Contacts411® Privacy Policy
This privacy policy (“Privacy Policy”) applies to the website https://contacts411.com as well as the services provided by Infinite Knot, Inc. (herein referred to as Contacts 411®). This Privacy Policy explains how information is collected, used and disclosed by Contacts 411® (“Contacts411®,” “we,” or “us”) with respect to your access and use of our Application and Service, as described in our Terms of Use. Visit our website for details on how information is collected, used and disclosed, at https://contacts411.com (the “Website”).
1. The Data We Collect Through the Application and the Service
Contacts411® is a smart Contacts data update application. In order to provide this Service to you, we require that you submit to us certain of your iOS device, CSV file, or customer database Contacts information, such as your contact names, landline and mobile phone numbers, email addresses and U.S. Postal addresses. Additionally, you will have the option to submit contact information that you collect that is not included in your Contacts app. Collectively this contact information is “Submitted Data”.
We do not retain Submitted Data from your contacts (the “Contacts”), we only access Submitted Data to complete your requested data and data updates and resolve any usage or billing questions. If you provide your own contact information within the Submitted Data, we will treat that as Submitted Data as well.
When you download and use our Application on your mobile device, or access our SaaS platform via the web, we automatically collect information about the type of the device you use and operating system version, as well as your IP address, and any other information that you provide to us.
We do not ask for, nor receive nor store, any credit card information. Contacts 411® Service fees are paid by the user to the Apple iTunes Store or Stripe. Users must have an established account with Apple or Stripe to use the Service, and Contacts 411® is not a party to such accounts. Apple and Stripe, third-party vendors, require disclosure of, and store, credit card information to the benefit of the user and Contacts411®. Any questions or issues arising from transactions paid for with the user’s credit card(s), including privacy matters, must be directed to the Apple iTunes Store or Stripe.
The Service and Application described in the Terms of Use may also collect certain information automatically, including the type of device you use, the IP address of your mobile device, information about your mobile operating system or browser, and information about the way you use the Service and Application. We collect this information to better understand how our users interact with the Service and Application, and how we might improve such interactions.
Likewise, if you request it as a supplemental service (which involves updating the contact data you already have for your contacts) we may access, temporarily store and maintain references to the Submitted Data. We may do so, for instance, as a feature of the Service to notify you when additional data about your contacts becomes available, or to permit you to access your Submitted Data so that you may restore it, at your preference and only with your permission.
If we should determine in the future to store and maintain any of your Submitted Data, we will send you an advance notification to provide you with the opportunity to delete your contacts from the Service.
2. How We Use the Data You Submit To Us
We use your Submitted Data to provide you with the Service described in the Terms of Use, or described and consented to by you through our Application interface or other communications between you and us. If you are a user of our Application or Service and you’ve given us your User Data, we also may contact you regarding the Application or Service – we may, for instance, from time to time ask for your feedback on the Service, send you surveys, or send you information to keep you updated on what’s going on, including new features, offers and updates.
We may additionally request directly from you your own contact information for use in product improvement and marketing activities, including asking for your feedback on the Service, sending you surveys, and sending you information to keep you updated on what’s going on, including new features, offers and updates.
3. How We Obtain the “Returned Data”
We license contact information about people and businesses from reputable data licensing companies. As evidenced by our business model, we believe that users should have appropriate control and transparency regarding how data about them is used, and we seek that our partners and licensors uphold the same high standards.
4. Opt Out of Information Sharing
If you are a consumer, e.g., a member of the general public, who wishes to be removed from our consumer database, please go to our opt-out page here.
If you have subscribed to our Service, we may send you service-related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email or text message. You do not have an option to opt out of these emails, which are not promotional in nature. We likewise may send you promotional emails, in which case you may unsubscribe to receiving promotional emails from us through a link we provide in those emails.
5. Delete Your Contacts
We do not currently store your Submitted Data on our systems, except briefly to process your requests and provide you with Returned Data. However, we may in the future store the Submitted Data (or your Returned Data) on our systems at your request, as necessary to provide you with additional features or functionality. If we do so, we will provide you with a means to delete your Submitted Data from our Service. We will notify you of such means through an email, a posting to our website or through our Service. Please note that in that event, such deletion shall only serve to delete the actual bits and bytes of information that you have submitted to us, from your contact lists: we will retain those contacts’ information to the extent that we independently received and maintain them for other users or licensors. Beyond use of your contact information for the purpose of completing your Contacts 411® transactions, we will retain and use those contacts’ information only as absolutely necessary to comply with our legal obligations, resolve disputes, and enforce our general business agreements while remaining respectful of your contact information.
6. How We May Share and Store Your Submitted Data
We may disclose any information that we collect (regardless how we received it) to employees, contractors and service providers who help us to operate our businesses, communicate with you and/or to provide the Application and Service to you. For instance, we may provide your Submitted Data to entities providing server and hosting support, tech support, billing and collection, security and auditing services, customer support, or data updating. Certain of these entities may in turn use your Submitted Data for internal operational, testing and evaluation purposes related to the service they provide and help us to provide (but not for their own marketing purposes).
We do not rent, lease or sell your contact information or your Submitted Data to anyone.
In addition, we reserve the right to disclose your contact information or your Submitted Data in the following unlikely circumstances:
1. in response to a subpoena, bankruptcy proceedings, court order or other governmental request, in which case we will, as law and exigencies permit, provide you with notice and an opportunity to object.
2. where we believe in good faith that disclosure is reasonably necessary to protect the property, rights or safety of any person.
3. in the event that, as a business, our assets or stock are acquired by another party, in which case any information we hold (including customer and transaction histories) would be one of the assets transferred to and acquired by the third party, and potentially any acquirer of Contacts411® may continue to use your personal information as set forth in this policy (or for other purposes permitted by law).
7. Website Visitors
Our website is at http://contacts411.com (our “website”). Like most website operators, Contacts411® collects web-based log and identifying information that web browsers and servers typically make available, such as the browser type, language preference, referring site, IP address and the date and time of each site visit. We may connect this to other information we collect about you, or you provide to us, such as your account information or other information you have provided to us. We may use any of this information (alone or combined) to operate our business, provide our services, better understand how our visitors use the Contacts411® App, Service and website and market to those visitors, and to prevent fraud or other inappropriate use of our website. From time to time, we may use or share non-personally identifying information in the aggregate (e.g., to analyze or share information about the usage of our website or the Service).
8. Additional Information About Cookies, Tags and Similar Technologies
We and our advertising and analytics service providers use technologies such as cookies, tags, and scripts to: analyze trends, administer the website, track users’ movements around the website, and gather demographic information about our user base as a whole. We may receive reports based upon the use of such technologies by these companies on an individual and aggregated basis.
A cookie is a string of information that a website stores on a visitor’s computer and that browser provides to the website each time the visitor returns. We may use cookies on the Website to help us identify and track visitors, their usage of our website, and their website access preferences, and to send you retargeted ads when you visit other websites. Website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our website. However, if you do so, certain features of the website may not function properly without the aid of cookies.
We use mobile analytics software to allow us to better understand the functionality of our Application on your phone and certain uses of our website. This software records marketing and product information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded.
9. Security of the Data We Maintain
Maintaining the data we possess or retain for you in a secure manner is of paramount importance to us. We therefore generally employ, in various forms and combinations, firewalls, physical and technological protections and barriers to access, and encryption and/or hashing techniques to protect data. However, none of these techniques – nor any other – is foolproof in safeguarding data, and we cannot guarantee that any data submitted to us cannot or will not be accessed in an unauthorized manner despite our best efforts to do so.
10. Security of the Data We Maintain
Maintaining the data we possess or retain for you in a secure manner is of paramount importance to us. We therefore generally employ, in various forms and combinations, firewalls, physical and technological protections and barriers to access, and encryption and/or hashing techniques to protect data. However, none of these techniques – nor any other – is foolproof in safeguarding data, and we cannot guarantee that any data submitted to us cannot or will not be accessed in an unauthorized manner despite our best efforts to do so.
11. Data Inquiries
If you have any concerns or questions about the information we hold or that you believe we have provided about you, please contact us through the contact information we provide in Section 15.
12. Links to 3rd Party Sites
Our website (or app) may include links to other sites whose privacy practices may differ from those of Contacts411®. If you choose to submit personal information to any such websites, your information will be governed by their published privacy policies. We encourage you to carefully read the privacy policy of any such websites that you choose to visit.
13. Social Media Features and Widgets
Our website may incorporate Social Media features (“Features and Widgets”), such as a Facebook Like button, a Twitter button or interactive mini programs. Features and Widgets, if incorporated, may collect your IP address, the page or pages you visit on our website, and a cookie to enable the Feature to function properly. Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features and Widgets are governed by the privacy policy of the companies providing them.
14. Privacy Policy Changes
We may change this Privacy Policy from time to time and in our sole discretion. If we make any material changes we will notify you by email, text message, or by means of a notice on our website prior to the change becoming effective. We encourage visitors to periodically check this Policy as contained in our application, or our website page that presents this Policy, for any changes to its Privacy Policy. Your continued use of this site, the Service and the Application after any change in this Privacy Policy will constitute your acceptance of such change.
15. Compliance with the California Consumer Privacy Act (“CCPA”)
Please see our below “Addendum” for information about how we comply with the CCPA, and what rights you have under the CCPA if you are a California resident.
16. Questions
If you have any questions about this Privacy Policy, you may contact us at support@contacts411.com or through our mailing address listed below.
Infinite Knot, Inc.
PO Box 390
Greens Farms, CT 06838-0390
Addendum For california residents
NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY PROTECTION ACT
The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services. This Addendum supplements the information in the Privacy Policy. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.
In the below tables and sections, we describe (as required by the CCPA):
1. Our collection of personal information
The types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from.
2. Our disclosure and sale of personal information
The types of recipients to whom we disclose or sell Personal Information.
3. Our business purposes
Our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same
4. Your california privacy rights and choices
What rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.
The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:
1. our collection of personal information
Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.
Category
Collection Method
Identifiers, e.g., name; alias; postal address; IP address; telephone number; email address.
From consumer data public record resellers and other publicly available business data sources (“Commercial Data Sources”).
Operating systems.
Internet or other electronic network activity information E.g., browsing history; information on a consumer’s interaction with a website.
Operating Systems (e.g., visits to our own website).
2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION
We will share the information collected about you as discussed above for various business purposes, with service providers and our customers. The chart below details how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.
Category
Categories of Third Parties We Share With
Whether We “Sold” This Category of Personal Information in the Last 12 Months
Identifiers, e.g., name; postal address; telephone number; email address.
Users of the Contacts411® App (Referred to together as “Customer Categories”).
Yes
We also may share any of the personal information we collect as follows:
Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
Sharing With Service Providers: We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.
Aggregate and Deidentified Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION
Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.
Contact data updating for personal and business app users interested in reaching someone via phone, email or postal mail.
Other internal purposes, for example:
For internal research, internal operations, auditing, detecting security incidents, debugging short-term and transient use, quality control, and legal compliance. We use the information collected from an app users’ registration process, and their activity with the app. We also may receive information from prospective business customers (such as through trade shows and events), which we use for our corporate and business outreach purposes.
4. YOUR CALIFORNIA RIGHTS AND CHOICES
Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)
A. Right to request access to your personal information
California residents have the right to request that we disclose what categories of your personal information that we collect, use, or sell. You may also request the specific pieces of personal information that we have collected from you. However, we may withhold some personal information where the risk to you or our business is too great to disclose the information.If you would like to see the personal information on you provided by Contacts411, you may do so as outlined here Consumer Access and Right to Know Request
B. Right to request deletion of your personal information
You may also request that we delete any personal information that we collected from you, such as if you have been a customer of ours. (Note that this is different from your right to “opt out” of us selling your personal information, which is described below; also note that we do not generally collect personal information directly from consumers.) However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
C. How to exercise your access, opt-out and (if applicable) deletion rights
California residents may exercise their California privacy rights by sending an email to optoutrequest@contacts411.com submitting your request on our Opt Out Page, or your access or deletion request to our Consumer Access portal here, or by contacting us at (844) 763-3411. For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. For instance, if you request categories or specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be. Once we have verified your identity, we will respond to your request as appropriate:
- Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.
- Where you have requested specific pieces of personal information, we will provide the information you have requested, except to the extent that we could not comply with your request.
D. Right to nondiscrimination.
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
E. Right to Opt-out of the sale of your personal information.
California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.” Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section 2 of this Addendum, titled “OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION”.
If you would like to opt out, you may do so as outlined on the Opt Out Page.
F. Information About Persons Under 16 Years of Age
We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).
G. Authorized Agents
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.