Last Updated: [October 22, 2020]
II. INFORMATION COLLECTED BY OUR SITE AND/OR SERVICES.
Data Submitted by User or Visitor of Site and/or Services
When you use our Site or Services, you can (depending on the Services you use) submit information by way of the following:
Engagement Tools and Engagement Data
Our Site also gathers information whenever you visit, log in or otherwise interact with us. As with other websites and interactive services, whenever you interact with our Site, your computer, mobile phone or tablet and its software (a “Device”) transmits a “request” to us. That request includes information received from your Device necessary for us to identify and appropriately route the information your Device is requesting. These “requests” and “replies” are present on all websites and Internet services. Therefore, whenever you:
Our Site also gathers information whenever you visit, log in or otherwise interact with us. In addition to managing the appropriate routing of information, we use so-called “cookies,” “web beacons,” “server logs” and other Engagement Tools (“Engagement Tools”) to enhance the quality of the service and content you receive. For example, we use Engagement Tools to:
Therefore, even if you do not register with us or submit any personal information on our Site, our Engagement Tools automatically receive information about your Device and the software running on it. We call such information Engagement Data (“Engagement Data”).
Engagement Data often includes elements such as the date and time a “request” is made, the model of the Device making the “request,” the type and version of operating system running on a Device, the browser making the request, routing information, IP address, geolocation, search terms a User enters, what URL a Device most recently visited, and, if a mobile application is used, an anonymous unique number. Engagement Data can also include Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement. Engagement Data can be combined with personal information. If so, we treat such combined information the same way we treat personal information.
You have the ability to control how certain Engagement Tools operate by modifying the settings on your Device or its software. Most browsers, for example, allow you to refuse accepting cookies, and many mobile Devices allow you to disable the sending of location information. In some cases, doing these things could diminish the performance of our Site and Services or render them inoperable. To learn more about Engagement Tools and how we use Engagement Data please see the section below entitled “How Information is Used.”
Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser “do not track” signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
Online Tracking By Third Parties
Third-party analytics and other service providers, such as Google Analytics, may set and access their own tracking technologies on your Device and they may otherwise collect or have access to information about you and track you over time and across third party websites. These service providers use tracking technologies to help us analyze how visitors use our Site and Services. We are not responsible for those third party technologies or activities arising out of them. However, some third parties may offer you certain choices regarding their practices.
For example, to learn about opting out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options. If you choose to opt out of the use of Google Analytics, Google will no longer collect and analyze information via cookies associated with your browser for these services. When you opt out, Google will place opt-out cookies on your browser. If you delete your cookies, change browsers, or change devices, you will need to repeat this opt-out process. Also, please note that this opt-out process will work only if your browser is set to accept all cookies. We may still use Google Analytics services to create promotions and apps within social networks after you opt out. These services do not rely on collecting and analyzing information via cookies. To learn more about your choices for these services, review the options your social network provides.
You can obtain information about which third parties have currently enabled cookies and how to opt-out of some of those cookies by visiting the Network Advertising Initiative’s website at http://optout.networkadvertising.org; or the Digital Advertising Alliance’s website at http://optout.aboutads.info. For more information on mobile-specific opt-out choices, please visit https://www.networkadvertising.org/mobile-choices.
Third Party Tools
We work with certain third parties who deploy their own Engagement Tools on our Site (“Third Party Tools”). In some instances they do so exclusively on our behalf. In other instances, they may retain and use the data they collect pursuant to publicly available privacy policies. These Third Party Tools are frequently deployed by companies providing online advertising services or analytics, but they may be deployed in other contexts as well, such as social media plug-ins. We treat personal and non-personal information that we receive from these Third Party Tools the same way we treat personal and non-personal information that we directly collect from our Site. We, however, do not control how these third parties manage the information they gather.
III. PERSONAL AND NON-PERSONAL INFORMATION.
Information you submit to us that identifies you or can be used to contact you (e.g., email or mailing address) is your “personal information.” We collect the following categories of personal information about you:
When we combine non-personal information with personal information, or non-personal information with other non-personal information in a way that renders the combined information personal information, we treat that combined information the same way we treat personal information. When we combine personal information with information from third party sources, we also treat that combined information the same way we treat personal information.
How Information is Used
We use personal and non-personal information (including Engagement Data) for the following purposes:
We use non-personal information for the following purposes:
We may also use non-personal information to prepare aggregate reports for current or future advertisers, sponsors or other partners to show trends about the general use of our Site and/or Services. Such reports may include age, gender, geographic, demographic or other general User information, but do not include personal information.
IV. CONSENTS AND AUTHORIZATIONS.
V. SERVICE EMAILS AND OTHER COMMUNICATIONS.
Our Site and/or Services allow Users to communicate with others through our in-product instant messaging services, Service-branded emails, SMS and other electronic communication channels. Communications that are sent by or on behalf of a User are indicated as being “From” that User. Communications that are sent by us are indicated as being from us or one of our account or support specialists assigned to assist you. Either type of communications may be “real time” communications or communications triggered automatically upon the occurrence of certain events or dates – such as a repeated sign-in failure, an appointment reminder and the like.
Electronic messages received from Users and our administrative announcements are often transactional or relationship messages, such as appointment requests, reminders and cancellations and other Service notifications. You may not be able to opt out of receiving certain messages, although our Site and/or Services may provide a means to modify the frequency of receiving them. In cases in which we believe User emails are not primarily transactional or relationship messages, it will include the capability to opt-out of receiving further e-mails. If you sign-up to receive marketing announcements from us, such emails will include capability to opt-out of receiving such e-mails in the future.
On occasion, we will communicate marketing information, operational updates and other information to Users via electronic mail. Users agree that such transmissions are important means of communication between us and Users and shall not be considered junk faxes or unsolicited advertisements as defined by the Telephone Consumer Protection Act of 1991 or other applicable state or federal laws or regulation.
From time to time we ask Users to complete surveys or otherwise provide input to improve our operations or to assist other Users in making informed choices. The content of such surveys, therefore, should be presumed public. When we make such survey, we let Users know how their responses will be used. As with communities and public forums, we strongly advise Users to exercise care in selecting what information they share in a survey or similar communication, and strongly recommend against sharing any personal financial or other sensitive information that could directly or indirectly be traced to any individual, including yourself.
Our Site may deploy Engagement Tools (such as “cookies,” “web beacons” and “server logs”) on outbound emails to Users and others to collect Engagement Data, and we may use vendors to assist us in sending outbound emails to Users who may deploy Third Party Tools.
Emails and Other Communications
Emails and other communications from individuals who are not users of our
VI. SHARING OF INFORMATION.
We will not share personal information you submit except under the following circumstances:
To limit sharing of personal information where possible, you may submit such requests by contacting us at www.oasisfinancial.com/privacy-rights. We do not sell personally identifiable information, and we will not sell personally identifiable information except as described in this Policy or with your consent. If we ever decide to sell personally identifiable information, we will provide you with notice and a right to opt-out of such sale.
VII. THE IMPORTANCE OF PROTECTING OUR SITE, SERVICES AND THE INFORMATION THEY SAFEGUARD.
Our Site and many of our Services are protected by technical measures intended to safeguard the confidentiality, integrity and accessibility of sensitive information our Users store and share on our Site. Further, certain regulations require us to investigate potential or suspected threats on our Services or the confidentiality, integrity or availability of the information they safeguard. Accordingly, we may preserve, use and disclose information – including personal and non-personal information – when we have a good faith belief it is necessary or advisable to:
We endeavor to make security of our Site and Services and the information they collect, store, process and transmit a top priority. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the information we collect, we deploy a wide range of technical, physical and administrative safeguards, including: Secure Socket Layer (SSL) encryption, firewalls, system alerts and other information system security technologies; housing data in secure facilities that restrict physical and network access; and regular evaluation and enhancement of our information technology systems, facilities, and information collection, storage and processing practices. It is important to remember, however, that no system can guarantee 100% security at all times. Accordingly, we cannot guarantee the security of information stored on or transmitted to or from our Site and Services.
Steps You Can Take
If we learn of a security vulnerability or risk, we may attempt to notify you and provide information on protective measures you may take. There are, however, some precautions that you can proactively take to improve your system security and reduce the likelihood of unintended disclosure of personal information:
IX. CHILDREN UNDER 13.
Without limiting the generality of the foregoing, our Site and Services do allow Users above the age of 18 years old – such as parents and guardians – to submit personal information about others, including minors. Such Users assume full responsibility over their submission, use and transmission of such information.
X. UNITED STATES ONLY.
XI. THIRD PARTY SERVICES.
XII. CHANGES TO THIS POLICY.
XIII. VIEWING, UPDATING AND DEACTIVATING INFORMATION.
Our Site and Services aim to provide you with access to the personal information you submit and the means to update it. This can be accomplished by logging into our Site or Services or contacting us using the contact information below. Under certain circumstances, we may ask you to verify your identity before your request is processed. This will be done free of charge except where it would require a disproportionate effort. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
You should also be aware that we store indefinitely non-personal information, including Engagement Data and de-identified personal information, as well as all information that you have shared on any of our public forums, blogs, communities, surveys and the like.
9525 West Bryn Mawr Avenue, Suite 900
Rosemont, Illinois 60018
Telephone (866) 871-7741
XIV. California Privacy Rights
Under the California Consumer Privacy Act, California residents have the right to:
You may submit such requests by contacting us at www.oasisfinancial.com/privacy-rights or call the toll-free number (866) 871-7741. When calling the toll-free number, you will be required to verify your identify by confirming three of the following pieces of information: name; telephone number; city and state; ZIP code; attorney name or law firm; Case ID or date of loss.
You may also designate an authorized agent to make such requests on your behalf by calling the toll-free number (866) 871-7741.
We will not discriminate against you because you exercise any of your California privacy rights.