Privacy Policy

Date last revised: Thursday, August 4, 2022

Introduction

Welcome to SEBPO! SEBPO values your privacy. In this Privacy Policy (“Policy”), we describe how ServicEngine US Liaison Office, Inc., and its affiliate, ServicEngine Ltd. (collectively, “SEBPO” “we,” “us,” or “our”) collect, use, and disclose information that we obtain about visitors to our website at www.sebpo.com or at other publicly-available websites we operate (collectively, the “Sites”), as well as in connection with the products and services that we provide to our customers (collectively, our “Services”).

By using our Sites or Services or otherwise providing us your consent or agreement, you agree that your personal information will be handled as described in this Policy. Your use of our Sites or Services, and any dispute over privacy or data security, is subject to this Policy and, if you or a company that you represent are a SEBPO customer, the terms of any agreements between us that pertain to privacy or data security (“Service Terms”), including their applicable limitations on damages and the resolution of disputes.

Businesses that use SEBPO’s Services (“Customers”) do so primarily to support their marketing, advertising, quality assurance, and other business processes and operations. Customers often use SEBPO’s Services and personnel to help them create and deliver digital advertisements and to track the performance of their ads online and in mobile apps. In this process, if you share your personal information with our Customers or their other suppliers, such as on the websites and mobile apps where they deliver digital ads, SEBPO and our Services may collect and process your personal information on our Customer’s behalf. To make it easy for you to navigate and understand our privacy practices, use these hyperlinks to find the section relevant to you.

Scope

SEBPO is the operator of our Sites and the controller of data collected from you by our Sites. With respect to the use of our Services by EU data subjects, we are either a controller or processor of your data, depending upon the circumstances that give rise to our processing of your data. Our US headquarters office is in the US state of New Jersey, and we have operations centers in Bangladesh and El Salvador.

Collection of Personal Data

Definition of “Personal Data”

“Personal Data” and “personal information” are terms used in many global privacy laws. We use them interchangeably throughout this Policy. They have the meanings given them in the applicable laws, but both terms generally refer to data that identify you as an individual or relate to an identifiable individual. Sometimes they also refer to households. 

We collect Personal Data in accordance with applicable laws and this Policy.  Examples of such data are (this list is not exhaustive):

  • Name
  • Gender
  • Age
  • Postal address
  • Telephone number
  • Email address
  • Driver License or Permit
  • Credit and Financial information in limited circumstances
  • Language preference
  • Geolocation information, such as IP addresses
  • Social media data made available to us through our Sites or for use in our Services
  • Cookie IDs, mobile advertising IDs, and other identifiers of you or your devices
  • Pictures, audio files, or videos you submit, including pictures of yourself
  • Credit card and billing information (if submitted as payment for Services or made available to us for use in our Services)
  • Other data about you that is requested by a Customer or that you authorize us to process

How We Collect Personal Data

We collect Personal Data in a variety of ways as described below.

Information Obtained Directly From You

We may ask you to provide Personal Data for various reasons. For example, we collect personal information when you visit our Sites, interact with our marketing messages, events and emails, request a demo of our Services, or engage with us about career opportunities with SEBPO. During these encounters, we may ask you for contact information such as your name, physical and email addresses, phone numbers, geographic information and job information.

To use our Services, we may require you to register or identify yourself by providing your name and contact information. We may ask you to provide additional information, such as the data listed in the Collection of Personal Data section above.

We may ask you for similar information at other times, such as when you apply for a job through our Sites or contact our customer service team.

You may also provide us your personal information when you sign up for a webinar, download a whitepaper directly on our Sites or from one of our partners, or complete a contact us form on our Sites.

We also collect Personal Data of the employees, contractors, and agents of our Customers, which they may provide to us when they use our Services. The information we collect may include name, address, company name, location, email address, phone number, and similar business contact information.

Information Used in the Services

Our Customers share Personal Data with us for use in our Services. This Personal Data may be collected through similar methods as those described in the Information Obtained From Third Party Sources and Information Collected Automatically sections below or that they collect when you purchase their products and services or view information about them online, including in their advertisements. We use this Personal Data to provide Services to our Customers. We may share it with third parties as authorized by our Customers.

SEBPO does not process your Personal Data in our Services for our own business purposes (such as for our sales, marketing and Customer support activities, which are discussed elsewhere in this Policy). Instead, we only process Personal Data in our Services for the benefit of our Customers and in compliance with their instructions and applicable privacy laws. Where your consent or an alternative lawful justification is required to process or share your Personal Data, we rely on our Customers and their suppliers and other partners to obtain your consent or otherwise show that they have a lawful justification for our processing. Since our Services are limited to processing your Personal Data as instructed by our Customers, either the Customers’ or their suppliers’ and partners’ privacy policies and other agreements with you will govern the scope of our use and processing of your personal information. Of course, we also comply with the data privacy and security laws that apply to our processing activities. 

Information Obtained From Third Party Sources

Through our Sites and Services, we may receive information, including, with your consent where required, from third party providers and sources that, alone or in combination with other information, could be used to identify an individual, including you. For example, a Customer of our Services may, either directly or through one of its advertising platform providers, allow us to access a profile of you and your interests, which we can use to market the Customer’s products and services to you.

While we make efforts to require our Customers and vendors to comply with applicable privacy laws, we do not control the privacy practices of our Customers or their third party providers. As a service provider, we rely on them to obtain your consent or have another lawful basis to process your Personal Data on their behalf.

We also may receive your Personal Data such as name, business email, company and job title, from trade shows or other similar events that we sponsor or from third parties that provide such information. We use this information to send marketing messages to you as described below.

Information Collected Automatically

We automatically collect information about your use of our Sites, including through cookies, web beacons, and other data collection technologies designed for use with websites, internet services or mobile devices or apps that you use. We may combine this information with other information we collect about you. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Data. Please see the information below to learn more about how we use cookies and other data collection technologies, and how you can control such uses.

This information can include your browser type and operating system, your IP address, the length and times of day you use our Sites, the referring URL or webpage that led you to our Sites or Services.

Additionally, through our advertising service providers, we may collect information on your mobile device, such as device name and model, mobile operating system type, name and version; language information; and your engagement with our ads and Services.

With your permission, we may collect location information from your mobile device to help us verify information you may have provided to us. You may turn off this feature through the location settings on your mobile device. More information about how to do this and manage other mobile privacy settings is available from your device provider.

Information Obtained From Social Networking Sites

Third-party social networking sites control the information they collect from you. They may provide information about you, including Personal Data, to us for our marketing purposes, or to our Customers or their service providers, including us, to use for marketing or other purposes. For information about how they may use and disclose your Personal Data, including any information you make public, please consult their privacy policies. We have no control over how any third-party social networking site uses or discloses the personal information it collects about you. When we use such information in connection with our Sites and marketing, we use it as described in this Policy and any disclosures on our Sites. When we use such information in our Services, we comply with our Customer’s instructions, which may include instructions to comply with the requirements of the social networking site that made your Personal Data available.

Use of Personal Data and Other Information

We use the Personal Data collected for the purposes described below.

To Market and Provide our Services

SEBPO uses your information, including Personal Data, for the following purposes:

  • To create and deliver digital advertisements to you that are tailored to your personal traits and interests.
  • To build profiles about your personal traits and interests that can be used to create more personalized advertising experiences for you.
  • To optimize and monitor the performance of our Customers’ digital advertising campaigns
  • To assist Customers in preventing fraud in relation to the ads for their products and services.

To Communicate with You

We use the information that we collect when you visit our Sites to respond to questions, comments or requests for information from us and to send applicable and personalized marketing messages in accordance with applicable laws. These marketing messages may include emails, texts, online advertisements, or phone calls. Marketing related communications to you will contain instructions on how to unsubscribe from receiving them. See more on how to opt out in the Your Choices section below.

When you send email or other communications to us, we may keep those communications and use the Personal Data they contain in order to process your questions, respond to your requests and improve our Sites or Services. In particular, we may use your email address to communicate with you about our Services, such as to provide you with support.

Other Uses of Data

We may anonymize, de-identify and/or aggregate the personal information that we collect and use such anonymized, de-identified and/or aggregated data for our own business purposes, including but not limited to sharing anonymized and de-identified data with our current and prospective business partners, service providers, affiliates, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyze patterns among groups of people, and conducting research on consumer demographics, interests and behavior.

We use personal information and other data for data analysis, security and fraud monitoring and prevention, product development and testing, improving or modifying our Sites and Services, analyzing website traffic patterns and behaviors, statistical and survey purposes, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

How We Share Your Information

SEBPO may share your information, including Personal Data, in the circumstances described below.

Customers. We will share the information that you direct us to share with a Customer, and we will share and process information about you as instructed by our Customers.

Third Party Data Sources. We share your information with third party data sources to verify the accuracy of the information you provide to us and to request information about you.

Aggregate and De-Identified Information. We may share aggregate or de-identified information about users and prospective users of our Sites and Services with third parties for marketing, advertising, research or similar purposes.

Service Providers. We share information with our third party vendors and service providers to perform certain functions on our behalf, such as hosting and operating our Sites and specific portions of the Services, maintaining databases, helping us collect job applications, delivering content, sending emails and text messages on behalf of our customers and for our own marketing communications, using text messaging services for multifactor authentication protocols, administering content, mailing information, processing payments or otherwise operating the Services or the Sites.

Business Transfers. We may transfer the information we have collected from you, including your Personal Data, if we are acquired by or merged with another company, if all or some portion of our assets are transferred to another company, or as part of financing due diligence, or in a bankruptcy proceeding, reorganization, or receivership, to the other company or bankruptcy trustee or administrator.

In Response to Legal Process. We may disclose the information we collect from you in order to comply with the law, a judicial or regulatory proceeding, court or governmental agency order, or other legal process, such as in response to a court order or a subpoena.

To Protect Us and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Service Terms or this Policy, or as evidence in litigation or disputes in which SEBPO is involved.

Links to Other Websites

Our Sites and Services may contain links to other websites not operated or controlled by SEBPO (“Third Party Sites”). The privacy practices described in this Privacy Policy do not apply to Third Party Sites. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the operators of Third Party Sites directly for information on their privacy practices and policies.

Security

SEBPO’s Services and operations are designed to protect our Customers’ and individuals’ private and personal information. We have implemented commercially reasonable and appropriate physical, technical, and process methods and precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. For example, we protect the personal information that you submit to us through measures such as encryption and access controls.

You are responsible for the privacy and security of your Personal Data when it is in your control, and you should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or misappropriated information when it is in your control or due to your failure to take appropriate precautions to secure your personal information.

Use of Cookies and Other Digital Technologies

As further described in our Cookie Notice, we may use “cookies” (a small text file sent by your computer each time you visit our Site) to collect information about you, your interactions with our Sites, and related information. However, we do provide you with the ability to manage your cookie preferences. See our Cookie Notice at the link in the “Cookies” section under “Access and Your Choices” below for additional information about managing cookies in your browsers and devices.

In addition to cookies, we may use other digital technologies as described below:

  • To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails or other electronic marketing communications from us, other than emails related to your use of the Services or management of your account. Please see the Access and Your Choices section below.
  • We might also use a pixel tag which is a small graphic file that allows us and third parties to monitor the use of the Sites and provide us with information based on your interaction with the Sites, Services and e-mails. These tags may collect the IP address from the device on which you loaded the page, your browser type, and other data. Pixel tags are also used by third parties to collect information when you visit our Site, the links and other actions you take on our Site, and we may use this information in combination with cookies to display targeted advertisements, subject to your opt-out rights in some countries and US states.
  • Other data technologies may be used that collect comparable information for security and fraud detection purposes.

Access and Your Choices

Cookies

See our Cookie Notice for more information about the cookies used on our Sites and to manage your cookie preferences.

Click here for our Cookie Notice

In addition, many browsers default to accepting cookies, but you may be able to change this setting in your browser and you can also clear your cookies in browsers. If you do this, you may lose some functionality of our Sites or the sites and services of our Customers and third parties. While we have provided information below about how to manage your browser settings on popular browsers, be sure to check your browser’s help function for the latest information about your cookie setting options in browsers.

Please see the links below for guidance on how to modify your web browsers cookie settings on the most popular browsers:

Note, however, that if you reject our request to use cookies or turn cookies off, our Sites and other sites may not work as intended; for example, you may be unable to access certain parts of the Sites and you may not be able to benefit from the full functionality of the Sites.

To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set, how to manage and delete them, and how to opt-out of their use, visit www.allaboutcookies.org, and/or the Digital Advertising Alliance’s (DAA) online resources at www.youradchoices.com/control, and/or the Network Advertising Initiative’s (NAI) online resources at www.networkadvertising.org, and follow the instructions there, or if located in the European Union, visit the European Interactive Digital Advertising Alliance’s (EDAA) Your Online Choices opt-out tool at www.youronlinechoices.com.

Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or the EDAA Your Online Choices opt-out page will opt you out from the delivery of interest-based content or ads to you by the third parties participating in those opt-out services, but it does not mean you will no longer receive any advertising through our Services or on our Sites or other websites. You may continue to receive advertisements, for example, non-personalized advertisements or advertisements based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA, NAI or EDAA websites, your opt out may not be effective. Additional information is available at these websites.

Mobile Devices

The DAA and NAI resources noted above also provide information about how to manage cookies, other digital technologies, and your advertising preferences on mobile devices. Also see your device provider’s information about managing your privacy on their devices. 

Third Party Analytics

We use automated devices and applications, such as Google Analytics, to evaluate usage of our Sites. We also may use other analytic means to evaluate our Sites and Services. We use these tools to help us improve our Sites’ and Services’ performance and user experiences. These tools and the companies that provide them may use cookies and other tracking technologies to perform their services.

Third Party Advertisers

We may use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms), both for SEBPO and our Customers. This enables us, our Customers and these third parties to personalize advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including Pixel Tags or clear GIFs), device profiles and graphs, and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one.

Modifying personal information

You may modify personal information that you have submitted to us by submitting a request to privacy@sebpo.com. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Services for a period of time and in accordance with our data retention policies.

Opting out of email

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

EU and UK Data Subjects

This section applies if you are an EU or UK data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). SEBPO is the data controller for processing Personal Data provided to SEBPO in relation to the Sites. Unless you have given us your consent for our independent uses of your Personal Data or we have another lawful basis for processing your Personal Data, we act strictly as a data processor for Personal Data that we process through the Services, as described under the “Information Collected Through our Services” section above. For example, we process data on behalf of Customers in support of their efforts to advertise, market and their support products and services. We rely on the following legal bases for processing your Personal Data:

  • Processing of your Personal Data based on your consent for such processing, which may be given either to us or the Customer, such when you request to receive information about a product or service.
  • Processing of your Personal Data that you provide to us (such as your name, email address, postal address, telephone number, company name and role) when you request information about a SEBPO Service or when you otherwise send inquiries about our Services is necessary to respond to or implement your request prior to entering into a contract with us or a data controller that is using our Services.
  • When you apply for employment, including through our Sites, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you submit.
  • We use account-related data to set up accounts for users in the Services and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Services, contact you regarding your use of the Services or to notify you of important changes to the Services. Such use is necessary for the performance of the contract between you and the Customers or us.
  • We may send you information by email or through other electronic communications on our products or services or other promotions if you consent to receiving them. If you have not opted-in to these marketing emails, we do this either because we are relying on an exception to opt-in requirements or because of our legitimate interest to promote the success of our business.
  • Our use of data relating to your use of the Sites and/or the Services, described above, is necessary for our legitimate interests in understanding how the Sites and the Services are being used by you, to improve your experience on it and our Service offerings.
  • We also have a legitimate interest in aggregating and/or anonymizing or de-identifying the information that we collect through our Sites and/or the Services and using this information for our business purposes, as described above.

When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent for our processing activities or those activities are otherwise required or permitted by law. You have the right to object to processing that is based on our legitimate interests, as further described below.

Subject to applicable law and reasonable steps that we may take to verify your identity with respect to your requests, you have the following rights in relation to your Personal Data. You may exercise these rights by contacting us as indicated under “Contact Us.” Note you will be asked to verify your identity when submitting a request.

  • Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification: If your Personal Data that we control is inaccurate or incomplete, you are entitled to have it rectified or completed. Note that we may not be able to rectify data obtained from a third party such as a governmental agency or other data that we do not control, and you will need to contact that third party directly. If we have shared your Personal Data with others, we will tell them about your rectification request where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where our Customer who controls your Personal Data authorizes it (we may not delete your data when other interests outweigh your right to deletion, for example if we are required by law to keep it). If we have shared your data with others, we will tell them about the erasure request where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you, to the extent it is available. We will give you your Personal Data in a structured, commonly used and machine-readable format.
  • Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so if we are processing your Personal Data for the Services, for direct marketing, or otherwise. However, if we are relying on a legitimate interest to process your Personal Data and we demonstrate compelling legitimate grounds for the processing we may continue to process your Personal Data. 
  • Rights in relation to automated decision-making and profiling: You have the right to be free from decisions that we make based solely on automated processing of your Personal Data, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent. Note this right may not apply to us if our processing is for our Customer. In such case we will refer your inquiry to our Customer.
  • Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Your withdrawal of consent will not apply to or affect prior processing of data that was processed prior to our receipt of your withdrawal of consent.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

EU Data Subjects may contact us about these rights at privacy@sebpo.com or at the address set out in the Contact Us section below.

International Data Transfers

Our Site is hosted and managed in the USA, and our Services are provided from the USA, Bangladesh, and El Salvador. Thus, the Personal Data we process may be transferred to, and processed in, these countries and in any country in which we, our group companies, or our service providers or partners operate, which may include countries other than the country in which you are resident. These countries may have data protection laws that are different than the laws of your country.

However, we have taken appropriate safeguards to protect your Personal Data in accordance with this Policy when it is transferred to such countries. In particular, SEBPO will, as needed, implement appropriate cross-border transfer mechanisms with data exporters for the protection of Personal Data in cross-border data transfers.

In particular, regarding the transfer to and processing in the USA, Bangladesh and El Salvador of Personal Data from the European Economic Area (EEA) member countries, the United Kingdom (UK) and Switzerland, SEBPO relies on the Standard Contractual Clauses (SCCs, also known as the EU Model Clauses and the corresponding Standard Data Protection Clauses issued by the UK Information Commissioner under S119A(1) Data Protection Act 2018 on 2 February 2022) to help safeguard such Personal Data and as our lawful transfer mechanism under applicable EU and UK privacy laws (collectively, “GDPR”). The SCCs are a set of terms and conditions published by the European Commission (EC) and approved for use by the UK with certain updates, that apply to controllers and processors that transfer personal data to countries that are not covered by an adequacy decision, such as the USA. You can learn more about the EU SCCs here and the UK SCCs here. If there is any conflict between the terms of this Policy and any SCCs that are applicable to the relevant transfer, the SCCs will govern.

SEBPO commits to resolve complaints about your privacy and our collection or use of your Personal Data. EEA, UK or Swiss individuals with inquiries or complaints regarding this privacy policy are encouraged to first contact SEBPO at the contact information provided in the “Contact Us” section below. You may refer any unresolved privacy or data use concern that we have not addressed satisfactorily to your local data protection authority, and we will work with them to resolve your concern.

When SEBPO transfers Personal Data about EEA, UK or Swiss individuals to other third parties, we will do so in accordance with the requirements of GDPR applicable to such transfers, including for onward transfers of Personal Information to third parties in other countries that are not covered by an adequacy decision, such as the USA. In these cases, SEBPO is potentially liable if such third parties do not provide the same level of protection as GDPR.

Retention

SEBPO will retain Personal Data for the period necessary to provide our Services or for the purposes for which it was collected, as otherwise required by our contracts or by law.

When determining how long we should keep data, we consider the length of time we or our Customers will have a relationship with you in connection with our Services, whether there is a legal obligation that would require us to keep the information for a specified period of time, the reasons why we process your Personal Data, and the risk of harm from unauthorized use or disclosure of your Personal Data.

We may also anonymize or de-identify Personal Data so it would no longer be associated with you for research or analytical purposes. If Personal Data is anonymized or de-identified, we may use this data for as long as we have a legitimate business purpose for such use, without additional notice to you.

Children Under 13

Our Services and Sites are not directed at or offered to children under 13 years of age (or older where required by law), and we do not knowingly collect or receive Personal Data from them. If we learn that we have received Personal Data from a child whose age requires parental consent for processing, we will delete the data. If you believe that we have received Personal Data from a child whose age requires parental consent, you may contact us at privacy@sebpo.com.

Do Not Track Signals

Some browsers, software and devices include “do not track” options for their users. The appropriate use and response to signals made available when you select “do not track” options have not been finalized; therefore, “do not track” signals do not apply to our Sites or Services, and we do not alter any of our data collection and use practices upon receipt of such a signal.

California Privacy Rights

Personal Data We Collect about California Consumers

Additional Notice for California Consumers – This part of our Privacy Policy applies to consumers who reside in California. To ensure we give California consumers the disclosures that are required by California laws, we have provided this additional notice. Our use of the term, “Personal Data” in this Privacy Policy also means “personal information” as defined under the California Consumer Privacy Act of 2018 (as amended from time to time, “CCPA”) and other California laws when used in this additional notice.

We describe the personal information we have collected from consumers in the twelve (12) months preceding the effective date of this Privacy Notice in the part of our Privacy Notice titled, “Collection of Personal Data” above.  In our Services, we collect and use personal information solely as a service provider (as defined in CCPA) for our Customers and their third-party partners. The information we collect includes the following:

  • Identifiers listed in the “Collection of Personal Data” section above.
  • The following categories of personal information described in California Civil Code §1798.80(e): (1) the personal information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Collection of Personal Data” above.
  • Characteristics of protected classifications under California or federal law: age, national origin, sex, gender, marital status, language and military status.
  • Commercial information, including information about orders or purchases of any of our Services; registration information, specials, and information you provide or submit to us when you participate in any event, program, survey or other promotion that we may offer from time to time.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our Sites, advertisements that we display on our Sites or mobile apps or on third party sites and apps, or accounts on third-party social media platforms.
  • Geolocation data.
  •      Inferences drawn from (1) the information we collect when you visit our Sites or the sites or mobile apps of our Customers or their third-party suppliers, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet or other third party data sources (such as public locations on the Internet), and (3) information about consumers’ preferences and behaviors that we collect on our Sites, the sites or mobile apps of our Customers or their third-party suppliers, or purchase from third parties in order to create a profile about a consumer, for our use or that of our Customers, that reflects the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

For more information, please see “Collection of Personal Data” and “Information Collected Automatically” above.

Disclosures of Personal Information for Monetary or Other Valuable Consideration or for Business Purposes

We do not sell consumers’ personal information in the sense that most people think of sales. The term, “sale,” is broadly defined in CCPA and includes any sharing of your personal information to a third party for consideration if the third party might use the information for their own purpose (such as in advertising or analytics). We do, however, work as a service provider for Customers and other third parties who may sell your personal information, and in that capacity, we only use your data as instructed by our Customer or other third party. We also may share your personal information with our own service providers with whom we have contracts to provide some part of our Services or to support our business operations, like marketing services providers and sponsors of events. As is common practice among businesses that operate websites, we may disclose certain online identifiers, information about the use of our Sites and inferences drawn about you to our social media, advertising and analytics partners for our marketing and related purposes. While we do not view these data sharing activities as “sales,” if you wish to opt-out of our uses of personal information for these purposes, see your options under the “Access and Your Choices” section of this policy above. We don’t intend for our Services to be used by anyone under 16 and therefore do not knowingly collect or disclose personal information of individuals under age 16.

We have disclosed personal information in all or substantially all of the categories identified in this Additional Notice for California Resident Consumers for various business purposes.  For more information about the categories of personal information we have disclosed, the categories of entities to whom we have disclosed this information and the purposes for which we have disclosed the information, please see “How We Share Your Information” above.

For additional information regarding the purposes for which we use the personal information we collect, please see “Use of Personal Data and Other Information” and “How we Share your Information” sections above. 

Your California Privacy Rights

If you are a California resident, you have the following rights.  We will honor requests received to the extent required by applicable law and within the time provided by law.

Right to Access and Information Regarding Personal Information

You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you.  Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

  • The categories of personal information we have collected about you;
    • The categories of sources from which the personal information is collected;
    • Our business or commercial purpose for collecting or selling personal information;
    • The categories of third parties with whom we share personal information;
    • The specific pieces of information we have collected about you;
    • The categories of personal information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of personal information for each third party to which we disclosed the personal information; and
    • The categories of personal information about you that we disclosed for a business purpose.

We will deliver personal information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law.  We may deliver the personal information to you through your account, if you maintain an account with us, or electronically or by mail at your option.  If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information from one entity to another without hindrance.

Right to Deletion of Personal Information 

You have the right to request that we delete personal information about you that we have collected from you.

Right to Opt Out

If in the future we sell your personal information, you have the right to opt out of the disclosure of personal information about you for monetary or other valuable consideration.  To Opt-Out, see the “Requests to Exercise Your Rights” section below.

Right to Limit Use and Disclosure of Sensitive Personal Information

If in the future we collect sensitive personal information about you for our business purposes, you have the right to direct us to limit our use of your sensitive personal information to uses permitted by CCPA. If we receive your sensitive personal information in the performance of our services for a Customer, we will only use your sensitive personal information in response to instructions from that Customer and not for any other purpose.

Right to No Discrimination

We may not discriminate against you because of your exercise of any of the foregoing rights under the California Consumer Privacy Act, including by:

  • Denying you goods or services;
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Providing you a different level or quality of goods or services; or
  • Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.

We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your personal information.

Requests to Exercise Your Rights

If you are a California resident, you may request to exercise the foregoing rights by:

  • Submitting a request to privacy@sebpo.com
  • Calling us at +1 856 547 1257    

Our Right to Verify Your Identity

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law.  If we cannot verify your identity, we may limit our response to your exercise of the above rights as permitted by law.

Data Sharing for Direct Marketing Purposes

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. We do not establish business relationships with California residents related to personal, family or household purposes, so this law does not apply to us. If you have any questions about our obligations under Section 1798.83, please contact us via email at privacy@sebpo.com. Except for the methods for managing your personal information described in this policy, SEBPO does not monitor, recognize or honor any opt-out or do not track mechanisms, including general web browser, “Do Not Track” settings and/or signals.

Changes to this Privacy Policy

We may change this Privacy Policy at any time. We will post all changes to this Privacy Policy on this page and will indicate at the top of the page the modified policy’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy policy. If required by the applicable law, we will notify you of the changes. By continuing to use the Sites and/or the Services or providing us with information following such a replacement Policy being provided, you agree that you will be deemed to have agreed to be bound by the Privacy Policy as changed.

Contact Us

If you have any questions or suggestions regarding this Privacy Policy or your rights regarding your Personal Data, please contact us at privacy@sebpo.com or send postal mail to: SEBPO Privacy Inquiries, 78 E Main St, Marlton, NJ 08053 USA