Privacy Policy
Effective Date: July 14, 2024
OPORA.DIGITAL, WE BELIEVE PRIVACY & CONSENT IS A CORNERSTONE OF TRUST.
OUR COMMITMENT TO OUR USERS
We don’t ask you for your personal information unless it is absolutely necessary for you to
contact us to hear about our services, join our newsletter, download or sign up to receive
content, offer our services, or join our team. We take a “Minimum Viable Data” approach to
all data collection practices and ensure we are never collecting additional information
beyond the necessary scope of service.
We limit sharing your personal information where possible, but will occasionally share it with
trusted partners for the purposes of co-marketing and co-sponsoring events, and to comply
with applicable laws, develop, enhance or modify our services or protect our rights.
We don’t store personal information on our servers unless required for the on-going
operation of one of our Services on behalf of our Clients or as specified on our website
forms.
OPORA.DIGITAL (“OPORA.DIGITAL,” “we,” “us,” or “our”) operates opora.digital the
subdomains, and all portals, products, services, events, and interactive features, or other
services controlled by us that post a link to this Privacy Notice (the “Site”). It is
OPORA.DIGITALs policy to respect your privacy regarding any information we may collect
while operating the Site. This Privacy Notice governs information that we collect from you on
the Site. We refer to all of the above as “Services.” This Privacy Notice only applies to
Personal Information and other information collected by us from: (i) visitors to the Site (“Site
Visitors”); (ii) our current and prospective customers and Clients (“Clients”); and (iii) people
applying for employment with OPORA.DIGITAL (“Employment Applicants”). If you have
questions about this Privacy Notice, contact us at privacy@opora.digital
OPORA.DIGITAL is a data controller for data collected on the Site and in most cases is a
data processor for our Clients.
1. PERSONAL INFORMATION COLLECTED
1.1. PERSONAL INFORMATION YOU PROVIDE DIRECTLY TO US
As you interact with the Site or Services, OPORA.DIGITAL may ask you to provide us with
certain personal information that can be used to contact or identify you (“Personal
Information”) via webforms or inputs/uploads on the Site, and through webinars, events,
telephone calls, letters, emails, texts and other communications with you. Personal
Information includes, but is not limited to the following:
Site Visitors
Contact information such as your first and last name, email address, job title, home
or business address, telephone numbers, mobile numbers.
Social media account information; and
Other information that could reasonably be used to identify you personally.
Clients
Contact information such as your first and last name, job title, email address,
business address, shipping address, telephone numbers, mobile numbers; and
Financial information such as your business credit card or debit card number, bank
account information and your payment, service and purchase history.
Employment Applicants
Contact information such as your first and last name, email address, home or
business address, shipping address, telephone numbers, mobile numbers;
Your current or past employment or educational information;
Relevant licenses and certifications; and/or
Other information that could reasonably be used to identify you personally.
Your decision to provide us with Personal Information is voluntary, but if you choose not to
provide any requested Personal Information, you may not be able to take advantage of all
the features of the Site or Services.
1.2. INFORMATION AUTOMATICALLY COLLECTED FROM THE SITE
Like most website operators, OPORA.DIGITAL collects non-personally identifying
information of the sort that web browsers and servers typically make available, such as the
browser type, language preference, referring site, and the date and time of each Site Visitor
request. OPORA.DIGITAL’s purpose in collecting this non-personally identifying information
is to better understand how Visitors use the Site.
OPORA.DIGITAL may also collect potentially personally identifying information like Internet
Protocol (IP) addresses. OPORA.DIGITAL only discloses IP addresses under the same
circumstances that it discloses personally identifying information as described below.
For location information, some of our Services may include features based on an individual’s
actual location and may report on an individual’s current location (“Location-Based
Services”). To the extent you use any Location-Based Services, we may collect and store
information about your location at the time you use those Location-Based Services (in
addition to some automatically collected geolocation data). This information can come from a
variety of sources depending on the device you use to access the Services; for example, a
mobile phone may report its GPS location at the time Location-Based Services are used.
If you no longer wish for us to collect and use location information, you may disable the
location features on your device. Consult your device manufacturer settings for instructions.
Please note that if you disable such features, your ability to access certain features,
Services, content, or promotions may be limited or disabled.
1.3. INFORMATION RECEIVED DIRECTLY FROM CLIENTS
OPORA.DIGITAL may receive data, including personally identifiable or aggregate
data, from our Clients that we process per a contract in place with these Clients. We
do not have a direct relationship with these individuals and are acting as a service
provider to our Clients in this instance. While we maintain this data, we are only
permitted to use it at the direction of the Client to provide the Services we are
contracted to provide.
1.4. COOKIES
A cookie is a string of information that a website stores on a visitor’s computer, and
that the visitors browser provides to the website each time the visitor returns.
OPORA.DIGITAL uses cookies to help us identify and track Site Visitors, their usage
of the Site, and their website access preferences. Site visitors who do not wish to
have cookies placed on their computers should set their browsers to refuse cookies
before using the Site, with the drawback that certain features of the Site may not
function properly without the aid of cookies.
1.4.1. What Kinds of Cookies and Tracking Technologies Do We Use?
The Site may use Strictly Necessary Cookies, Performance Cookies, Functional
Cookies, Targeting Cookies and Social Media Cookies. Any of these may be
first-party cookies or third-party cookies, persistent or session.
Strictly Necessary Cookies: These are cookies without which you would not be able
to use the Site. For example, Strictly Necessary Cookies adjust the Site data
transmitted to match your Internet connection, get you to the secure versions of the
Site, and help provide services you specifically request. If you set your browser to
block these cookies, some parts of the Site will not work. Strictly Necessary Cookies
do not store any Personal Information.
Performance Cookies: We use these cookies to count visits and traffic sources, to
measure and improve Site performance. They help us to know which pages are the
most and least popular and see how Site Visitors move around the Site.
Performance Cookies do not store any Personal Information. Specifically, for
analytics providers, we use Google Analytics, Yandex Metrika. You can also request
access, correction, updates or deletion of your Personal Information we collect via
MailChimp. If we have collected and process your Personal Information with your
consent, then you can withdraw your consent at any time by contacting us or clicking
on the “unsubscribe” link located at the bottom of our email communication.
Withdrawing your consent will not affect the lawfulness of any processing we
conducted prior to your withdrawal, nor will it affect processing of your Personal
Information conducted in reliance on lawful processing grounds other than consent.
To exercise these rights, please contact us at privacy@opora.digital. For more
information on the privacy practices of MailChimp, please visit their Privacy Policy:
https://mailchimp.com/legal/
Functional cookies: These cookies allow the Site to remember choices you make
and provide enhanced functionality and more personalized features. Depending on
context, Functional Cookies may store certain types of Personal Information as
needed to provide functionality.
Targeting Cookies: Targeting cookies help us manage and display our
advertisements, based on your activity on the Site and other websites; this is known
as interest-based advertising. Targeting cookies mainly rely on uniquely identifying
your browser and internet device.
We may also use third-party service providers to show advertisements, which may
include targeted advertisements on a third-party website after you have visited the
Site. We and the third-party service providers use cookies to inform, optimize,
measure performance and serve ads based on your previous visits to the Site. Any
tracking that a third-party performs is subject to their own privacy notice. Our
third-party service providers may provide us information that tells us how our
marketing ads, often placed on third-party websites, performed and who clicked on
them. This information does not identify any specific individual and is generally
non-identifying. If we were to associate it with you, we would treat it as Personal
Information.
Social Media Cookies: Social Media Cookies make social sharing easier for you,
provide you with tools to connect with the Site, and help us better understand both
the audience for the Site and the effectiveness of our social media outreach. These
are third-party cookies. Your choices with respect to such cookies are determined by
the social media platforms on which you have accounts. Social media cookies store
Personal Information as needed to provide functionality.
1.4.2. Don’t Want Cookies?
Most web browsers let you choose whether to accept cookies. Most also let you
delete cookies already set. The choices available, and the mechanism used, will vary
from browser to browser. Such browser settings are typically found in the “options”,
“tools” or “preferences” menu. You may also consult the browsers “help” menu. For
example:
Chrome
Firefox
Internet Explorer
Edge
Safari
Please note at this time, we do not recognize automated browser signals regarding
tracking mechanisms, which may include “do not track” instructions.
1.5. AGGREGATED STATISTICS
OPORA.DIGITAL collects statistics about the behavior of visitors to the Site. For
instance, OPORA.DIGITAL monitors the most popular blog posts or pages on the
Site. OPORA.DIGITAL may display this information publicly or provide it to others.
However, OPORA.DIGITAL does not disclose personally identifying information other
than as described below.
2. USE OF YOUR PERSONAL INFORMATION
As mentioned, the Personal Information that OPORA.DIGITAL collects and stores
relating to you is used to communicate to you and to provide our Services to you.
OPORA.DIGITAL takes all measures reasonably necessary to protect against the
unauthorized access, use, alteration or destruction of Personal Information.
We use your Personal Information for business and commercial purposes, including
to use or browse the Site, to offer our Services, to provide you with customer service,
to prevent security and fraud, to provide marketing information about our Services,
and to perform website and mobile application analytics.
We may use the Personal Information we collect about you in a variety of ways,
including to:
2.1. TO PROVIDE OUR SERVICES
We process certain Personal Information when you access or use our Services,
including the following:
2.1.1. Functionality of the Site
We may collect Personal Information from users of the Site to improve website
functionality and provide a test environment for our data collection infrastructure.
This also enables us to customize experiences and personalization when you are on
the Site.
2.1.2. Webinars and Events
We may collect Personal Information to facilitate various webinars and events that
we host on topics such as marketing technology and measurement, media, and
digital content creation.
2.1.3. New Services
We may collect Personal Information to offer new digital performance marketing
services.
2.2. TO COMMUNICATE WITH YOU
We process certain Personal Information in order to communicate with you in
relation to your accounts, our services, our marketing, and your requests. Our text
message program is opt-in and consent to receiving text messages and is not a
condition of purchase of our services. We may process your Personal Information to:
communicate with you about our Services, accounts and programs;
respond to your customer service inquiries and requests for information;
post your comments or statements on the Site;
contact you about our Services by any of the methods that you have consented to at
the time we collected your Personal Information;
communicate with you about our brands, events, or other promotional purposes; and
implement your communications preferences, such as sharing Personal Information
with our business partners so that they may email you about their promotions,
products and initiatives.
2.3. FOR IMPROVEMENT OF THE SITE
We want to ensure that the Site is continually improving and expanding so that we
meet and exceed your needs and expectations. To do so, we may process certain
Personal Information, including to:
maintain, improve, and analyze the Site or Services;
understand how users interact with the Site and Services; and
detect, prevent, or investigate suspicious activity or fraud.
2.4. TO COMPLY WITH APPLICABLE LAWS
We may be required to process certain Personal Information under certain laws and
regulations, such as tax laws, as well as to:
maintain appropriate records for internal administrative purposes; and
comply with applicable legal and regulatory obligations, and respond to lawful
governmental requests, as needed.
2.5. TO ENFORCE OUR TERMS, AGREEMENTS, OR POLICIES
To maintain a safe, secure, and trusted environment for you when you use the Site,
and Services, we may use your Personal Information to ensure our terms, policies,
and agreements with you and any third parties are enforced.
2.6. EVALUATE YOUR APPLICATION FOR EMPLOYMENT
We may use your Personal Information to evaluate your application for employment
or administer employment benefits.
2.7. WITH YOUR CONSENT
We may process certain Personal Information in order to fulfill any other business or
commercial purposes at your direction or with your consent.
2.8. LOG DATA
Log data refers to events that occur on our website, such as button clicks or form
submissions. We may use log data for various internal business purposes which
include:
To monitor abuse and prevent illegal activities and fraud,
To troubleshoot Service functionality and fix bugs;
To track people’s preferences which allows us to create new services, features and
content that may be more personalized for you and your interests;
To track behavior on an aggregated/anonymous level to track and understand trends
related to our offerings and services.
If you are a Site Visitor, OPORA.DIGITAL will only contact you when you have
provided consent and only by those means you provided consent.
3.3 THIRD PARTY ADVERTISING
For more information about how targeted advertising works, you can visit the
Network Advertising Initiative’s (“NAI”) educational page at
https://www.networkadvertising.org/understanding-online-advertising/how-does-it-wo
rk.
3.4 TO COMPLY WITH LEGAL PROCESS OR TO PROTECT OPORA.DIGITAL
Other than to its employees, contractors and affiliated organizations, as described
above, OPORA.DIGITAL discloses potentially personally-identifying and
personally-identifying information in response to a subpoena, court order or other
governmental request, or when OPORA.DIGITAL believes in good faith that
disclosure is reasonably necessary to protect the property or rights of
OPORA.DIGITAL, third parties or the public at large.
3.5 BUSINESS TRANSFERS
If OPORA.DIGITAL, or substantially all of its assets, were acquired, or in the unlikely
event that OPORA.DIGITAL goes out of business or enters bankruptcy, user
information would be one of the assets that is transferred or acquired by a third party.
You acknowledge that such transfers may occur, and that any acquirer of
OPORA.DIGITAL, or the assets of OPORA.DIGITAL, may continue to use your
Personal Information as set forth in this policy.
4. INTERNATIONAL TRANSFER OF DATA
OPORA.DIGITAL may transfer the Personal Information that we collect from you to
locations outside of headquarters for processing and storing. In addition, it may be
processed by staff operating outside the office area who work for us or for one of our
suppliers. For example, such staff may be engaged in the processing and concluding
of your order, the processing of your payment details and the provision of support
services. By submitting your Personal Information, you agree to this transfer, storing
or processing. OPORA.DIGITAL will take all reasonable steps to make sure that your
Personal Information is treated securely and in agreement with this Privacy Notice.
Personal Information that is provided to OPORA.DIGITAL is stored in our cloud.
Details relating to any transactions entered into via the Site will be encrypted to
ensure its safety.
The transmission of information via the internet is not completely secure and
therefore OPORA.DIGITAL cannot guarantee the security of data sent to
OPORA.DIGITAL electronically and the transmission of such data is entirely at your
own risk. Where OPORA.DIGITAL has given you (or where you have chosen) a
password so that you can access certain areas of the Site, you are responsible for
keeping this password confidential.
5. THIRD PARTY LINKS
OPORA.DIGITAL may have links on the Site to other websites that OPORA.DIGITAL
does not operate. If you click on a third-party link, you will be taken directly to that
website, which is governed by its own privacy notice. OPORA.DIGITAL strongly
encourages you to read that privacy notice. OPORA.DIGITAL does not control that
website and assumes no responsibility for the content, policies or its practices.
6. CHOICES AND INDIVIDUAL RIGHTS
OPORA.DIGITAL aims to take reasonable steps for you to correct, amend, delete or
limit the use of your Personal Information. If you are a customer of one of our Clients
that works with OPORA.DIGITAL and would no longer like to be contacted by them,
please send your request to the Client that you interact with directly. If our Client
requests OPORA.DIGITAL to remove or amend your Personal Information, we will
respond to that request within thirty (30) days. OPORA.DIGITAL outlines your
choices below:
6.1. EMAIL
As described above, if you do not wish to receive promotional emails from
OPORA.DIGITAL or for us to share your Personal Information with a joint partner in
co-branded marketing events, you may opt out at any time. If you opt out of a
promotional email, OPORA.DIGITAL may still send you transactional and
administrative emails about this privacy notice or about the Services for which you
have contracted with us.
6.2. COOKIES
Your browsers help function should contain instructions on how to set your computer
to accept all cookies, to notify you when a cookie is issued, or to not receive cookies
at any time.
7. YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION
(“GDPR”)
This section of the Privacy Notice applies solely to Visitors, users, and others who
reside or are located in the European Economic Area (“EEA”). We adopted this
section to comply with European privacy laws, including the GDPR. Any terms
defined in the GDPR have the same meaning when used in this Section. In most
instances, OPORA.DIGITAL is the data processor for processing Personal
Information for our Clients.
We have listed below the rights that you may be able to exercise in respect of the
processing of your Personal Information, subject to applicable law. We take every
reasonable step to ensure that the Personal Information that we process are limited
to the Personal Information that are reasonably required in connection with the
purposes set out in this Privacy Notice.
If you are a resident of or located within the EEA, you have certain data protection
rights. These rights include:
The right to access, update or delete the Personal Information we have on
you. Whenever made possible, you can access, update or request deletion of
your Personal Information by contacting us at the contact information below.
The right of rectification. You have the right to have your Personal Information
rectified if that Personal Information is inaccurate or incomplete.
The right to object to processing. You have the right to object to our
processing of your Personal Information.
The right of restriction. You have the right to request that we restrict the
processing of your Personal Information.
The right of deletion. You have the right to request that we delete or remove
Personal Information when there is no good reason for us to continue
processing it.
The right to data portability. You have the right to be provided with a copy of
the Personal Information we have on you in a structured, machine-readable,
and commonly used format.
The right to withdraw consent. You also have the right to withdraw your
consent at any time where OPORA.DIGITAL relies on your consent to
process your Personal Information.
7.1. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
OPORA.DIGITAL relies on the following lawful grounds to collect and process any
personal data you may have provided:
Legitimate Business Interests: Our use of Personal Information relating to
your use of the Site and/or the Services, described above, is necessary for
our legitimate interests in understanding how the Site and the Services are
being used by you, to improve your experience with them, and to contact you
with information about our Site and Services. We also have a legitimate
interest in aggregating and/or anonymizing the information that we collect
through the Site and/or the Services and using this information for our
business purposes, as described above. When we process your Personal
Information for our legitimate interests, we make sure to consider and balance
any potential impact on you, and your rights under data protection laws. Our
legitimate business interests do not automatically override your interests we
will not use your Personal Information for activities where our interests are
overridden by the impact on you, unless we have your consent or those
activities are otherwise required or permitted by law. You have the right to
object to processing your Personal Information that is based on our legitimate
interests, as further described below.
Performance of Contract: Processing of your Personal Information that you
provide to us when you interact with our Services is necessary to respond to
or implement your request prior to entering into a contract with us. We use
account-related data to provide you with access to the Services, contact you
regarding your use of the Services or to notify you of important changes to the
Services. Such use is also necessary for the performance of the contract
between you and us.
User Consent: If you are a Site Visitor and have supplied your email address
and provided consent, OPORA.DIGITAL may occasionally send you emails to
tell you about industry news and information, solicit your feedback, or keep
you up to date with what’s going on with OPORA.DIGITAL and our services.
We primarily use our email newsletter or email you updates on our blog to
communicate this type of information. If you do not provide us with your
consent to the processing of your Personal Information for this purpose, we
will not send you this information. You have the right to withdraw your consent
at any time as described below.
Employment Application: When you apply for employment through the Site,
processing of Personal Information such as your contact details and data
about your employment history and education (as needed to evaluate your job
application, to conduct job interviews, and as is otherwise needed for
recruitment) is necessary to respond to your request to process your
application for employment. If you do not provide this Personal Information,
we will not be able to process the application that you send through the Site.
7.2. RETENTION OF PERSONAL INFORMATION
OPORA.DIGITAL will retain your Personal Information only for as long as is
necessary for the purposes set out in this Privacy Notice. We will retain and use your
Personal Information to the extent necessary to comply with our legal obligations (for
example, if we are required to retain your Personal Information to comply with
applicable laws), resolve disputes and enforce our legal agreements and policies.
All information you provide to us is stored in our cloud or those of our third-party data
storage providers.
7.3. EXERCISING YOUR RIGHTS UNDER GDPR
If applicable, you may exercise any of your rights under the GDPR by submitting a
verifiable data subject request to us by using the contact details below. You may
make a request related to your Personal Information or on behalf of someone for
which you have authorization. You must include your full name, email address, and
attest to the fact that you are a citizen or resident of the EEA by including your
country of citizenship or residence in your request. We may require you to confirm
your identity and/or legal standing for the request as well as your residency in the
EEA in order to obtain the information. We will respond to your request within 30
days or let you know if we need additional time.
Please note that we will ask you to verify your identity before responding to such
requests, and we may deny your request if we are unable to verify your identity or
authority to make the request.
Should you wish to raise a concern about our use of your data (and without prejudice
to any other rights you may have), you have the right to do so with your local
supervisory authority.
8. YOUR CALIFORNIA PRIVACY RIGHTS
This section of our Privacy Notice applies to consumers who reside in California. We
adopt this section to comply with the California Consumer Privacy Act of 2018
(“CCPA”).
If you are a California resident, you have the following rights. We will honor requests
received to the extent required by applicable law and within the time provided by law.
Right to Notice
8.1. RIGHT TO ACCESS INFORMATION REGARDING PERSONAL INFORMATION
You have the right to request, no more than twice in a 12-month period, that we
disclose to you the categories and specific pieces of Personal Information we have
collected about you. Specifically, you have the right to request that we disclose the
following to you, in each case in the twelve-month period preceding your request:
The categories of Personal Information we have collected about you;
The categories of sources from which the Personal Information is collected;
Our business or commercial purpose for collecting or selling Personal
Information;
The categories of third parties with whom we share Personal Information;
The specific pieces of Personal Information we have collected about you;
The categories of Personal Information about you, if any, that we have
disclosed for monetary or other valuable consideration and the categories of
third parties to which we have disclosed the Personal Information, by category
or categories of Personal Information for each third party to which we
disclosed the Personal Information; and
The categories of Personal Information about you that we disclosed for a
business purpose.
We will deliver Personal Information that we are required by law to disclose to you in
the manner required by law within forty-five (45) days after receipt of a verifiable
request, unless we notify you that we require additional time to respond, in which
case we will respond within such additional period of time required by law. We may
deliver the Personal Information to you through your account, if you maintain an
account with us, or electronically or by mail at your option. If electronically, then we
will deliver the Personal Information in a portable and, to the extent technically
feasible, in a readily usable format that allows you to transmit the information from
one entity to another without hindrance. If we receive a Right to Know request
regarding Personal Information that we process on behalf of our Client, we will also
recommend that the California resident submit a Right to Know request directly with
the client, and will provide contact information for that client where feasible.
Right to Limit Use and Disclosure of Sensitive Personal Data
You have the right to request to limit the use or disclosure of certain sensitive
personal information we collected about You unless an exception applies. To submit,
please see contact privacy@opora.digital.
8.2. RIGHT TO DELETION OF PERSONAL INFORMATION
You have the right to request that we delete Personal Information about you that we
have collected from you. If we are able to verify your identity or the identity of your
authorized agent, we will respond to your request by deleting your Personal
Information and, if applicable, directing any of our service providers to delete your
Personal Information.
We may choose to delete Personal Information by de-identifying, aggregating, or
completely erasing the information. We will specify the manner in which we delete
your Personal Information. If a California resident submits a request to delete
Personal Information to one of our Clients and the client instructs us to delete the
California resident’s Personal Information, we will delete the information as required
by the CCPA. If we receive a Right to Deletion request regarding information that we
process on behalf of our client, we will also recommend that the California resident
submit a Right to Deletion request directly with the Client and will provide contact
information for that Client where feasible.
As permitted by the CCPA/CPRA, if you request deletion of Personal Information that
we have collected about you, we, our service providers, and our contractors may be
unable to comply with such a request if your Personal Information is necessary to:
Complete the transaction for which the Personal Information was collected,
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;
Prevent, detect, and investigate security incidents, protect against malicious
deceptive, fraudulent, or illegal activity; or prosecute those responsible for that
activity;
Debug to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another Consumer to exercise his or
her right of free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act pursuant to
Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal
Code;
Engage in public or peer-reviewed scientific, historical, or statistical research
in the public interest that adheres to all other applicable ethics and privacy
laws, when our deletion of that information is likely to render impossible or
seriously impair the achievement to such research, if you have provided
informed consent;
Enable solely internal uses that are reasonably aligned with your expectations
based on your relationship with us;
Comply with a legal obligation; or
Otherwise use your Personal Information, internally, in a lawful manner that is
compatible with the context in which you provided the information.
8.3. RIGHT TO CORRECT PERSONAL INFORMATION
You have the right to request that we correct any inaccurate information that we
maintain about you.
8.4. RIGHT TO OPT OUT
You have the right to opt out of the disclosure of Personal Information about you for
monetary or other valuable consideration. To Opt-Out, please send email to:
privacy@opora.digital.
8.5. RIGHT TO NON-DISCRIMINATION
We may not discriminate against you because you have exercised any of the
foregoing rights, including by:
Denying you our Services;
Charging different prices or rates for our Services, including through the use
of discounts or other benefits or imposing penalties;
Providing you a different level or quality of our Services; or
Suggesting that you will receive a different price or rate for our Services or at
a different level or quality of our Services.
However, we may charge different prices or rates, or provide a different level or
quality of our Services, if that difference is reasonably related to the value provided
to us by your Personal Information.
8.6. PERSONAL INFORMATION WE COLLECT ABOUT CALIFORNIA
CONSUMERS
We describe the Personal Information we have collected about consumers in the
twelve (12) months preceding the effective date of this Privacy Notice in the part of
our Privacy Notice titled, “Personal Information Collected” above. The Personal
Information we collect includes the following:
Category of Personal
Information Collected
Collected (Yes/No)
Sources of Personal
Information Collected
Commercial Purpose fo
Identifiers such as
name, address, email
address, phone
number, unique id, and
other identifiers listed in
the Personal
Information Collected
section above.
Yes
You, Automatically,
Third Parties
To provide our products
and Services To provide
information you
requested To improve
our products and
Services To identify
potential customers To
market our products and
Services For verifying
identity For fraud
prevention purposes To
process payments To
comply with law To offer
employment, to provide
insurance and benefits,
for background checks
The following
categories of Personal
Information described in
California Civil Code
§1798.80(e): (1) the
Personal Information
listed in the preceding
bullet point as
“identifiers,” and (2) the
other information that
identifies, relates to,
describes, or is capable
of being associated with
a particular individual
that we describe in
“Information We
Collect” above.
Yes
You, Automatically,
Third Parties
To provide our products
and Services To provide
information you
requested To improve
our products and
Services To identify
potential clients To
market our products and
Services For verifying
identity For fraud
prevention purposes To
process payments To
comply with law To
manage payroll and
provide and administer
employee benefits
Characteristics of
protected classifications
under California or
federal law list any of
these that you collect:
Yes
You, Automatically,
Third Parties
To provide our products
and Services to Clients
To improve our products
and Services To offer
employment, to provide
race, color, ancestry,
national origin,
citizenship, religion or
creed, marital status,
medical condition,
physical or mental
disability, sex (including
gender, gender identity,
gender expression,
pregnancy or childbirth
and related medical
conditions), sexual
orientation, veteran or
military status.
insurance and benefits,
for background checks
To comply with law
Commercial
information, including
information about
orders or purchases of
any of our Services;
registration information,
specials, and
information you provide
or submit to us when
you participate in any
event, program,
contest, survey or other
promotion that we may
offer from time to time.
Yes
You, Automatically,
Third Parties
To provide our products
and Services To market
our products and
Services To improve our
products and Services
To provide information
you requested To
comply with law
Biometric data
N/A
N/A
N/A
Internet or other
electronic network
activity information,
including, but not limited
to, browsing history,
search history, and
information regarding
your interaction with the
Site, mobile apps,
advertisements that we
display on the Site or
mobile apps or on third
party websites and
apps, or
OPORA.DIGITAL pages
or accounts on any
third-party social media
platforms.
Yes
You, Automatically,
Third Parties
To provide our products
and services To market
our products and
services To improve our
products and services
(e.g., usage pattern
data) To track employee
actions for internal
reports and information
security purposes
Geolocation data
Yes
Automatically
To market our products
and services For
detecting security
incidents and protecting
our Site
Audio information from
calls placed with
customer service and
accounting centers
which may be reported,
and electronic
information in the form
of Internet or other
electronic network
activity information
described above.
No
N/A
To provide our products
and Services
Professional or
employment-related
information
Yes
Automatically
To provide our products
and Services To offer
employment, to provide
insurance and benefits,
for background checks
Education information
No
N/A
N/A
Inferences drawn from
(1) the information we
collect when you visit
the Site, tools, widgets
and plug-ins, (2)
information we collect,
including through
third-party suppliers,
regarding content and
other data posted on
the Internet (such as
public locations on the
Internet), and (3)
information about
consumers preference
and behavior that we
collect on the Site and
mobile apps or
purchase from third
parties in order to
create a profile about a
consumer reflecting the
consumer’s
preferences,
characteristics,
psychological trends,
predispositions,
behavior, attitudes,
intelligence, abilities
and aptitudes.
Yes
You, Automatically,
Third Parties
To provide our products
and Services To market
our products and
Services To improve our
products and Services
For detecting security
incidents and protecting
our Site
Sensitive Personal
No
You
N/A
Information such as
racial / ethnic origin,
political opinions,
religious / philosophical
beliefs, genetic data,
biometric data, sex life /
sexual orientation, past
or spent criminal
convictions, mail, email
and text message
content, precise
geolocation data, social
security, driver’s
license, state
identification card, or
passport number,
account login, financial
account, debit card, or
credit card number.
We collect this Personal Information from sources that include our Clients and other
sources referenced in the “Personal Information Collected” section above.
8.7. DISCLOSURE OF PERSONAL INFORMATION FOR MONETARY OR OTHER
VALUABLE CONSIDERATION OR FOR BUSINESS PURPOSES
Under the CCPA, sharing of Personal Information that is necessary to provide you
with personalized ads and with some of our partners may be considered a “sale,”
even if no money is exchanged. In that respect, we may disclose email addresses
and contact information to other businesses and third parties that include our joint
marketing partners when we host webinars and events with them within the twelve
(12) months preceding the effective date of this Privacy Notice.
We have disclosed Personal Information in all or substantially all of the categories
identified in this section for various business purposes.
Category
Categories of Third Parties We Share
With
ory of Personal Info
1. Identifiers such as name, address,
email address, phone number.
Advertising partners
Analytics providers Media platforms
Clients (and their service providers)
Social media networks
Consumer data resellers
Distribution partners
Yes
2. The following categories of Personal
Information described in California Civil
Code §1798.80(e): (1) the Personal
Information listed in the preceding bullet
point as “identifiers,” and (2) the other
information that identifies, relates to,
describes, or is capable of being
associated with a particular individual
that we describe in “Information We
Collect” above.
N/A
No
3. Characteristics of protected
classifications under California or
federal law
Advertising partners
Analytics providers
Media platforms Clients (and their
service providers)
Social media networks
Consumer data resellers
Distribution partners
Yes
4. Commercial information, including
information about orders or purchases
of any of our Services; registration
information, specials, and information
you provide or submit to us when you
participate in any event, program,
contest, survey or other promotion that
we may offer from time to time.
N/A
No
5. Internet or other electronic network
activity information, including, but not
limited to, browsing history, search
history, and information regarding your
interaction with the Site, mobile apps,
advertisements that we display on the
Site or mobile apps or on third party
websites and apps, or Response Media
pages or accounts on any third-party
social media platforms.
Advertising partners
Analytics providers
Media platforms Clients (and their
service providers)
Social media networks
Consumer data resellers
Distribution partners
Yes
6. Geolocation data.
Advertising partners
Analytics providers
Media platforms Clients (and their
service providers)
Social media networks
Consumer data resellers
Distribution partners
Yes
7. Audio information from calls placed
with customer service that may be
reported, and electronic information in
the form of Internet or other electronic
network activity information described
above.
N/A
No
8. Professional or employment-related
information
N/A
No
9. Education information
N/A
No
10. Inferences drawn from (1) the
information we collect when you visit
the Site, tools, widgets and plug-ins, (2)
information we collect, including
through third-party suppliers, regarding
content and other data posted on the
Internet (such as public locations on the
Internet), and (3) information about
consumers preference and behavior
that we collect on the Site and mobile
apps or purchase from third parties in
order to create a profile about a
consumer reflecting the consumer’s
preferences, characteristics,
psychological trends, predispositions,
behavior, attitudes, intelligence, abilities
and aptitudes.
Advertising partners
Analytics providers
Media platforms Clients (and their
service providers)
Social media networks
Consumer data resellers
Distribution partners
Yes
11. Sensitive Personal Information such
as racial / ethnic origin, political
opinions, religious / philosophical
beliefs, genetic data, biometric data,
sex life / sexual orientation, past or
spent criminal convictions, mail, email
and text message content, precise
geolocation data, social security,
driver’s license, state identification card,
or passport number, account login,
financial account, debit card, or credit
card number.
N/A
No
For more information about the categories of Personal Information we have
disclosed, the categories of entities with which we have disclosed this Personal
Information and the purposes for which we have disclosed the Personal Information,
please see “Use of Your Personal Information” above and “Where and How We
Share and Disclose Your Personal Information”.
For information regarding the purposes for which we collect and use the Personal
Information we collect, please see “Use of Your Personal Information” and “Where
and How We Share and Disclose Your Personal Information” sections above.
8.8. REQUESTS TO EXERCISE YOUR RIGHTS
Only you or a person that you authorize to act on your behalf may make a verifiable
consumer request related to your Personal Information. You may also make a
verifiable consumer request on behalf of your minor child if you believe we have
received their Personal Information inadvertently. You may request to exercise the
aforementioned rights by:
- Submitting a request to privacy@opora.digital
Please note that we may take steps to verify your identity and residency before
granting you access to Personal Information or acting on your request to exercise
your rights, as required or permitted by law. If you use an authorized agent, we may
require proof of written authorization you have given to make the request. We may
limit our response to your exercise of the above rights as permitted by law. We will
confirm receipt of the request within ten (10) business days describing our
verification process. We will respond to your request within forty-five (45) calendar
days, if we are able to verify your identity. Requests for deletion will require a
separate confirmation that you want your Personal Information deleted.
If a request or series of requests are manifestly unfounded or excessive, we may
charge a reasonable fee for processing the request(s), or may refuse to process the
request(s).
We will maintain records of requests made pursuant to the CCPA for a period of at
least 24 months.
8.9. DATA SHARING FOR DIRECT MARKETING PURPOSES
California Civil Code § 1798.83 further permits California residents to request certain
Information regarding our disclosure of Personal Information to third parties for their
direct marketing purposes. If you are a California resident, you may ask us to refrain
from sharing your Personal Information with certain of our affiliates and other third
parties for their marketing purposes. Please tell us your preference by contacting us
at privacy@opora.digital.
9. YOUR VIRGINIA PRIVACY RIGHTS
If you are a resident of Virginia, you have the right under the Virginia Consumer Data
Protection Act, upon a verified request, to:
To confirm whether or not a controller is processing your personal data and to
access such personal data;
To correct inaccuracies in your personal data;
To delete your personal data;
To obtain a copy of your personal data that you previously provided to us in a
portable, and if technically feasible, readily usable format, if processing is
carried out by automated means;
To opt out of the processing of your personal data for purposes of (i) targeted
advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of
decisions that produce legal or similarly significant effects concerning the
consumer.
To exercise these rights, you may make a request to confirm, access, correct, delete,
obtain a copy, or opt-out of the processing of your Personal Information for targeting
advertising, sale, or profiling by contacting us using the information in the Contact Us
section below:
We may require you to confirm your identity and your residency in order to obtain the
Personal Information, and you are only entitled to make this request up to twice
annually. For emails, please include “Virginia Privacy Rights” as the subject line. You
must include your full name, email address, and attest to the fact that you are a
Virginia resident. We will process your request within forty-five (45) days or let you
know if we need additional time or cannot process your request. If you make this
request by telephone, we may also ask you to provide the request in writing so that
we may verify your identity. If we are unable to honor your request for any reason,
we will notify you of the reason within the request time period.
If we decline to take action on your request, residents of Virginia can appeal our
decision by submitting an email to privacy@opora.digital entitled “Virginia Privacy
Rights Appeal” and we will review your request and respond with a written
explanation of the reasons for our decision. If your appeal is denied, you may contact
the Virginia Attorney General to submit a complaint.
10. SECURITY
OPORA.DIGITAL cares about the security of your Personal Information. Although we
cannot guarantee 100% security, we use reasonably appropriate security measures
to protect your Personal Information against unauthorized use, access, modification,
destruction or disclosure. We require our third-party service providers to use similar
safeguards to those we use.
11. SENSITIVE DATA
OPORA.DIGITAL requests that you do not send us any sensitive data such as social
security or national identification numbers, information related to racial or ethnic
origin, political opinions, religious beliefs, health data, biometrics or genetic, criminal
background or trade union membership information. If you do send OPORA.DIGITAL
this information, then you are consenting to its processing in accordance with this
privacy notice. To avoid processing of sensitive data, do not submit it.
12. OUR POLICY ON CHILDREN’S INFORMATION
The Site is not directed to children under 18. If we learn that we have received
Personal Information from a child who is under 18, we will delete the data. If you
learn that your minor child has provided OPORA.DIGITAL with Personal Information
without your consent, please contact us at privacy@opora.digital.
13. PRIVACY NOTICE CHANGES
Although most changes are likely to be minor, OPORA.DIGITAL may change its
Privacy Notice from time to time, and in OPORA.DIGITAL’s sole discretion. We will
indicate at the top of the page the modified notice’s effective date. We therefore
encourage you to refer to this page on an ongoing basis so that you are aware of our
current privacy notice. If required by the applicable law, we will notify you of the
changes. By continuing to use the Site or providing us with information following
such a replacement Notice being uploaded, you agree that you will be deemed to
have agreed to be bound by the Privacy Notice as changed.
14. ACCESSIBILITY
Any person with a disability that prevents or restricts them from accessing this
Privacy Policy through our website may request a copy of the Privacy Policy in an
alternative format by contacting us at privacy@opora.digital.
15. CONTACT US
OPORA.DIGITAL welcomes any queries, comments or requests you may have
regarding this notice.
Email: privacy@opora.digital