Privacy Policy

Last Updated: Sept. 20, 2021

Constant Processing (“Constant Processing,” “we,” “our,” or “us”) is committed to protecting its users’ privacy.  This Privacy Policy is designed to inform users about how we gather and use information collected through the Website (regardless of how users access or use the Website) and through other sources, and under what circumstances we disclose such information. We will take reasonable steps to protect user privacy consistent within this Privacy Policy and applicable laws. This Privacy Policy may be periodically updated from time to time and without notice. Changes are effective upon the posting of the revised Privacy Policy, and user consent to the revised Privacy Policy is given upon use of our Website after posting. Any previously collected personal information will not be used in a manner materially different than indicated at the time it was collected without first obtaining the user’s consent.

Additional privacy policies or practices on our Website shall govern such data collection and use. Please also review our Terms of Use which governs the use of our Website.

By accessing this Website you agree to be bound by the Terms of Use and Privacy Policy.

Scope

Except as set forth in the Privacy Notice for California Residents below, this Privacy Policy applies to how we gather and use information through the Website and other sources. It does not apply to third-party websites which may be linked to our Website and collect personally identifiable information about a user’s online activities, or from collection activities offline. Third-party websites may have their own privacy policies. If you click on a link and visit another website, please be sure to review their privacy policy. We are not responsible for the privacy practices of other websites.

Collection of Personal Information

We may collect the following types of personal information in the following ways:

  • Personal identifiers such as name, address, email address, identification numbers, account information, or other similar identifiers.
  • Information described in California Customer Records Act, such as name, signature, address, telephone number, and payment information.
  • Internet or other network activity, such as IP (Internet Protocol) addresses of computers used to visit this site preserved in the system, and other information such as email addresses, browser types, operating systems, and the URL addresses of sites clicked to and from this site, or if a consumer visits a payment portal.

Personal information we collect is obtained:

  • Directly and indirectly from business clients and consumers, and their agents, such as from information they provide to us in order for us to provide services.
  • From individuals with whom we communicate.
  • From service providers and vendors, who provide goods or services.
  • Directly or indirectly through the Internet and websites, through consumer visits to such sites or submissions.

Sharing and Use of Personal Information

We do not disclose non-public personal information about consumers except as stated in this Privacy Policy, the Privacy Notice for California Residents, as authorized or required by law, or in the following instances:

  • For regulatory compliance.
  • For contractual or legal compliance under state and federal laws.
  • To businesses and clients, service providers, vendors and third parties, in connection with the foregoing.
  • To federal, state and local regulators and other governmental agencies, as may be required.
  • To professional and legal advisors.
  • To law enforcement and other governmental authorities as may be required.

Consent to Contact

By using this Website or providing us with your personal contact information such as address, telephone number, mobile telephone number or email address, you consent to us or our servicers, agents and representatives, assignors and assignees, or third parties contacting you by any such contact method provided, including by an automated dialing device and pre-recorded message call devices, text-messaging, and email.

Confidentiality and Security

We limit access to non-public personal information to those individuals and third parties who have a need to fulfill their business responsibilities, and only for the purpose for which the information is disclosed. Those individuals are required to adhere to confidentiality requirements of a contract, the requirements imposed by law and to the Privacy Policy, as well as being obligated to adhere to our confidentiality policy. We maintain physical, electronic, and procedural security measures to protect your information. You may have other privacy protections under state laws.

Cookies

Cookies are sent to your personal computer when you access the Website that specifically identifies the particular browser being utilized, which are used by us for a variety of reasons, including but not limited to information tracking on how to improve the services being provided by us and tracking user tendencies.  If you do not want these cookies to be used in connection with your system, you may set your browser so that cookies are not accepted and you may also set your browser to notify you when your system has received a cookie, however, some features and services may not function properly if your cookies are disabled.

Do Not Track Disclosures

Web browsers allow consumers the choice on how personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services are collected. This Website may not respond to Do Not Track (DNT) privacy preferences set in user web browsers.

Privacy Notice for California Residents

This Privacy Notice applies only to visitors, users, and others who reside in the State of California, and is provided pursuant to the California Consumer Privacy Act (CCPA).  This Privacy Notice supplements our Privacy Policy.

Your Access Rights

You have the right to request that we disclose the following information to you about our collection of personal information:

  • The categories of personal information we collected.
  • The categories of sources from which personal information was collected.
  • Our business or commercial purpose for collecting personal information.
  • The categories of personal information that we disclosed for a business purpose.
  • The categories of third parties to whom personal information was disclosed for a business purpose.
  • The specific pieces of personal information we collected or disclosed.

Personal Information We Collect

Most of the personal information we collect or maintain is as a Service Provider.  The following categories of personal information have been collected in the past twelve (12) months from consumers:

  • Personal identifiers such as name, address, email address, identification numbers, account information, or other similar identifiers.
  • Information described in California Customer Records Act, such as name, signature, address, telephone number, and payment information.
  • Internet or other network activity, such as IP (Internet Protocol) addresses of computers used to visit this site preserved in the system, and other information such as email addresses, browser types, operating systems, and the URL addresses of sites clicked to and from this site, or if a consumer visits a payment portal.

We will not collect additional categories of or use the personal information collected for materially different, unrelated, or incompatible purposes without providing you notice.

The categories of sources from which personal information is collected are:

  • Directly and indirectly from business clients and consumers, and their agents, such as from information they provide to us in order for us to provide services.
  • From consumers with whom we communicate.
  • From service providers and vendors, who provide goods or services.
  • Directly or indirectly through the Internet and websites, through consumer visits to such sites or submissions.

The business or commercial purposes for collecting personal information are:

  • To provide services to our business customers.
  • For regulatory compliance.
  • To comply with contractual or legal requirements under state and federal laws.

Disclosure of Personal Information for a Business Purpose

We do not and will not sell your personal information.  We do not sell any personal information of minors.

We engage certain parties to perform functions and provide services to us for a business purpose.  We may share your personal information with these parties, but only to the extent necessary to perform these functions or provide such services.  We require that all personal information we disclose to a recipient be maintained in a secure and confidential manner.

The categories of personal information that we disclosed for a business purpose in the preceding twelve (12) months are:

  • Personal identifiers as described in this Notice.
  • Information described in California Customer Records Act.

The categories of third parties to whom personal information identified in this notice may be disclosed to are:

  • Business clients and customers.
  • Service providers, vendors and third parties.
  • Federal, state and local regulators or governmental agencies.
  • Professional and legal advisors.
  • Law enforcement and other governmental authorities as required.

Your Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.  We may deny your deletion request if retaining the information is necessary for us or a service provider to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested or authorized, take actions reasonably anticipated within the context of an ongoing business relationship with you, or otherwise perform a contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act.
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Otherwise use the personal information internally in a lawful manner compatible with the context in which you provided it.
  • An exemption or exception to the requirement to delete personal information applies.

If we deny your request because all of the information collected or maintained about you has been pursuant to our role as a Service Provider, we will provide you with the contact information of the business on whose behalf we collect or maintain the information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge your different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Access and Deletion Rights; Authorized Agents

To exercise your rights to access and deletion described above, you may submit a verifiable consumer request to us in the following ways:

Only you, or an authorized agent on your behalf, may make a verifiable consumer request related to your personal information.  You may also make a verifiable consumer request on behalf of your minor child.  You may only make a verifiable consumer request for access twice within a 12-month period.  The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to requests or provide personal information if we cannot verify your identity or an authorized agent’s authority to make the request, and confirm the personal information relates to you.

We will only use personal information in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will respond to a verifiable consumer request within forty-five (45) days of receiving it.  If additional time is required, we will inform you of the reason and extension period (an additional 45 days), in writing.  Any disclosures we provide will cover just the twelve (12) month period preceding receipt of the verifiable request.  Our response will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with the cost before completing your request.

Contact Information

If you have any questions about this Privacy Policy, the Privacy Notice for California Residents, the ways we collect and use your information as explained here, your choices and rights regarding such use, exercising your rights, or for consumers with a disability who would like to access this information in an alternate format, you may contact us by: