Privacy Policy

Privacy Policies

Best Reviews Hub LLC

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GENERAL

Best Reviews Hub LLC (“Company” or “we” or “us” or “our”) is publishing this Privacy Policy for its users (“user” or “you”) that use our website located at consumeradvise.org, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that Company may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should review any changes since the last time you used the Website.

Notice to Users Outside the United States

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you may be viewed as transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet (including personal data collection, use and disclosure), different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website. Further, note that your jurisdiction may offer a more limited or different level of protection with respect to the privacy of your data.

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

Users of the Website Generally

“Non-Personally Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person.

Like most website operators, Company gathers from users of the Website Non-Personally Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally Identifying Information, it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company analyzes Non-Personally Identifying Information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use.

From time to time, Company may also release the Non-Personally Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.

Web Cookies

A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We use cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate purchase procedures. Company also uses Web Cookies to track the pages that users visit during each Website session, both to help Company improve users’ experiences and to help Company understand how the Website is being used. As with other Non-Personally Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the Website is being used. COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES MAY LOSE FUNCTIONALITY OR USE OF CERTAIN FEATURES OF THE WEBSITE.

“Device fingerprinting” can track devices over time, based on your browser’s configurations and settings. Because each browser is unique, device fingerprinting can identify your device, without using cookies. Since device fingerprinting uses the characteristics of your browser configuration to track you, deleting cookies won’t help. Device fingerprinting technologies are evolving and can be used to track you on all kinds of internet-connected devices that have browsers, such as smart phones, tablets, laptop and desktop computers. For more information please see: https://www.consumer.ftc.gov/articles/0042-online-tracking

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Website. These companies may use information about your visits to the Website and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third-party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the instructions and linkshere: http://www.networkadvertising.org/choices/ and http://preferences-mgr.truste.com, or http://www.aboutads.info/choices. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.

We may allow advertisers to choose the characteristics of users who will see their advertisements, and we may use any of the Non-Personally Identifying Information we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. We do not identify you to the advertiser.

Web Beacons

A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally Identifying Information. They are a technique Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.

Analytics

We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Website, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads help (https://support.google.com/ad/answer/262922?hl=en).

Aggregated and Non-Personally Identifying Information

We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

In addition, Company may make use of de-identified information in accordance with applicable privacy law.

Mobile Device Additional Terms

  • Mobile Device. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
  • Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for Company to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.
  •   Push Notifications. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
  • Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally Identifying Information you submit within the mobile application.

SOCIAL MEDIA 

We may provide you the option to connect your account on the Website to your account on some social networking sites for the purpose of logging in, uploading information or enabling certain features on the Website. When logging in using your social network credentials, we may collect the Personally Identifying Information you have made publicly available on the social networking site, such as your name, profile picture, cover photo, username, gender, friends network, age range, locale, friend list and any other information you have made public. Once connected, other users may also be able to see information about your social network, such as the size of your network and your friends, including common friends. By connecting your account on the Website to your account on any social networking site, you hereby consent to the continuous release of information about you to us. We will not send any of your account information to the connected social networking site without first disclosing that to you. Each social network may further allow you to set privacy controls around your information on their system, and our collection of information will always follow such controls and permissions. This feature is subject to continuous change and improvement by us and each social networking site involved, and therefore the available features and shared information are subject to change without notice to you.

We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.

COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION

Website Registration

As defined above, Personally Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally Identifying Information from and about Website users. Much of the Personally Identifying Information collected by Company about users is information provided by users themselves when (1) registering for our service, (2) logging in with social network credentials, (3) participating in polls, contests, surveys or other features of our service, or responding to offers or advertisements, (4) communicating with us, (5) creating a public profile or (6) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic or relevant information as determined by Company from time to time. Users of the Website are under no obligation to provide Company with Personally Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.

BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Online Postings

Certain Personally Identifying Information collected from users may be disclosed as a matter of course as a result of your use of the Website. We may provide areas on the Website where you can post reviews and other information relating to your activities on the Website. Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.

Company Communications

We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though this may not opt you out of all emails, such as notices about your account, including service announcements and administrative messages.

General Use by Company

Company uses the Personally Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website (1) to deliver the products and services that you have requested; (2) to manage your account and provide you with customer support; (3) to communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties; (4) to develop and display content and advertising tailored to your interests on the Website and other sites; (5) to resolve disputes and troubleshoot problems; (6) to measure consumer interest in our services; (7) to inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud and other criminal activity; (10) to enforce our Terms of Use; and (11) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on the Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed to manage our business.

Company Disclosures

Company will disclose Personally Identifying Information under the following circumstances:

  •   By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose Personally Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
  •  Marketing Communications.Unless users opt-out from receiving Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If you wish to opt-out of receiving marketing materials from Company, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable) or contacting us using the contact information below.
  • Third-Party Service Providers. We may share your Personally Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
  •  Business Transfers; Bankruptcy. Company may disclose all Personally Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.
  • Employees, Contractors, and Consultants:  Some Company employees and operations contractors, and consultants may have limited access to your Personal Information in the course of providing services to you, including for the purpose of troubleshooting problems and/or resolving complaints. These contractors include vendors and suppliers that provide us with technology, services, and/or content for the operation and maintenance of the Website. Access to your Personal Information is limited to the information reasonably necessary for the employee or contractor to perform the function needed to resolve the issue or to provide or improve the service.

Your Ability to Change Personally Identifying Information; Account Termination

You may at any time review or change your Personally Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below.  Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some Personally Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your Personally Identifying Information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.

Children’s Personally Identifying Information

The features, programs, promotions and other aspects of our service requiring the submission of Personally Identifying Information are not intended for anyone under 13 years of age. We do not knowingly collect Personally Identifying Information from children under the age of 13 other than minor children receiving the service through registration by their parent or legal guardian. If you are under 13 then you may not use or access our website or services at any time or in any manner.  If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed Personally Identifying Information to us please contact us at [email protected] A parent or guardian of a child under the age of 13 may review and request deletion of such child’s Personally Identifying Information as well as prohibit the use thereof.

SECURITY

We use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse.  However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.

We are dedicated to protect all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

Despite our efforts to protect your Personally Identifiable Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.  We do not utilize encryption systems for emails from us to you.  Therefore, we make no representations or warranties regarding the sufficiency of the above security measures. No data transmission over the Internet or through mobile devices can be guaranteed to be 100% secure. While we strive to protect your personal information from unauthorized access, use or disclosure, we cannot ensure or warrant the security of any information you transmit to us on the Website.  There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Therefore, the Company is not responsible for any actual or consequential damages that result from a lapse in compliance with this Privacy Policy because of a security breach or technical malfunction.

PRIVACY POLICY CHANGES

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the Website. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, at least once a year and free of charge, information about the Personally Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.

DO-NOT-TRACK POLICY

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. The Website does not currently respond to DNT browser signals or mechanisms.

QUESTIONS OR COMPLAINTS

If you have any questions regarding our Privacy Policy or complaints regarding your privacy rights, please submit your complaint in writing our Privacy Officer at:

 

Best Reviews Hub LLC
Attn: Privacy Officer
Twin Oaks Valley Rd. #1689
San Marcos, CA 92069

Email: [email protected]
Phone: 703-972-2383

We will not retaliate against you for filing a complaint.

In addition, you can complain to:

Secretary of the U.S. Department of Health and Human Services
Office of Civil Rights
200 Independence Avenue, SW
Room 509F, HHH Building
Washington, D.C. 20201

For additional information, call U.S Office of Civil Rights at (800) 368-1019 (Voice) or (800) 537-7697 or via Fax: (202) 619-3818 or email: [email protected], or contact your local Office of Civil Rights of the U.S. Department of Health and Human Services: https://www.hhs.gov/ocr/about-us/contact-us/index.html#ocr-regional-offices.

EFFECTIVE DATE

This Privacy Policy is effective as of February 3, 2022, and, was last updated on February 3, 2022.

Changes to this Notice

If we change the terms of this Privacy Policy, then we will post the new Privacy Policy on our Website. Any new Privacy Policy will apply to all the information that we maintain, including information that was created prior to the change.


Note to Clients—About the California Consumer Privacy Act of 2018

Introduction: The California Consumer Privacy Act of 2018 (CCPA), Cal. Civ. Code 1798.100 to 17989/199 contains requirements applicable to certain businesses and requires specific disclosures additional to those in the regular Privacy Policy. Because CCPA’s requirements are extensive, we provide a separate disclosure form.

To Whom CCPA Applies: Significantly, CCPA gives the consumer the right to request that a “business that collects a consumer’s Personal Information disclose to that consumer the categories and specific pieces of Personal Information the business has collected.” 1798.100(a).

In Section 1798.140(c)(1), CCPA defines “business” as:

(1) A sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that collects consumers’ Personal Information, or on the behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ Personal Information, that does business in the State of California, and that satisfies one or more of the following thresholds: (emphasis added)

(A) Has annual gross revenues in excess of twenty-five million dollars ($25,000,000), as adjusted pursuant to paragraph (5) of subdivision (a) of Section 1798.185.

(B) Alone or in combination, annually buys, receives for the business’ commercial purposes, sells, or shares for commercial purposes, alone or in combination, the Personal Information of 50,000 or more consumers, households, or devices.

(C) Derives 50 percent or more of its annual revenues from selling consumers’ Personal Information.  (emphasis added)

Under 1798.140(t): “Sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party for monetary or other valuable consideration. (emphasis added) However, there are a number of exceptions which we can discuss with you; note that this is an evolving area, and unclear with respect to the telemedicine arena. Having the CCPA disclosure is precautionary, and while we will advise, companies will make their own business judgment with respect to compliance and enforcement risk.

An entity that “controls” or is “controlled” by, and ‘shares common branding with,” a business, is also a “business.”  (1798.140(c)(2)).

The CCPA applies not only to information collected electronically on the Internet, but also to the collection and sales of all information a business collects from consumers (1798.175).

Review & Update: Covered businesses must review and update the California-specific privacy notice’s content at least every 12 months (Cal. Civ. Code § 1798.130(a)(5)). The business should also establish practices or procedures that ensure legal counsel learns when activities occur that then require revising the notice, such as: Collecting, disclosing, or selling new or different categories of Personal Information; Disclosing or selling Personal Information to new or different categories of third parties; Using, disclosing, or selling Personal Information for new or different purposes; Selling Personal Information for the first time.

How to Work with This Form: Carefully review each and every section as it is very fact dependent on your specific business practices.  Let us go over these with you during a call.

CMIA Requirements: Note the CCPA’s requirements do not apply to “medical information” subject to the California Confidentiality of Medical Information Act (CMIA) or to “protected health information” (PHI) collected by covered entities and business associates under the HIPAA Privacy, Security and Breach Notification Rules. Moreover, providers of health care subject to CMIA and covered entities subject to HIPAA are not covered businesses under CCPA if they maintain all patient information in the same manner they maintain “medical information” or “protected health information” subject to CMIA and HIPAA, respectively. CCPA also exempts information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act or the California Financial Information Privacy Act as well as other exemptions.

However, businesses potentially might be subject to CMIA and/or HIPAA with respect to medical information or PHIrespectively; and also, subject to CCPA with respect to other information.  We can discuss with you.

Penalties: Section 1798.150 gives consumers the right to institute a civil action to recover damages as specified by the statute for breaches of certain unencrypted/unredacted data resulting from not having reasonable security measures. This only applies to the type of data you would normally have a breach notification for such as SSN, account numbers, etc. The rest of CCPA, such as disclosures, access requests, etc., is enforced by the Attorney General who can enforce possible breaches too. Each has statutory penalties.

Related Statutes: Note that the legislative scheme with respect to “medical information” and “personal information” includes additional statutes, such as CMIA (previously noted, above) and, California Civil Code provisions such as Section 1798.81 (“A business shall take all reasonable steps to dispose, or arrange for the disposal, of customer records within its custody or control containing personal information when the records are no longer to be retained by the business by (a) shredding, (b) erasing, or (c) otherwise modifying the personal information in those records to make it unreadable or undecipherable through any means.”).  See also 1798.81.5, which among other things provides, that: “A business that owns, licenses, or maintains personal information about a California resident shall implement and maintain reasonable security procedures and practices appropriate to the nature of the information, to protect the personal information from unauthorized access, destruction, use, modification, or disclosure.”  This obligation includes contractually requiring that a third party that has access to the personal information implement and maintain reasonable security procedures as well.

 

Best Reviews Hub LLC

Privacy Notice for California Residents under the

California Consumer Privacy Act of 2018

Effective Date: February 3, 2022

Last Reviewed on: February 3, 2022

This Privacy Notice for California Residents supplements the information contained in Best Reviews Hub LLC’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information“). In particular, consumeradvise.org has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

YES (A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

NO (B) Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.

NO – (C) Characteristics of protected classifications under California or federal law, including: age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information,

NO –  (D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO – (E) Biometric information.

YES – (F) 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 Web site, application, or advertisement.

YES – (G) Geolocation data.

NO – (H) Audio, electronic, visual, thermal, olfactory, or similar information.

NO – (I) Professional or employment-related information.

NO –  (J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

NO –  (K) Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal Information does not include:

  • Publicly available information that is lawfully made available from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Best Reviews Hub LLC obtains the categories of Personal Information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Website.

Use of Google Analytics

YES – We use Google Analytics on our website.

If the above box is checked, then we use Google Analytics to provide internal insight on how the site performs, how frequently it is visited, how users interact with it, and to pinpoint potential improvements that we can implement to improve our user experience.

Google Analytics collects the following information:

  • Behavioral data (which pages of our website you visit; how long you stay on each page)
  • Browser type (e.g. Chrome, Firefox, etc.)
  • Network provider
  • Device category (desktop, tablet, or mobile)

None of this information is ever provided to third parties for dissemination of any kind.

Use of Personal Information

We may use, or disclose the Personal Information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Website, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
  • Other business purposes.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Best Reviews Hub LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Best Reviews Hub LLC about our Website users is among the assets transferred.

Best Reviews Hub LLC will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Best Reviews Hub LLC may disclose your Personal Information to a third party for a business purpose [or sell your Personal Information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights)]. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your Personal Information with the following categories of third parties:

  • Service providers.
  • Data aggregators.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has not disclosed Personal Information for a business purpose/has not disclosed the following categories of Personal Information for a business purpose:

[Category A: Identifiers.] [Category B: California Customer Records Personal Information categories.] [Category C: Protected classification characteristics under California or federal law.] [Category D: Commercial information.] [Category E: Biometric information.] [Category F: Internet or other similar network activity.] [Category G: Geolocation data.] [Category H: Sensory data.] [Category I: Professional or employment-related information.] [Category J: Non-public education information.] [Category K: Inferences drawn from other Personal Information.]] [We disclose your Personal Information for a business purpose to the following categories of third parties:

  • Service providers.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold Personal Information/has sold the following categories of Personal Information:

[A. Identifiers.] [B. California Customer Records Personal Information categories.] [C. Protected classification characteristics under California or federal law.] [D. Commercial information.] [E. Biometric information.] [F. Internet or other similar network activity.] [G. Geolocation data.] [H. Sensory data.] [I. Professional or employment-related information.] [J. Non-public education information.] [K. Inferences drawn from other Personal Information.]] [We do not sell your Personal Information to third parties.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Best Reviews Hub LLC disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • The categories of third parties with whom we share that Personal Information.
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

A verifiable consumer request means a request made by a consumer, or certain other persons authorized to act on the consumer’s behalf, and that the business can reasonably verify (1798.140(y)).

Deletion Request Rights

Per California Civil Code, Section 1798.105, you have the right to request that Best Reviews Hub LLC 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 (see Exercising Access, Data Portability, and Deletion Rights), 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 our service provider(s) to:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act 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 or data portability 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 your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

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

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide 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 do 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 a cost estimate before completing your request.

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 you 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at:

Best Reviews Hub, LLC
Twin Oaks Valley Rd #1689
San Marcos, CA 92069

Changes to Our Privacy Notice

Best Reviews Hub LLC reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Best Reviews Hub LLC collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Best Reviews Hub LLC

Attn: Privacy Officer
Twin Oaks Valley Rd #1689
San Marcos, CA 92069

Email: [email protected]
Phone: 703-972-2383

 

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