ONE10 WEBSITE PRIVACY POLICY

One10 LLC Privacy Notice

Effective Date: June 1, 2017
Last Updated: September 1, 2021

One10 LLC, d/b/a One10 or One10 Marketing (“One10,” “us,” "we," or “our”) is committed to protecting and respecting the privacy of our customers and those who use our websites, including but not limited to the www.one10marketing.com (the “Site”), and our products, mobile application(s) (“Application(s)”) and services (collectively the “Services”). This Privacy Notice describes One10’s policies and practices regarding our collection and use of your personal data or information and sets forth your privacy rights. We recognize that data privacy is an ongoing responsibility. We will from time to time update this Privacy Notice as we adopt new privacy practices and policies in response to updates in the law, to align with changing industry best-practices, and to reflect our product enhancements.

You can jump to particular topics by going to the headings below:

Types of information We Collect

The following provides examples of the type of information that we collect from you and how we use that information.

Context Types of Data Primary Purpose for Collection and Use of Data
Account Information We collect your name, e-mail address, physical address, social security number, password, date of birth, account balance, transaction history, and in certain instances, telephone number of our clients and their employees with whom we may interact. We have a legitimate interest in contacting our clients and their program participants and communicating with them concerning normal business administration such as projects, services, and billing.
Client 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 Site. 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 the 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 web site is viewed. We have a legitimate interest in making our Site 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. We have a legitimate interest in engaging in behavior-based advertising and capturing Site analytics.
Demographic Information We collect personal information, such as your age, gender, home address, phone number, email address, business title, business phone, business email, business address, business region Passport information, NIN number, Credit Card number, special needs and dietary preferences. We have a legitimate interest in understanding our users and providing tailored services.
Distance Information When you use our Services we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device. We have a legitimate interest in understanding our users and providing tailored services. In some contexts our use is also based upon your consent to provide us with geo location information.
Email Interconnectivity If you receive 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.
Employment If you apply for a job posting, or become an employee or work with us, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment. We use information about current employees and those who work with us to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations.
Feedback/Support We collect personal data from you contained in any inquiry you submit to us regarding the 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.
Mobile Devices We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our Site or using our Services. We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
Order Placement We collect your name, billing address, e-mail address, phone number, and credit card number when you place an order. We use your information to perform our contract to provide you with 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 Site. 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 Site 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 the visitors to our Site. Among other things, it helps us understand which of our services is the most popular.
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. For example, if you submit a job application, or become an employee, we may conduct a background check or a credit check for purposes of a new business customers becoming a new users.

How We Use Your Information

In addition to the purposes and uses described above, we use information in the following ways:
  • To provide the Services.
  • To provide you with other services requested by you.
  • To respond to your comments, questions, or requests.
  • To store user preferences.
  • To disseminate push notifications through the Application.
  • To manage our business needs, such as monitoring, analyzing, and improving the Services and the Site’s performance and functionality.
  • To manage risk and protect the Services.
  • To market to you.
  • To comply with our legal and regulatory obligations.
  • For internal administrative purposes, as well as to manage our relationships

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 our 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 the Services.  As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

How We Share Your Information

We do not rent, sell or otherwise disclose personal information about our customers or users with unaffiliated third parties for their own marketing use. In addition to the specific situations discussed elsewhere in this Privacy Notice, we disclose information in the following situations:

Affiliates and Acquisitions. We may share your personal information with other One10 entities, brands, and divisions to serve you, including for the activities listed above. We may also share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).  If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.

Our Business and Service Partners. We share your information with service providers.  Among other things service providers help us to administer our website, conduct surveys, provide technical support, process payments, provide travel-related services, and assist in the fulfillment of orders.

Public.  Some of our Services may provide the opportunity to post comments, or reviews, in a public forum.  If you decide to submit information on these pages, that information may be publicly available.

Other Disclosures with Your Consent.  We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Notice.

Legal Requirements and Business Transfers. We may disclose personal information (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other government official requests, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iii) in connection with an investigation of a complaint, security threat, or suspected or actual illegal activity; (iv) in connection with an internal audit; or (v) in the event that One10 is subject to a merger or acquisition to the new owner of the business.

Your Choices

We offer certain choices about how we communicate with you and what personal information we obtain about you and share with others.

Profile. If you have created a profile or account for the Services, you can update your contact information after you log into your account or by contacting your program sponsor.

Mobile Devices. If you previously chose to receive push notifications on your mobile device from us but no longer wish to receive them, you can manage your preferences either through your device or the Services settings. If you no longer wish to have any information collected by the Services, you may uninstall the Services by using the uninstall process available on your mobile device. We encourage to you to visit your device’s help menu to learn about your options to limit tracking when using your device. For some information on controlling your mobile choices, click here.

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 may unsubscribe from emails from us by clicking the unsubscribe link at the bottom of any promotional email from us. You may also contact us by e-mail or postal address as noted below. Please include your current contact information, the information you are interested in accessing and your requested changes. If you decide not to receive promotional emails, we may still send you service-related communications.

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.”

Your Privacy Rights

Under the GDPR, EU residents have the existence of certain choices with respect to their personal information. You can make the following choices regarding your personal information:

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. We will provide this information in a portable format, if required. 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.

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

Deletion Of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice, 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 email 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.

Complaints and Objections to Certain Processing. We are committed to resolving valid complaints about your privacy and our collection or use of your personal information.  For questions or complaints regarding our data use practices or Privacy Notice please contact us at privacyofficer@one10marketing.com.

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.

You may exercise these rights by contacting us at privacyofficer@one10marketing.com.

We will respond to any such request in a timely manner as specified by the GDPR. If we need more time to fulfill your request, we will let you know in advance. We will not exceed the legally specified time limit under any circumstance.

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, a company determined identifier, program or campaign you are enrolled in, 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, signed written notice indicating that you have 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.

How We Keep Your Information Secure

One10 has implemented reasonable physical, technical, and administrative security standards to protect your personal information from loss, misuse, unauthorized access, alteration, or destruction. Although we take reasonable steps to safeguard personal information, no practices are 100% secure, and we do not guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. You must protect against unauthorized access to your computer and important information. We strongly recommend that you log off each time you finish using a shared computer.

Retention of Your Information

We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it.  See the Section “Your Choices” about storage of your personal information.

Other Important Information

California Users – Your California Privacy Rights.  If you are a California resident, California law indicates that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law).  You can find a list of the categories of information that we collect and share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing during the immediately preceding calendar year. please submit a written request to us using the information in the "Contact Information" section below.  Please note that a request does not ensure complete or comprehensive removal of the information you have posted. There may be circumstances in which the law does not require or allow removal even if requested. We do not discriminate against California residents who exercise any of their rights described in this Privacy Notice.

Transmission Of Information To Other Countries. One10 is located in the United States.  Our service providers and other third parties you may interact with in connection with our Services may be located in the United States and other countries around the world. As a result your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country.  Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information.  By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.  To the extent personal information is collected and subsequently transferred out of the European Economic Area, the transfer will take place consistent with the Standard Contractual Clauses. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.

Children’s Use of Our Services. Under no circumstance may persons under the age of 16 use this Services.

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

Links to Third-Party Websites.  Our Services may provide links to other websites that we do not control or maintain. Those websites have their own privacy policies and we are not responsible for their actions or those of their operators. We urge you to read the privacy policies of other websites before submitting any information to those websites.

Changes to This Privacy Notice. We may change our Privacy Notice and practices over time.  To the extent that our Privacy Notice changes in a material way, the Privacy Notice that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new Privacy Notice.  Our Privacy Notice includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.

Dispute Resolution. As this Privacy Notice is part of our Terms of Use, any disputes involving you and us that relate to privacy or the use of your information, and that arise out of or are related to this Privacy Notice or our Services, will be subject to our Terms of Use, including any provisions regarding the limitation of damages and liability, choice of law, and dispute resolution.

Contact Information.  If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below.  We will attempt to respond to your requests and to provide you with additional privacy-related information.

One10 LLC
100 N. Sixth Street, Suite 700B
Minneapolis, MN 55403
Phone Number: (763) 445-3000

privacyofficer@one10marketing.com

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.