INFORMATION WE COLLECT
In providing our products and services to you, we may collect the following types of information:
“Personal Information,” or information about you that may be used to identify you or that can uniquely be associated with you, such as your name, address, e-mail address, phone number and other non-public information relating to such information. For certain services, we also collect credit card or payment account information.
“Personal Health Information,” or health-related information about you (such as weight, blood pressure or glucose levels, lab results, medications and health history) that you give us or that we receive from third parties.
We act as a service provider to our clients and may process and store on behalf of our clients Personal Information or Personal Health Information, or both, that our clients collect about third parties (or about you). We do not own that Personal Information or Personal Health Information.
We may gather navigational information during each visitor’s use of our site. In the process of gathering navigational information, non-personally identifiable information (e.g., domain type, browser version and service provider and the like) may be collected. The navigational information tells us about the use of our site by visitors, including the areas of our site that are most visited or the time of a last visit to a page on our site. It also tells us about the technical efficiencies of our site and services (e.g., the time it takes a visitor to connect to our site or download pages). The navigational information helps us better understand a visitor’s experience and improve upon that experience by recognizing and delivering more of the features, services and products our visitors prefer. We may provide this statistical information to third parties, but such information is not combined with personally identifying information without your consent.
When we provide communications services including short message (“SMS or text messaging services), to you or to those businesses that offer the services to consumers, we may gather information necessary to provide those services such as your mobile or other telephone number, communications made to subscribe or unsubscribe to those services and other information and other information relating to your or other consumers’ use of the services. We also may receive information about you or others’ use of SMS services from wireless carriers, operators or our clients including an end user’s mobile telephone number and, in some cases, additional information such as a user’s geographic location, personal information number (PIN), or electronic and physical mailing addresses. Additionally, we process message content transmitted through the SMS services that may contain personal information communicated or received by an end user. We are, however, only a passive conduit for personal information transmitted as communications made through our SMS service and the end user is ultimately responsible for the information that is transmitted through the service.
You are responsible for ensuring the accuracy of the Personal Information and Personal Health Information that we collect from you. Inaccurate information will affect the use and effectiveness of our services and our ability to contact you.
Our servers may automatically collect information, such as Internet Protocol (IP) addresses, browser type, pages visited, access times, duration of visit, referring URL, platform, links accessed, timestamp and exit page information (“Automated Information”) with respect to each visitor to the websites, whether or not such visitor is a logged-on user.
We may receive Personal Information or Personal Health Information about you from other sources, such as telephone or telefax, or from other parties such as vendors and third party providers. We may add this information to the information we have already collected about you in order to improve our products and services.
HOW WE USE AND DISCLOSE INFORMATION
We may also use the Personal Information and Personal Health Information that we obtain from you or from other sources for the following purposes:
To Provide and Improve Our Website, Products and Services
We use the information that you provide for such purposes as responding to your requests, improving our websites, products and services, and communicating with you. We may use your information to deliver information to you that, in some cases, is targeted to your interests. We may ask you to provide us voluntarily with additional information regarding your personal or business interests, experience or requests, which we may use to customize our service for you. We may combine your information with information that we collect from other companies (such as demographic data) to improve and personalize services. We may collect information for auditing, research and analysis in order to maintain, protect and improve our websites, products and services.
To Track Site Traffic Information
Clear GIFs (also known as web beacons) are used in combination with cookies to help Site operators understand how visitors interact with their web sites. A clear GIF is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. The use of a clear GIF allows the Site to measure the actions of the visitor opening the page that contains the clear GIF. We utilize clear GIFs to measure visitor behavior, to help us improve visitor experience and to manage site content. We may use clear GIFs on this Site, in our emails, in our advertisements on other web sites, or in our advertisements in others’ emails.
In addition, we may use non-business IP addresses and other Automated Information collected to track aggregate information regarding website traffic. We do not collect any Personal Information or Personal Health Information via a user’s non-business IP address. One of the uses for which this data may be gathered is for statistical purposes so that we may analyze trends and performance over time.
To Transfer Information for Legal Purposes
For Data Aggregation
We may disclose aggregated, non-personal data generated from our websites, products and services to third parties. Depending on the circumstances, we may or may not charge third parties for this aggregated, non-personal data. You grant us the right to accept payment or other remuneration for such data. We require parties with whom we share aggregated, non-personal data to agree that they will not attempt to make this information personally identifiable.
For Use With Third Parties
We may hire third parties to provide services on our behalf, such as performing statistical analysis, developing websites and answering customer service and billing questions. We will give those third parties only the Personal Information or Personal Health Information they need to deliver the service for which they have been hired. We may also share your Personal Information and Personal Health Information with vendors or other third parties in order for them to provide you with offers that we think you will find valuable. We will require such third parties to maintain the confidentiality of any information we provide.
To drive traffic to your website and to make your website easier to find, we will disclose keywords about your business, your business name, general and specific descriptions about your business, information about your location, and information about your products and services to third-party services and to the general public.
We may also use third parties to maintain and store your Personal Information to process any payment you make to us. Generally, these third parties are required not to use your Personal Information other than to provide the services requested by us.
For Use By Subsidiaries and Affiliates
SHARING YOUR INFORMATION
PROTECTING THE CONFIDENTIALITY AND SECURITY OF INFORMATION
We are committed to protecting the security of your information. We have adopted commercially reasonable security measures consistent with industry practice that are designed to assist in protecting against the loss, misuse and alteration of your Personal Information and Personal Health Information which is under our control. As you know, no security system or system of transmitting data over the Internet can be guaranteed to be 100% secure. Accordingly, you should not expect that any information provided to us or to any third party will always remain private.
Do Not Track Browser Setting
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a single website. For these purposes tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time.
For a description of Do Not Track protocols for browsers and mobile devices, or simply to learn more about the choices available to you, you can visit the All About Do Not Track website: https://allaboutdnt.com/.
HOW TO UNSUBSCRIBE
Should you decide to stop receiving e-mail communications or newsletters from us, you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail. If at any time you wish to unsubscribe from any communications from us, you may do so by contacting us at [email protected]. Despite your indicated e-mail preferences, we may send you e-mail regarding updates to legal notices applicable to the account you created with us. From time to time, we may contact you by telephone to offer you products or services which we believe may be valuable to you. Should you prefer not to receive such calls, please advise the representative who contacts you or contact our law office at [email protected].
From time to time we may contact you to offer products or services that we believe may be valuable to you. Should you prefer not to receive such calls, please so advise the representative who contacts you.
Should you wish to discontinue receiving SMS or text messages, you may communicate your preference by using the unsubscribe feature provided for that service.
PRIVACY OF MINORS
We do not knowingly collect or maintain information provided by children under the age of majority in their jurisdiction of residence, and in any event does not knowingly collect information provided by or relating to children under the age of 18. If a child has provided us with personally-identifying information without parental or guardian consent, the parent or guardian should contact us and we will remove the information.
LINKS TO OTHER SITES
Osborne Tripp SC
132 North Water Street
Sparta, WI 54656
NOTICE FOR CALIFORNIA USERS
California Civil Code, Section 1798.83
A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties’ direct marketing purposes.
If you are a California resident and would like to make such a request, please send an email to [email protected].
The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted by email at [email protected], in writing at Department of Consumer Affairs, Consumer Information Division, 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
California Consumer Privacy Act of 2018
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.
Types of verifiable consumer requests:
- Access to Specific Information – once we receive and verify your request based on the criteria herein, 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 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).
- If we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Data Portability – we will select a format to provide your personal information that is readily useable and transmittable.
- Deletion – we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
- Personal Information Sales Opt-Out and Opt-In Right – We do not sell your personal information.
How to Exercise Your Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
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.
You may have other privacy protections under applicable state laws. To the extent these laws apply, we will comply with them when we share information about you.
Effective as of: Jan. 1, 2020