Table of Contents
- What We Do
- Our Relationship to Consumers
- How We Collect, Store and Use Your Information
- Cookies & Related Technologies
- Data Sharing
- Consumer Choices & How to Opt-Out
- California Consumer Privacy Rights
- Additional Disclosures
- Online Tracking
- Information Security and Retention
- Independent Service Provider
- Geographical Restrictions
- Changes to this Policy
- Questions or Comments
EFFECTIVE DATE: JANUARY 1, 2020
WHAT WE DO
Balboa Digital provides 3rd party Services for many Clients. For these Clients, Balboa Digital acts in the role of a contracted agent. In this role, and using our Client’s branded name, our primary Services are (1) take inbound phone calls and messages to support sales or customer support for the Client, and (2) make outbound phone calls or send messages in response to Client product or service inquiries where the Consumer has provided expressed consent for our Client, or us as the Client’s agent, to make a contact attempts via human or automated means.
OUR RELATIONSHIP TO CONSUMERS
HOW WE COLLECT, STORE AND USE YOUR INFORMATION
There a few sources of Consumer PI which may be received, stored or transmitted by our systems:
- Data that is posted to Balboa Digital by a Client in order for us to perform Services.
- Data that is volunteered by you in a phone call or message.
- CallerID data that is provided by our telephone provider.
- 3rd party data attributes that are directly or indirectly matched or related to your Consumer PI.
|Category of Personal Information||Source of Personal Information|
|Identifiers (e.g. name, email address, postal address, website(s) visited or other similar identifiers)||Client, telephone provider or during contact|
|Demographics (e.g. age, gender, race, or other protected classifications under applicable law)||Client, during contact, or 3rd party|
|Commercial information (e.g. products or services purchased, or other purchasing or consumption histories or tendencies)||Client, during contact, or 3rd party|
|Professional information (e.g. employer, salary, or job title)||Client, during contact, or 3rd party|
|Educational information||Client, during contact, or 3rd party|
|Inferences regarding other characteristics (e.g. Derived Data, as defined below)||Derived by Balboa Digital|
When we provide our Services to our Clients, our Contact Center Platform (“Platform”) facilitates the capture of data from each Consumer contact or attempted contact, which includes, but is not limited to, Consumer volunteered information, call recordings, text from messages, time stamps, outcomes of contacts and all associated history of these contact events. For our Clients utilizing the Services, certain “Derived Data” may be used internally and provided to the Client for periodic reporting, trending purposes and for the performance management of Services.
The following categories of your Consumer PI may be shared with Clients during the fulfilment of Services:
- Commercial information;
- Internet or other electronic network activity information;
- Professional information;
- Education information; and
- Inferences regarding preferences or other characteristics.
Your Consumer PI is gathered, stored and transmitted within the boundaries of the Services provided to the Client. We do not sell or transmit your Consumer PI to any other party.
A Client may provide certain additional information in its possession, such as conversion data, Identifiers, and/or other Consumer PI (“Contributed Data”) when utilizing certain aspects of our Services. If any Contributed Data is provided by a Client, this information is utilized solely to generate applicable Derived Data (which does NOT contain your name or other contact information) associated with that query. We rely solely on our Clients to have secured the proper permissions from Consumers or other sources where they have been provided with the Contributed Data.
CONSUMER CHOICES AND HOW TO OPT-OUT
We recognize how important online privacy is to Consumers, and we support the following options for Consumers to control or opt out of certain collection and disclosure of information:
- Opting out of Internet-based advertising. Our Clients may use certain insights gained by the use of our Services and Platform to tailor the advertising Consumers see on our Clients’ websites. We do not deliver advertising on our own, including targeted advertising. Consumers may be able to opt-out of Interest-based advertising by our Clients either through options provided through the websites Consumers visit and interact with, or by using an industry-wide opt-out tool, such as:
- Digital Advertising Alliance (DAA):
- National Advertising Initiative (NAI):
Please note that in some cases, Consumers will still see advertisements after opting out; these advertisements may just not be tailored to the Consumers’ interests.
- Digital Advertising Alliance (DAA):
- Opting out of cookies and beacons. If a Consumer does not want cookies placed on the Consumer’s device at all, the Consumer can adjust the device’s browser settings to display a notification before any cookie is placed. Browser settings may also be changed to refuse all cookies, or only third-party cookies. Likewise, the Consumer can remove any cookies that have already been placed on the device. Please note that settings may need to be adjusted on each browser and device used by the Consumer.
CALIFORNIA CONSUMER PRIVACY RIGHTS
California law provides California residents with the following privacy rights:
- Right to access personal information: Individuals exercising this right may request access to the categories and specific pieces of their personal information we have collected in the prior 12-month period. Individuals exercising this right may receive their personal information, when provided electronically, in a readily-useable format. You can exercise your rights here: Request to know.
- Right to deletion: Individuals exercising this right can ask us to delete their personal information we have collected, though we may be permitted to retain personal information for certain purposes. You can exercise your rights here: Request to delete.
- Right to disclosure: Individuals exercising this right can receive additional information regarding the sources from which we collect information, the purposes for which we collect and share personal information, the information of theirs we hold, and the categories of parties with whom we share their information.
- Right to opt out of sales: As permitted by applicable law, we may share your personal information for monetary or other valuable consideration (under California law, this is considered a “sale”). You may opt out of such a “sale” of your personal information to third parties. You can exercise your right to opt-out here: Do Not Sell My Info.
- Right to be free from discrimination: Users may freely exercise these rights without fear of being denied goods or services.
Currently, this law specifically applies to California residents, but Balboa Digital will respond to requests to exercise your rights which we receive from any resident of the United States or Canada. If you are a resident of California, the United States, or Canada, and would like to exercise one of your rights, please contact us at firstname.lastname@example.org or through our CCPA Privacy Request Form.
You may designate an authorized agent to request the exercise of one or more of these rights on your behalf. Please note all consumer requests are subject to verification and there may be circumstances where we do not honor your request, as permitted under the law. We may verify your request by asking for additional information about how you found out about Balboa Digital, who referred you to Balboa Digital to make a request (which Client referred you to us) and which websites you made the same requests to; and we will need to be able to verify with that Client as to the validity of your request first. If you are using an authorized agent, such requests are subject to the same criteria.
In addition to the specific disclosures of data related to our Services and Platform described above, we may also disclose or share data collected under the following circumstances:
- As required by appropriate third parties, including government and law enforcement authorities, if we have a good faith belief that disclosure of such data is reasonably necessary to (i) satisfy applicable law, regulation, legal process, or an enforceable governmental request; (ii) enforce our agreements with Clients, including in the course of investigation of potential breaches of such agreements; or (iii) detect, prevent, or otherwise address fraud, security, or technical issues;
- To protect against harm to the rights, property, or safety of Balboa Digital, our Clients, Consumers, or the public, as required or permitted by law;
- In the event we go through a business transition, such as a merger with, or acquisition by, another company; or the sale of all or a portion of our assets, we may disclose data to the party or parties involved in preparation for, and as incident to, such business transition; and
- To aggregate data for reporting, analytics, and other business reasons, including to promote or describe the use of our Services and Platform.
As described above, our Platform does implement technologies, including cookies, which enable the identification of a web user’s device as it interacts with different websites and applications. We do not recognize or honor Do Not Track signals or similar mechanisms.
INFORMATION SECURITY AND RETENTION
We use security measures to protect against unauthorized access to and unauthorized alteration, disclosure, and destruction of data collected, processed, and stored by our Platform. These security measures include firewalls; encryption; internal reviews of our data collection, storage, and processing practices; obligations of confidentiality; and restrictions on logical and physical access to data. However, we are unable to guarantee that the security measures we take will not be penetrated or compromised or that information will remain secure under all circumstances. In the event we utilize third party services in the provision of the Platform, we rely on those third parties’ representations and warranties. We retain information we collect through or Services and Platform indefinitely, or as required by applicable law.
Our Services are limited to companies who are interested in a formal business relationship. We do not knowingly collect, maintain, disclose, or sell information from individuals who are under 16 years of age, and no part of our Platform is designed to attract people under the age of 16. Protecting the privacy of children is very important to us. If we obtain knowledge that a Client or Consumer is under the age of 16, we will take steps to remove that individual’s information from our databases.
INDEPENDENT SERVICE PROVIDER
Our Platform and Services are intended for use solely within the United States of America and Canada and is directed to Clients solely located in those locales. We make no representation that our Services or Platform is appropriate or available for use in locations outside the United States. Unless otherwise expressly stated, all marketing or promotional materials found on or accessible through this website are intended to be directed to individuals, companies, and other entities located in the United States of America or Canada.
QUESTIONS OR COMMENTS
Balboa Digital LLC
1502 Foothill Blvd.
Ste. 103 PMB 153
La Verne, CA 91750