Last Revised Jun, 2024

Protecting your privacy is fundamental to the way Agency Within,  (“we”, “us”, or “our”) conduct business. This Privacy Policy explains how we may collect, use and disclose your personal information. You can jump to particular topics by going to the headings below:

• How We Collect or Receive Personal Information

• Disclosure of Personal Information

• Your Choices

• Data Security

• How We Retain Your Personal Information

• Other Important Information

• Contact Information

• Other Jurisdictions

We collect personal information in the course of providing services to our business customers and, sometimes, to you directly. Here are the types of information we gather: We collect personal information in the course of providing services to our business customers and, sometimes, to you directly. Here are the types of information we gather:

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• Client Information. We collect the name, usernames, and contact information, of our clients and their employees with whom we may interact. We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.

• Client User Account information. We collect personal data from our clients when they create an account to access and use the services or request certain free services from our website. This information could include business contact information such as name, email address, title, company information, and password for our services.We have a legitimate interest in providing account-related functionalities to our users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, we use this information to fulfill our contract to provide you with services

• Cookies and first party tracking. We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. See our Cookie Policy for more information.We have a legitimate interest in making our website operate efficiently.

• Cookies and Third-Party Tracking. We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our Cookie Preference Center for more information.We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics.

• Demographic Information. We collect personal information, such as your age or location.We have a legitimate interest in understanding our users and providing tailored services.

• Email Interconnectivity. If you receive an email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.We have a legitimate interest in understanding how you interact with our communications to you.

• Feedback / Support. We collect personal data from you contained in any inquiry you submit to us regarding our sites or services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support requests, or to report an issue. When you communicate with us over the phone, your calls may be recorded and analyzed for training, quality control and for sales and marketing purposes. During such calls, we will notify you of the recording via either voice prompt or script.We have a legitimate interest in receiving and acting upon, your feedback, issues, or inquiries.

• Mailing List. When you sign up for one of our mailing lists we collect your email address or postal address.We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.

• Surveys. When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.We have a legitimate interest in understanding your opinions and collecting information relevant to our organization.

• Website interactions. We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.

• Web logs. We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.We have a legitimate interest in monitoring our networks and visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

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In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. 

 

How We Use Personal Information

We use the personal information we collect from you to fulfill the purpose for which it was provided to us, such as contacting you about our services, evaluating your employment application. We may also use your personal information: (1) to provide you with information, products or services that you request from us; (2) to provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you; (3) to improve our website and present its contents to you; (4) for testing, research, analysis and product development; and (5) for any other purpose with your consent.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you sign up for services, we may collect your information to complete that transaction, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your services. As a result, our collection and processing of your information are based in different contexts upon your consent, our need to perform a contract, our obligations under the law, and/or our legitimate interest in conducting our business.

 

Disclosure of Personal Information

In addition to the specific situations discussed elsewhere in this policy, we may disclose personal information we collect from you: (1) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our clients or others (2) to contractors, service providers, and other third parties we use to support our business; (3) to fulfill the purpose for which you provide it; (4) to a buyer or other successor in the event of a sale, merger, reorganization or transfer of some or all of our business or assets; (5) for any other purpose disclosed by us when you provide the information; (6) to comply with any court order, law or legal process, including responding to any government or regulatory request; (7) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; or (8) with your consent. We do not sell or otherwise share personal information with third parties for direct marketing purposes.

 

Your Choices.

You can make the following choices regarding your personal information:

1. Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. 

2. Right to Data Portability. You may have the right to obtain a copy of the Personal Data that you previously provided.  We will provide this information in a portable format, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller without hindrance, where the processing is carried out by automated means. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.

3. Changes To Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information,
   you contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law.

4. Deletion Of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.

5. Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.

6. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

7. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can
   stop receiving promotional emails by following the unsubscribe instructions in the e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.

8. Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”

9. Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires
   us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

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Please address written requests and questions about your rights to info@iconmxusa.com or call us at +1 (773) 508-4160. 

Note that, as required by law, we will require you to prove your identity.  We may verify your identity by a phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  We will require verification that you provided the authorized agent permission to make a request on your behalf.  You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.  If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

1. A completed notarized statement executed by you and the consumer indicating that you have the authorization to act on the consumer’s behalf.

2. If you are a business, proof that you are registered with the Secretary of State to conduct business in California.

If we do not receive both pieces of information, the request will be denied.

 

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access and disclosure. The use of, and access to, your personal information by us is restricted to employees and contractors who need to know that information to provide services to you. We maintain physical, electronic and procedural safeguards to limit access to your nonpublic personal information. 

Unfortunately, no method of transmission of information via the internet or electronic storage is completely secure. Although we use reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our website or other electronic means. Any electronic transmission of personal information is at your own risk. In the event that we are required by law to inform you of a breach of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Generally, we will hold your personal information for as long as you are a customer and use our Services to ensure accuracy and to help maintain quality of service or if we are obliged to retain such information for legal, regulatory, fraud prevention and legitimate business purposes.

The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use and/or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research, statistical or other business purposes. We may use this aggregated, anonymized, or de-personalized information indefinitely without further notice.  We may retain personal information for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements.

 

Contact Information

If you have questions or comments about this Privacy Policy, please call or email us at info@iconmxusa.com or (+1 (773) 508-4160‬.

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Children’s Policy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying FTC regulation establish United States federal law that protects the privacy of children using the Internet. In addition, other state laws protect the privacy of children. We therefore do not knowingly contact or collect personal information from children under 16. Our website is not intended to solicit information of any kind from children under 16. It is possible that by fraud or deception we may receive information pertaining to children under 16. If we are notified of this, as soon as we verify the information, we will immediately obtain parental consent or otherwise delete the information from our servers. If you want to notify us of our receipt of information by children under 16, please do so by emailing us at info@iconmxusa.com.

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Selling or Sharing for Targeted Advertising.  

We do not “sell” personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our Services for purposes of analyzing and optimizing our Services and advertisements (ads), providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. 

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How to Exercise Your Privacy Rights

To exercise your rights please submit your request to info@iconmxusa.com. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of: (a) A completed written notice indicating that you have authorization to act on the consumer’s behalf signed by you and the consumer; and (b) if you are a business, proof that you are registered with the appropriate Secretary of State to conduct business. If we do not receive both pieces of information, the request will be denied.

Right to Know Disclosures. In the last 12 months, we have collected the following categories of personal information:

Categories of Personal Information That We Collect. To Whom We Disclose Personal Information for Business Purpose

Identifiers – this may include name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name, signature, social security number, driver’s license number, passport number, or other similar identifiers.

• Advertising networks

• Affiliates or subsidiaries

• Business partners

• Data analytics providers

• Government entities

• Internet service providers

• Operating systems and platforms

• Other Service Providers

• Payment processors and banks

• Product and service fulfillment companies

• Social media platforms & networks

Financial information – this may include bank account number, credit or debit card number, or other financial information.

• Government entities

• Internet service providers

• Operating systems and platforms

• Other Service Providers

• Payment processors and banks

• Service fulfillment companies

Protected characteristics – this may include race, gender, physical or mental disability, and religion.

• Affiliates or subsidiaries

• Government entities

• Other Service Providers

Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

• Advertising networks

• Affiliates or subsidiaries

• Business partners

• Data analytics providers

• Government entities

• Internet service providers

• Operating systems and platforms

• Other Service Providers

• Payment processors and banks

• Product and service fulfillment companies

• Social media platforms & networks

Geolocation data – this may include precise physical location.

• Data analytics providers

• Internet service providers

• Other Service Providers

Electronic and sensory data – this may include audio, electronic, visual, thermal, olfactory, or similar information (e.g., pictures, a recording of a customer service call, security video surveillance footage).

• Government entities

• Other Service Providers

Professional / employment information – this may include occupation and professional references.

• Government entities

• Other Service Providers

Education information – such as information contained in education records.

• Government entities

• Other Service Providers

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Contact Us

If you have any questions or requests in connection with this CA Notice or other privacy-related matters, please send an email info@iconmxusa.com