Effective date: March 1, 2022
In order to provide you with relevant information, respond to your requests, and increase the benefits you receive from the Services, we sometimes request that you provide us with information about yourself. This Policy sets out important information on where and how we collect your personal information, what we do with it, how we protect it, and what your rights are.
This Policy may change from time to time; we will post updates here when revisions are effective. You can determine when the Policy was last revised by referring to the “Effective date” at the top of this page.
What Personal Information We Collect and How We Collect It
We collect information, including personal information, when you use our Application. We may collect information meant to support you knowingly choose to disclose. We collect usage information as you and others use our Services. If you choose to correspond with us through e-mail, we may retain the content of your e-mail message together with your e-mail address and our responses. (We may gather information about you from third parties (e.g., employers) and combine it with other information we have collected about you.)
Information We Collect
Personal data is information that can be reasonably used to identify you or any other individual to whom the information may relate personally (“Personal Data”).
The types of information we collect may include:
- your first and last name;
- your title and your company’s name;
- your home, billing, or other physical address (including street name, name of a city or town, state/province);
- your e-mail address;
- your telephone number;
- any other identifier that permits Loyal (or those parties you authorize) to make physical or online contact with you;
- any information that Loyal collects online from you and maintains in association with your account, such as: your Loyal username, your Loyal password, your billing information.
We also use this information to provide you with information related to your account and the services you receive from us, to better understand your needs and interests, to improve our service, and to personalize communications.
Data may be collected from you automatically when you access or interact with the Services. We may collect information about how you access and use the Services (“Usage Data”). Usage Data may include information such as your device’s Internet Protocol address (“IP address”), the type of browser or application you are using to access the Services, browser version, the operating system, the time and date of your visit, the time spent in the Application, unique device identifiers, keystroke logging, and other diagnostic data. We may also collect information regarding the device(s) you use to access or use the Services.
When you use the Services with a mobile device, we may collect certain information automatically, including, but not limited to: the type of mobile device you are using, your mobile device unique identifier, the IP address of your mobile device, your mobile device operating system, the type of mobile internet browser you are using, unique device information, and other diagnostic data.
Usage Data may be tracked and recorded for purposes of enhancing your use of the Site and/or Services and maintained for session replay purposes. By using the Site, you agree to the collection, maintenance, and replay of this Usage Data to enhance your user experience.
Tracking and Cookies Data
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, some features of our Services may be unavailable to you.
We may use your Personal Data to connect you with newsletters, marketing or promotional materials, and other information that may be of interest to you. We have a legitimate interest in using your data for promotional purposes (see “Why We Collect Your Personal Data” below). We may know if you click a link in an email or other communication with us. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any e-mail we send. We may still send you non-promotional emails relating to our transactions with you.
How We Collect Your Personal Data
We may collect Personal Data in a number of circumstances and ways when you visit and/or use our Application, including when you:
- enroll in our Services;
- request support for our Services;
- you request information or materials;
- participate in surveys and evaluations;
- participate in trainings, webinars, and events;
- participate in promotions, contests or giveaways;
- submit questions or comments to us.
Why We Collect Your Personal Data
When you visit and/or use our Application, most of the Personal Data we collect is provided to us directly by you so that we can provide the Application. Your Personal Data is collected for our legitimate business interests or those of our service providers including as outlined below:
- To provide and maintain our Services, including to monitor the usage of our Services.
- To process, fulfill, and follow-up on your orders.
- To create and maintain your accounts.
- To register your services.
- To send you surveys.
- For the performance of our Services to you.
- To monitor, troubleshoot and improve performance of the Application.
- To contact you by phone, email, text message, or via other means regarding product updates.
- To register your Services and programs (at your request).
- To provide you with news, special offers, and general information about us and our products unless you have opted not to receive such information.
- To manage your requests, such as to attend and manage requests you direct to us.
- To provide customer support.
- To detect, prevent, and address technical issues.
- To gather analysis and valuable information so that we can improve the Services we provide to you.
Sharing and/or Disclosure of Your Personal Data
We (and our service providers) may share your personal information in the following situations:
- With website providers: We may share your Personal Data with website providers to monitor and analyze the use of our Application.
- With service providers: We may share your Personal Data with service providers to help us deliver our services to you, such as what may be required to fulfill orders, or to conduct billing/credit card processing.
- For business transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale or transfer of Company assets, financing, or acquisition of all or a portion of our business by another company.
- With affiliates: We may share your Personal Data with our affiliates.
- With business partners: We may share your Personal Data with our business partners, including potential employers.
- With third party vendors: We may share your Personal Data with third party vendors to provide behavioral remarketing, analytics, or advertising services.
We share aggregated anonymous information about you with third-party clients, partners, other web site visitors and other third parties. We may also aggregate data on an anonymous basis with respect to job qualifications, schooling, age, experience level or other information relevant to the job search or competition among job seekers for any such job. Such aggregated data does not identify users individually, and may be made available to employers, fellow job seekers, or community members.
We may supply technology and related services to healthcare providers (“Providers”) in order to facilitate their interactions with you either via their respective web sites or third parties such as Google (in either case, referred to as “Linked Sites”). If you are using our Services through a website, application or service provided by or on behalf of Google, please review the additional terms found at Section 9 at https://developers.google.com/business-communications/business-messages/support/tos/ and Section 11 at https://developers.google.com/business-communications/rcs-business-messaging/support/tos, which apply alternatively based on the specific service provided to you by or on behalf of Google and are hereby incorporated.
Additionally, you may be asked to provide information on your age, gender, or race where permitted by law. You should understand that this information should only be used in accordance with applicable law. However, we are not responsible for the actions of such Providers or other companies. All such information provided will be kept separate by us from your activities through the Services. Providing this information is strictly voluntary and you will not be subject to any adverse action or treatment from us if you choose not to provide this information.
We may disclose your Personal Data if we are required by law to do so or in response to legitimate requests of public authorities (e.g., a court or government agency).
Disclosure Through Business Transfers
We may buy, merge, or partner with another company or business and in doing so acquire or transfer Personal Data. Personal Data collected through the Application may be among the transferred business assets. In the event of an acquisition or merger, your Personal Data may be transferred so that we may continue to provide the Application to you. In the course of such a transaction your Personal Data would likely be considered a business asset, and, notwithstanding limitations imposed by applicable data privacy legislation, you hereby agree to such a transfer.
Other Reasons for Disclosure
We may disclose your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation.
- Protect and defend the rights of the Company.
- Prevent or investigate possible wrongdoing in connection with the Services.
- Protect the personal safety of users of the Services or the public.
- Protect against legal liability.
How Long We Keep Your Personal Data
The criteria used to determine our retention periods includes:
- The length of time we have an ongoing relationship with you and provide services to you or our customer (for example, for as long as you have an account with us or keep using the services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
In general, the third-party providers used by us will only be permitted to collect, use, and disclose your Personal Data to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers have their own privacy policies with respect to the information we are required to provide to them for your activities with the Application. For example, we may have agreements with your healthcare provider pursuant to which we provide them Personal Data and other data in connection with their services to you. For these providers, we recommend that you read their privacy policies to learn about the manner in which your personal information will be handled by these providers.
The Services we provide may be embedded in or include links to third-party websites, plug-ins, and applications. Interacting with those websites, including but not limited to clicking on those links or enabling those connections, may allow third parties to collect or share data about you. We are not responsible for these third-party websites, plug-ins, applications, or their respective privacy statements, and we expressly disclaim all liability of any kind whatsoever arising out of, in connection with, related to and/or resulting from any products, services, or information offered, provided, or collected by third-party websites, or any activities of third-party websites. We are not responsible for your use of these third-party websites, plug-ins, or applications. We make no warranty, express or implied, or any guarantee regarding any third-party websites, plug-ins, applications, or their respective privacy statements, or any products, activities, services, or information offered, provided, or collected by third-party websites, plug-ins, or applications. When you leave the Application, we encourage you to review the privacy policies of such third parties by visiting the links included within those separate websites, since their policies may differ from this Policy, and they may use information in ways other than those described in this Policy.
The security of your Personal Data is important to us, but remember that no method of transmission over the Internet is 100% secure. To protect your Personal Data, we endeavor to take commercially reasonable precautions designed to protect your Personal Data from inappropriate loss, misuse, access, disclosure, alteration, or destruction. Even so, technical mistakes are possible. No company, including us, can fully eliminate security risks associated with the transmission of Personal Data over the Internet.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.
Age of Consent
The Services are not intended for use by those under the age of 18, nor are they targeted to those under the age of 18. If you use the Services, you hereby represent and warrant that you are at least 18 years of age. No one under the age of 18 may provide any information to or on our Services.
We do not knowingly collect personal information from those under the age of 18, nor do we knowingly sell or otherwise disclose the personal information of those under the age of 18. If you are under the age of 18, do not (i) use or provide any information on our Services or through any of its features, (ii) use any of the interactive or fillable features of the Services, or (iii) provide any information about yourself to us, including your name, address, telephone address, e-mail address, or any other information that could be used to identify you.
California Privacy Rights
In this section, ‘Personal Data’ means information related to an identified or identifiable individual under the California Consumer Privacy Act of 2018 (CCPA) and subject to that law. If you are a California resident, you have certain data protection rights. Under the CCPA and California Civil Code § 1798.83, you have the right to exercise the following rights:
Disclosures of Personal Information We Collect
You have the right to know:
- The categories of Personal Data we have collected about you.
- The categories of sources from which we have collected Personal Data.
- Our business or commercial purpose for collecting or selling Personal Data.
- The categories of third parties with whom we share Personal Data.
- The specific pieces of Personal Data we have collected about you.
- Personal Data We Sell or Use for a business purpose.
In connection with any Personal Data we may sell or disclose to a third party for business purposes, you have the right to know:
- The categories of Personal Data that we sold.
- The categories of third parties to whom Personal Data was sold.
- The categories of Personal Data that we disclosed for a business purpose.
Categories of Personal information That We Collect and Disclose
The table below identifies the categories of personal information (as defined by the CCPA) that we have collected about consumers in the prior 12 months, as well as how we have disclosed such information for a business purpose (subject to our applicable legal and ethical obligations).
|Personal Information Collected||Disclosed for business purposes|
|Category||Description||Yes/No||Categories of third parties|
|Identifiers||Includes direct identifiers such as a name, alias, address, email address, user ID, IP address and other online identifiers and other similar identifiers.||Yes||Service providersClients|
|Customer records||Customer records: includes personal information, such as name, account name, billing and payment information, signatures, government identifiers and other information that individuals provide us in order to use our Services.||Yes||Service providers Regulatory and government entities Affiliates Clients Parties and related parties in legal matters|
|Protected classifications||Characteristics of protected classifications, such as age, gender, marital status, disability and health information that individuals provide to us.||Yes||Service providers Regulatory and government entities Affiliates Clients Parties and related parties in legal matters|
|Commercial information||Such as records of purchases and use of the Services and other products and services.||Yes||Service providers Judicial and quasi-judicial bodies Regulatory and government entities Affiliates Clients|
|Usage data||Internet or other electronic network activity information: including browsing history, search history, access logs and usage data, and other information regarding a person’s interaction with our Application||Yes||Service providers Judicial and quasi-judicial bodies Regulatory and government entities Affiliates|
|Audio, Video and Electronic Data||Includes audio, electronic, visual, thermal, olfactory, or similar information, such as thermal screenings and CCTV footage (e.g., collected from visitors to our offices for health and safety purposes), photographs and images (e.g., that you provide us) and records of calls, webinars and video conferences (eg, when you participate in one of our webinars).||Yes||Service providers Judicial and quasi-judicial bodies Regulatory and government entities Affiliates|
|Professional information||Includes professional and employment-related information such as your employer name, title, the nature of your responsibilities, and your practice area, specialties, qualifications and areas of focus.||Yes||Service providers Judicial and quasi-judicial bodies Regulatory and government entities Affiliates Parties and related parties in legal matters|
|Inferences||Includes inferences drawn from any of the information identified above to create a profile about you, such as reflecting your preferences and other characteristics.||Yes||Service providers Affiliates|
For more information on the categories of sources from which we collect information and our purposes for such collection, please see “What Personal Information We Collect and How We Collect It.”
In addition to the above, we may disclose the personal information that we collect to others, as necessary to comply with applicable laws or our legal and ethical obligations. We do not sell personal information about California residents, including those we have actual knowledge are younger than 16.
Right to Deletion
Subject to certain exceptions set out below, upon receipt of a verifiable request from you, we will:
- Delete your Personal Data from our records; and
- Direct any service providers to delete your Personal Data from their records.
Please note that we may not delete your Personal Data as permitted by applicable law. For example, we may retain your Personal Data if it is necessary to:
- Complete the transaction for which your Personal Data was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.
- Detect and protect against security incidents, fraudulent or illegal activity, or for prosecuting those responsible for such activity.
- Debug, identify, or repair errors that impair existing functionality.
- Exercise free speech.
- Comply with the California Electronic Communications Privacy Act.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all applicable ethics and privacy laws.
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
- Comply with an existing legal obligation.
- Otherwise use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information.
Exercise of Your Rights
You may exercise your rights indicated above by submitting a verifiable request as follows:
- Submit a rights request form
- Contact us at: [email protected]
For requests made in connection with the Right to Know and/or Right of Deletion, please note that we must take steps to verify your request before we can provide or delete information. To verify your request, we may require you to provide your name, physical address, email address, contact information, and information about your account or previous transactions with us. If we believe we need further information to verify your request as required by law, we may ask you to provide additional information to us.
You may authorize another individual to submit a request on your behalf through the means indicated above. As permitted by law, we may require the authorized agent to provide proof of your signed permission to submit the request and may require you to do one of the following: i) verify your identity directly with us; or ii) directly confirm to us that you have provided the authorized agent permission to submit the request.
Protection Against Discrimination
You have the right not to be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot:
- Deny goods or services to you; or
- Provide a different level or quality of services to you
Please note that we may charge a different price or rate to you if that difference is reasonably related to the value provided to us by your Personal Data. We may limit our response to your exercise of rights as permitted by law.
California’s Shine the Light Law
In addition to CCPA, California Civil Code § 1798.83 permits users that are residents of California to request the following information regarding our disclosure of your Personal Data to third parties for those third parties’ direct marketing purposes: (i) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and (iii) where the nature of the third parties’ business is not reasonably determinable, examples of the products or services marketed (if we have that information) . If you are a California resident and would like to make such a request, please email us at [email protected].
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Application does not respond to or support Do Not Track (DNT) signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party Web sites or online services. Third parties may collect personally identifiable information about individual consumer’s online activities over time and across third-party Web sites or online services. Loyal
If you would like to exercise one of your rights as set out in this Policy, or you have a question or a complaint about this Policy, or the way your Personal Data is processed, please contact us at [email protected].