Information We Collect About Consumers.
Both Matter potentially collects the following categories of information about consumers, some of which may be collected or maintained in a manner such that it can be considered Personal Information:
Identifiers: Examples of the types of identifiers that Both Matter may collect include real names, nicknames, postal addresses, online identifiers, Internet Protocol addresses (“IP addresses”), email addresses, account numbers, Social Security numbers, driver’s license numbers, passport numbers, and other government identification numbers.
Other types of information: Examples of other types of information include physical characteristics or descriptions of you, telephone number, insurance policy number, education, employment, financial information including bank account, credit card, and debit card numbers, and health insurance information. It also includes additional information provided to Both Matter directly by you, such as when you complete a questionnaire, answer a survey, or receive a financial consultation. This category includes information identified as Personal Information in California Civil Code Section 1798.80(e) that is not otherwise categorized.
Characteristics protected under some laws: Examples of the types of characteristics that Both Matter may collect include age, national origin, citizenship, marital status, medical information, sex, sexual orientation, and veteran or military status.
Commercial information: Examples of the types of commercial information that Both Matter may collect includes records of business and other property owned, products or services purchased, obtained, or considered from Both Matter or our partners, and other purchasing or consuming histories or tendencies.
Internet information: Examples of the types of internet or other electronic network activity information that Both Matter may collect includes browsing history, search history, information about the device the consumer is using to access our website or applications, and information regarding a consumer’s interaction with Both Matter’s or our partners’ websites, applications, or advertisements. We may also collect information from visitors to our website such as browser settings, operating systems, referring/exit pages, and clickstream data. When we send you an email, Both Matter may also collect information, including about how you interact with that email.
Geolocation information: Both Matter may collect information about where a consumer resides or is otherwise located.
Audio and visual information: Both Matter may make audio recordings of calls with consumers. We may make visual recordings of consumers when they visit our premises or when consumers agree that Both Matter may take their photograph or videotape them. We may also collect visual images of consumers in other situations. We do not collect thermal or olfactory information.
Professional and employment-related information: Examples of the types of professional and employment-related information Both Matter may collect includes information about professional status and affiliations, employment history, and employment status.
Where We Collect Information About Consumers.
Related Consumers: We may collect information about you from someone you know. For instance, your spouse, coparent, or former spouse may provide contact information and other details about you.
Employers: We may collect information about you from your employer if your employer has elected to provide you with employment benefits through Both Matter. For instance, your employer will tell Both Matter when you are first eligible to receive services from Both Matter as part of your benefits.
Professionals: We may collect information about you from the independent professionals with whom you may consult as a result of your engaging Both Matter.
Business Partners and Affiliates: We may collect information about you from our business partners and affiliates. An example of the type of information that we may receive from business partners and affiliates is information about the product you purchased from them after you indicated an interest in an offer that Both Matter presented to you.
Publicly/Commercially Available Information: We may collect information related to you from publicly available sources of information, including government records and commercially available sources of consumer information.
Unrelated Parties: We may receive information related to you from people and entities with whom Both Matter does not have a direct relationship.
How We Use the Information We Collect About Consumers.
If, in the future, Both Matter wishes to use information about you in a manner that is not consistent with the purposes outlined below, we will seek your consent prior to the expanded use if and where we are legally required to do so.
Providing Products and Services: Both Matter collects information for the purpose of providing products and services. We may also use information to respond to inquiries from potential customers who are interested in learning more about our products and services. Examples of the types of uses of consumer information for these purposes include producing and delivering documents purchased by consumers, administering the Both Matter website, and displaying content based on consumer preferences.
Security: Both Matter collects information for the purpose of ensuring that we maintain appropriate security over computer networks and our physical facilities. We may also collect information for the purposes of detecting fraud or other suspicious activities.
Marketing: Both Matter collects information for use in marketing to current and prospective customers.
Product Development: Both Matter collects information for use in improving our existing products and developing new products.
Analytics: Both Matter collects information for use in performing various types of analytics. For example, Both Matter uses information to analyze how visitors interact with our website, where visitors to our website arrive from and exit to, and gaining insights into the types of consumers that may be interested in our products and services. We may also use information to develop inferences from the information we collect regarding consumer preferences, characteristics, predispositions, behaviors, and attitudes.
Operational Purposes: Both Matter collects information for use for our operational purposes, and the operational purposes of our service providers and business partners. For instance, Both Matter may use information for maintaining our website and other infrastructure, training and quality assurance, for conducting surveys or sweepstakes, to promote our brand, and to use in connection with our relationships with service providers and business partners.
Sharing with Business Partners: Both Matter collects information in order to provide business partners’ information in connection with consumers who have either expressed interest in hearing from the business partner or who have purchased a bundled product through Both Matter.
Financial Reporting: Both Matter collects information for use in various types of financial reporting and other similar internal uses. Examples of the types of financial reporting that Both Matter may use consumer information in connection with are internal budgets and projections, calculation of compensation, and reporting to investors.
In addition to the purposes listed above, Both Matter may also use de-identified or aggregate data that is not capable of being linked to any individual consumer for additional purposes not listed above.
How We Share Consumer Information and Who We Share It With.
Service Providers: Both Matter may share information about consumers with Service Providers who assist us. These entities are not authorized to use the information we share with them for any other purpose other than providing services to Both Matter or to you.
Professionals: Both Matter may share consumer information with the independent professionals that assist in our services.
Business Partners and Affiliates: Both Matter may share information with business partners and affiliates in limited circumstances. These include:
If you express interest in an offer made by a business partner, we may provide information about you in connection with the offer you have selected. If you later decide to opt-out from allowing Both Matter to share your information with business partners for their marketing purposes, you may do so by contacting Customer Care at email@example.com or (512) 537-7050. To the extent that Both Matter has already shared your information prior to your decision to opt-out, you may opt out from future marketing by contacting our business partners directly.
When you purchase a product from us that is bundled with a product offered by one of our business partners, we will share information about you with those business partners so that they can provide you with the product or services included with your purchase. These companies are not authorized to use the information we share with them about you for their own marketing purposes without first asking for your permission.
Employers: Both Matter may share information with employers who have elected to provide employment benefits through Both Matter. This is done for operational purposes, such as verification of employee emails.
Related Consumers: In limited circumstances, we may provide information about you to someone you know. For instance, we may provide information connected to your account with Both Matter to your authorized contacts.
Government Entities: Both Matter may share information about consumers with government entities in order to fulfill the products purchased by our customers.
Public Postings: Both Matter may publicly share information about consumers, such as by displaying the information on our website or having the information published in publicly available media, in a limited number of circumstances.
We may display personal testimonials of satisfied customers received through email surveys on our website or other marketing. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
When consumers leave us reviews either on the Both Matter website, or on other publicly available websites, we may display these customer reviews on the Both Matter website. If you provide a review that we display and wish to update or delete it, you can also contact us at support@BothMatter.com. We will delete your review at your request or if, at our discretion, we choose not to update your review as requested.
Our website includes areas where users may interact with each other, including a question and answer section. Any information that is provided in these areas of our website may be publicly available. You should use caution when deciding whether to disclose your Personal Information in these areas of the site. To request removal of your information from our community forums, contact us at support@BothMatter.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
When we collect publicly available information, we may share that information on our website.
Required by Law: Both Matter may disclose consumer information as required by law, such as in response to a subpoena, a lawful request by a public authority, including to meet national security or law enforcement requirements, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a legal request.
Related Parties: Both Matter may disclose consumer information with businesses controlling, controlled by, or under common control with Both Matter. If Both Matter is merged, acquired, or sold, or if some or all of our assets or equity are transferred, we may disclose or transfer consumer data in connection with the associated transactions.
In addition to the circumstances listed above, Both Matter may also share de-identified or aggregate data that is not capable of being linked to any individual consumer with additional entities not listed above.
This section expands on how Both Matter uses internet technologies, such as cookies, to collect information about consumers.
Web Beacons. We employ a software technology called clear gifs (a.k.a. web beacons), that help us track referrals from our partners and affiliates and better manage content on our website. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence.
Third Party Links
How You Can Control The Information Both Matter May Have About You.
This section describes how you can access and control the information that Both Matter may have about you. It applies to all consumers worldwide, including individuals who have purchased from Both Matter or who believe that information about them may have been provided to us by a third party. Depending on where you reside, you may have additional rights beyond what is described in this section. If you are a resident of California, please review the section “Information for California Residents” for more information about your rights.
Confirmation of Possession of Information Related to You. Upon a verified request, and subject to the privacy interests of others and technical limitations, Both Matter will provide you with information about whether we hold any information related to you. At Both Matter’s sole discretion, unless otherwise required by law, we may in some instances correct or delete information upon a verified request. Please note, however, that in certain circumstances we may be required by law to retain your Personal Information, or may need to retain your Personal Information in order to continue providing a product or service to you or another customer.
If you would like to submit a request about your data, you may do so by completing the form located here, or by calling us at (512) 537-7050. After you submit the request, you will be asked to verify your email address and may also be asked to provide additional information in order to verify your identity.
Opting Out of Email. We send promotional emails and newsletters from time to time to consumers who have provided us with their email address or whose email addresses we have obtained through other sources. You can opt-out of promotional communications by using the “Unsubscribe” link and following the unsubscribe instructions in an email you receive from us or by emailing us at support@BothMatter.com. We may also send service-related or transactional communications, which are not promotional. Generally, you may not opt-out of these communications. If you do not wish to receive service-related communications, you may terminate your account by contacting us at support@BothMatter.com or (512) 537-7050.
Opting Out of Marketing Calls. If you wish to be placed on Both Matter’s internal “Do Not Call,” you can tell us either while speaking to us on the phone or by emailing us at support@BothMatter.com.
Opting Out of SMS/Text Messages. If you wish to stop receiving SMS or text messages from Both Matter you can let us know by replying STOP to any SMS/text that you receive from us. You may also let us know by emailing or calling us at email@example.com or (512) 537-7050.
Data Retention. At minimum, we will retain your information for as long as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Both Matter may maintain some or all of this data in its archives even after it has been removed from the Site.
Information Processed On Behalf of Third Parties
In some instances, Both Matter may process Personal Information on behalf of third party affiliates. Both Matter acknowledges that in these instances, you have the right to access your Personal Information. Where Both Matter has no direct relationship with the individuals whose Personal Information it processes, individuals seeking access, or seeking to correct, amend, or delete inaccurate data, should direct their inquiry to the third party affiliate (the data controller).
IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED PLEASE CONTACT US IMMEDIATELY AT (512) 537-7050.
Information for California Residents.
If you are a resident of California, this section provides information regarding your rights, and Both Matter’s responsibilities, regarding your Personal Information.
California Resident Rights
California law allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ Personal Information give consumers access to certain information. This includes the specific pieces and categories of Personal Information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared.
Consistent with California law, if you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your information.
How to Submit a Request for Access to Information or Deletion of Information
Submit a request by emailing firstname.lastname@example.org or by calling support at (512) 537-7050.
After you submit the request you will be asked to verify your email address and may also be asked to provide additional information in order to verify your identity, including potentially providing a declaration under penalty of perjury. Both Matter will attempt to verify your identity by asking for information that correlates with the information that we have previously collected about you. Where this is not possible, Both Matter may request you submit additional information for verification, such as proof of residency or redacted government-issued identification. Please note that consistent with California law, we will be unable to satisfy your request until we have verified your identity.
You may also designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide Both Matter with written permission for the agent to make the request on your behalf or provide us with an executed power of attorney. You will also be required to submit your valid government issued-identification, and the authorized agent’s valid government-issued identification.
Changes To This Policy.
Attn: Privacy Team
8305 W Hwy 71, Suite 215
Austin, TX 78735
Created on March 3rd, 2020.