Effective June 7, 2024
Welcome to the ABLE website! By using our “Website” (www.growwithable.com and my.growwithable.com) and our services (“the ABLE system”), you consent to the collection and use of information you submit as described in this Privacy Policy.
This Privacy Policy serves as an agreement between The Growth Partnership (“Company”) and any person or business (each a “User” or “Client”) that visits the Website or accesses or uses the ABLE system. “We” are the Company, and “You” are the “User” or “Client.” Individual accounts must be associated with an organization registered with the ABLE system (“Registrant Organization”).
“Personal information” is data about an individual who can be identified from that data or from that data and other information to which one has access. Personal Information is usually your name in combination with another identifier, such as date of birth, postal address, email address, telephone number, or government-issued identification number. The specific definition of Personal Information often varies from one jurisdiction to another.
What Personal Information Do We Collect?
We are a B2B service, so our clients are typically businesses, and their individual employees act on behalf of the businesses. That said, when you use the ABLE system or contact us, we may collect a variety of personal information, including your name, mailing address, phone number, email address, and contact preferences.
How Personal Information is Collected?
We collect most of this personal information directly from you—in person, by telephone, text, email, and/or via our website. However, we may also collect information:
- From publicly accessible sources (e.g., social media accounts);
- From cookies on our website; and
- Via our IT systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email, and instant messaging systems.
How Do We Use Your Personal Information?
We may use your Personal Information to identify your account, track your use of the Website, transact business with you in connection with the ABLE System, assess your degree of satisfaction with the ABLE system or the Website, update you about the ABLE system, to improve the effectiveness of the Website or the ABLE system; to prevent, deter and investigate violations of this Privacy Policy and our Terms and Conditions, or any fraud and other illegal activities, and to send you important notices regarding the ABLE system and changes to our business policies.
With Whom Do We Share Your Personal Information?
We may share your Personal Information with third parties who may help us operate the Website or help us assess your interest or satisfaction with the Website or the ABLE system.
We may disclose your Personal Information if we determine that disclosure is reasonably necessary to enforce our Terms and Conditions and this Privacy Policy or to otherwise protect our operations, clients, or users.
We may release your Personal Information to others (including law enforcement) if we believe such release is reasonably necessary to comply with the law or legal process; enforce or apply the terms of applicable terms of use; detect, prevent, or otherwise address fraud, security or technical issues; or otherwise protect the rights, property or safety of others.
We may sell, transfer and/or disclose your Personal Information as part of a business divestiture, sale, merger, or acquisition of all or a part of our business. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset.
How Long Do We Retain Your Personal Information?
We will keep your personal information while you have an account with us or provide services. After that, we will keep your personal information for as long as is necessary:
• To respond to any questions, complaints, or claims made by you or on your behalf; • To show that we treated you fairly; or
• To keep records required by law.
We will not retain your personal information longer than necessary for the purposes set out in this policy. Different retention periods apply to different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.
How Do We Protect Your Personal Information?
We maintain various security measures, including physical, electronic, and procedural safeguards. No system can be completely secure, so we do not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure.
Your Access to Personal Information
You can ask us for the Personal Information we possess so that you can determine if it is inaccurate or if you want it deleted, provided we are not required to retain it by law or for legitimate business purposes.
We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made to [email protected].
What Other Information Do We Collect?
We automatically gather information when you browse or view the Website. This log data may include your browser type (e.g., Chrome, Safari, Firefox, or Internet Explorer), your domain, the Internet Protocol (IP) address assigned to your computer (or the unique device ID of your mobile device or other unique identifier), the date and time of your visits, the pages on the Website you visit, and other information related to your visit.
We collect data that does not permit direct association with any specific individual. We may collect, use, transfer, and disclose such non-personal information for any purpose. If we combine non-personal information with your Personal Information, we will maintain it as Personal Information for as long as it remains combined.
We may collect details of how visitors to the Website use our services.
How Do We Employ Cookies and Similar Technologies?
We use technologies such as “cookies” and web beacons to remember certain information about you and your preferences or recognize you when you return. They also help us compile aggregate data about Site traffic and Site interaction to improve the Website and protect it from fraud.
A cookie is a text file that is stored on your computer. As text files, cookies cannot read information on your hard drive, run programs, or deliver viruses to your computer. Cookies let the Website remember your preferences or recognize you when you return.
Most browsers are set to accept cookies automatically. You can set your browser to decline all cookies automatically or to prompt you for a response each time a cookie is offered. Note that declining cookies may hinder the Website’s performance and may not allow you to access all its features and services.
Web beacons, known as clear GIFs, are often combined with cookies. These often transparent images are part of web pages and allow us to count users who have visited certain pages and generate statistics about how the Website is used. They are not used to access Personal Information.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
Like many websites, we gather some information automatically, such as Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exiting websites and applications, operating system, date/time stamp, and clickstream data.
In some of our email messages, you will find a “click-through URL” linked to content on the Website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. You should not click such links in our email messages if you prefer not to be tracked this way.
You should be able to adjust your mobile device’s privacy and security settings to manage how your mobile device and mobile browser share location information with us and how your mobile browser handles cookies and related technologies.
There are “do not track” or similar browser choices available to internet users regarding online web activity. Still, given the present lack of consensus on what constitutes an informed election, appropriate trigger, or breadth of scope of such choice, the Website will not operate differently when a “do not track” signal is received.
Personal information that clients maintain on the ABLE system
You are solely responsible for the Personal Information you collect from your own customers and maintain on the ABLE system. You are responsible for determining with whom you share it or how you use it. Customers of Clients should look to those clients for their Privacy and other policies regarding using Personal Information.
You are expected to adhere to CAN-SPAM and similar laws in communicating with your customers and other individuals, and you should obtain any necessary consent from your customers before sending them marketing materials.
Social Networking Sites
You may be able to post content to Social Networking Sites (such as Facebook, Instagram, Snapchat or Twitter) on which we maintain a presence. If you choose to do this, we will provide information to the Social Networking Sites in accordance with your elections. You acknowledge and agree that you are solely responsible for using those websites and must review the terms of use and privacy policies. We are not responsible for the availability, accuracy, content, products, or services of such Social Network Sites.
Third-Party Links
The Website may have links to or be linked to other sites we do not own, control, or maintain. We are not responsible for and make no representations or warranties about the privacy practices of those sites. We recommend that you check the privacy policies of other sites and contact the operator if you have concerns or questions. Nonetheless, we seek to protect the website’s integrity and welcome any feedback about these third-party sites.
Children
The Website is not directed to minors. If we learn that we collected personal information from anyone under 13, we will endeavor to delete such information as soon as possible.
Your Privacy Rights
If you would like to exercise any of your rights described in this Privacy Policy, please email us at [email protected].
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly by website or email, you will need to provide us with:
• Enough information to identify you (e.g., your full name, address and customer reference number);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or if someone is authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
If you are a California resident, please see our ‘ADDITIONAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS’ section, which includes additional disclosures as required by California law.
Opting Out of Communications
You may opt out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us or by changing the communication preferences on your online account or profile. If you have difficulty unsubscribing from our marketing communications using the above methods, please get in touch with us at [email protected].
Even if you opt out of receiving marketing emails or text messages, we may still need to contact you about your orders, customer service inquiries, promotion participation, and other matters. If you agreed to receive future marketing communications directly from a third party through the Website, you will need to contact that party to opt out of such communications. This process may be outlined in that party’s Privacy Policy.
Changes to our Privacy Statement
We may update this Privacy Statement occasionally, so please check the effective date at the top of this page as the date of the last revision. Changes will become immediately effective upon posting on the Website unless otherwise noted. Following these changes, your use of the Website indicates your consent to the practices described in the revised Privacy Statement.
Contacting Us
If you have any questions regarding this privacy policy, contact us at [email protected]. If you need to contact the company to file a complaint, contact us at [email protected].
ADDITIONAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires us to provide some additional information to California residents. This Section only applies to you if you are a California resident, although please note that this information and the rights afforded herein are the same as offered to our other users in our main Privacy Policy. This Section does not apply to the personal information we collect from our employees and job applicants in their capacity as employees and job applicants, as such information practices are described in separate policies.
The following chart details these activities:
For more information about each category of personal information, the purpose of use, and third parties to which we disclose personal information, please see the “What Personal Information Do We Collect,” and “How Personal Information is Collected” sections of our Privacy Policy.
Your Choices Regarding “Sharing” and “Selling”: You have the right to opt out of our sale/sharing of your personal information for purposes of online analytics and advertising. Currently, we do not sell or share your data as defined by the CCPA and we have not done so over the past 12 months from the effective date of this Privacy Policy.
Other CCPA Rights. If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.
The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.
Please see the “Your rights with respect to your information” section of our Policy above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.
Retention of Your Personal Information. Please see the “How Long Do We Retain Your Personal Information” section in our Privacy Policy for more information.
Shine the Light Disclosure
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We currently do not disclose your personal information to third parties for their own direct marketing purposes.
For any questions, please send an email to [email protected] or write to us at:
The Growth Partnership
303 Evernia Street, Suite 300
West Palm Beach, FL 33401