PRIVACY POLICY

Last updated February 20, 2020

Thank you for choosing to be part of our community at AdaptiGroup LLC, doing business as AdaptiBar ("AdaptiBar'', "we'', "us'', or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our privacy notice, or our practices with regards to your personal information, please contact us at support@adaptibar.com.

When you visit our website https://www.adaptibar.com, mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Sites or Apps and our services.

This privacy notice applies to all information collected through our website (such as https://www.adaptibar.com), mobile application, ("Apps"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy notice as the "Services").

Please read this privacy notice carefully as it will help you make informed decisions about sharing your personal information with us.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us such as name, address. contact information, passwords and security data, and payment information.

We collect personal information that you voluntarily provide to us when registering at the Services or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or Apps or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:

Personal Information Provided by You. We collect app usage; financial information (credit card number, purchase history, invoices); and other similar data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Braintree.
You may find their privacy policy link(s) here:
https://www.braintreepayments.com/legal/braintree-privacy-policy.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information -such as IP address and/or browser and device characteristics -is collected automatically when you visit our Services or Apps.

We automatically collect certain information when you visit, use or navigate the Services or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Services or Apps, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Information collected through our Apps

In Short: We may collect information regarding your mobile device, when you use our apps.

If you use our Apps, we may also collect the following information:\

  • Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

  • To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.

  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

  • Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services or Apps.

  • To post testimonials. We post testimonials on our Services or Apps that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at support@adaptibar.com and be sure to include your name, testimonial location, and contact information.

  • Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

  • Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.

  • Request Feedback. We may use your information to request feedback and to contact you about your use of our Services or Apps.

  • To protect our Services. We may use your information as part of our efforts to keep our Services or Apps safe and secure (for example, for fraud monitoring and prevention).

  • To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.

  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

  • To deliver services to the user. We may use your information to provide you with the requested service.

  • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Services or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this privacy notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

  • Business Partners. We may share your information with our business partners to offer you certain products, services or promotions. This may include information concerning your usage of our site and your progress using our study materials, which may be disclosed to third parties such as educational institutions, professors and product development partners for a variety of purposes, including but not limited to analyzing and improving bar passage rates and for the development of new products and services, as you have agreed to under the terms of service by using the AdaptiBar website.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short: We only share information with the following third parties.

We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

  • Advertising, Direct Marketing, and Lead Generation
    We may process your data if you have given us specific consent to use your personal information in a specific purpose.

  • Communicate and Chat with Users
    Drip, Facebook Customer Chat, Hotjar, MailChimp, Mailgun, SurveyMonkey and Zendesk Chat

  • Content Optimization
    Google Fonts and YouTube video embed

  • Functionality and Infrastructure Optimization
    Amazon Web Services, SiteGround Hosting and Termly.io

  • Invoice and Billing
    Braintree and PayPal

  • Retargeting Platforms
    Facebook Remarketing, Google Ads Remarketing, Google Analytics Remarketing and Facebook Custom Audience

  • Social Media Sharing and Advertising
    AddThis, Facebook advertising, Facebook social plugins, lnstagram advertising, Linkedln advertising, Linkedln social plugins, ShareThis, Twitter advertising, Twitter social plugins and YouTube social plugins

  • User Commenting and Forums
    Facebook Comments and Google Tag Manager

  • Web and Mobile Analytics
    Facebook Ads conversion tracking, Facebook Analytics, Google Ads, Google Analytics, Google Analytics for Firebase, Google Tag Manager, Hotjar, TestFlight and WordPress Stats

  • Website Hosting
    WordPress.com

  • Website Performance Monitoring
    Crashlytics, Firebase Crash Reporting, Firebase Performance Monitoring and New Relic

  • Website Testing
    Cloudflare, Beta by Crashlytics, Google Play Console, Google Website Optimizer and TestFlight

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this privacy notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services or Apps is at your own risk. You should only access the services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at support@adaptibar.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you have questions or comments about your privacy rights, you may email us at support@adaptibar.com.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services or Apps. To opt-out of interest-based advertising by advertisers on our Services or Apps, visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below.

You will then be removed from the marketing email list - however, we will still need to send you service­ related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

  • Contact us using the contact information provided.

  • Unsubscribe at the bottom of any email received.

10. DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when AdaptiGroup LLC believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that AdaptiGroup LLC becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information AdaptiGroup LLC will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("ONT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing ONT signals has been finalized. As such, we do not currently respond to ONT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine the Light" law, permits California residents to request certain information regarding our disclosures of your personal information to third parties for their direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

Under the Shine the Light Law, if you are under 18 years of age, reside in California, and have a registered account with the Services or Apps, you have the right to request removal of unwanted data that you publicly post on the Services or Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

Our Privacy Notice is designed to meet the standards in the California Consumer Privacy Act of 2018 (“CCPA”). Even so, we need to specifically advise you of the following information and rights of California residents.

Right to Opt Out of Sale of Personal Information: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below.

Right to Know: You have the right to obtain information about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, 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 purpose for collecting that personal information

  • The categories of third parties with whom we share that personal information

  • The specific pieces of personal information we collected about you (also called a data portability request).

Right to Access Information: 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 contact 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. To make a request for information contact us at 1-877-466-1250 for instructions or email us at support@adaptibar.com. Upon confirming your request, we will evaluate and respond to your request for information within 45 days.

Right to Request Deletion of Information: You have the right to ask us to delete certain personally identifiable information about you which we have collected.

To submit a request to delete, you 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 to delete personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You may call Customer Service at 1-877-466-1250 for instructions or email us at support@adaptibar.com.

We will notify you once the deletion of your data has been completed, but certain personal information may be retained by us if we need to do any complete any of the following activities for which we may need to retain your data:

  • 1. Provide goods or services to you;

  • 2. Detect and resolve any issues related to security or functionality;

  • 3. Comply with legal obligations

13. DO WE MAKE UPDATES TO THIS PRIVACY NOTICE?

In Short: Yes, we will update this privacy notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?

If you have questions or comments about this privacy notice, you may email us at support@adaptibar.com or by post to:

AdaptiGroup LLC
33 N Dearborn St., Ste 1415
Chicago, IL 60602
United States

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.