights” request. If we deny your rights request and you would like to appeal, you may contact us at legal@paciolan.com.

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    In addition, if you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at legal@paciolan.com. Indicate in your email that you are a California resident making a "California Shine the Light" inquiry. Note that, as of the date of this policy, we have not shared personal information with a third party for its own marketing purpose in the previous 12 months.

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     Note that this section does not apply to personal information that we collect for or on behalf of our business customers, including colleges and universities, in connection with our provision of our products and services to those customers. If you have questions about the privacy practices of our customers or wish to exercise your privacy rights with respect to the personal information that we collect on their behalf, including colleges and universities, please contact them directly.

  • We have adopted reasonable security procedures to help protect against loss, misuse, and unauthorized access to the information we collect and receive. Please note that no data transmission or storage can be guaranteed 100% secure. As a result, while we strive to protect the information we maintain, we cannot guarantee or warrant the security of any information collected on our Platform. We also cannot be responsible for the theft, destruction, or inadvertent disclosure of information.

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    ​You are responsible for maintaining the confidentiality of your account password and for any access to or use of the Platform using your password, whether or not authorized by you. Please notify us immediately of any unauthorized use of your password or account or any other breach of security.

  • Paciolan is based in the United States, and, regardless of where you use our Platform or otherwise provide information to us, the information may be transferred to and maintained on servers located in the U.S. Under United States law, your information may be subject to access requests from governments, courts, or law enforcement in the United States.

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    We may also transfer your information to other countries and make it accessible to any of our affiliates and third-party service providers internationally. By using our Platform and providing your information to us, you understand and agree that your information may be sent to other countries including those which do not provide an equivalent level of information protection as the laws in your country of residence.

  • The Platform may contain links to other websites or online services that are operated and maintained by third parties. If you click on a link to a third-party site, you will be taken to a site we do not control. This Privacy Policy does not apply to this third-party content. We encourage you to review the privacy policies of these third-party websites or services. We are not responsible for these third-party sites.

  • If you have any comments or questions, you may send an e-mail to our Compliance Department at paciolancompliance@paciolan.com.

     

    You may also write to us at the following address:

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    5291 California Ave, Suite 100

    Irvine, CA 92617

  • We may modify this Privacy Policy at any time by posting revisions to the Platform and revising the effective on this policy date. We may also provide you with notice where required by law. We encourage you to periodically review this statement to be informed of how we are protecting your personal information.

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