LAST UPDATED: March 5, 2024

Thank you for choosing to be part of our community at AspireVue. Prepare to Change, Inc., owners of the AspireVue platform, are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at info@aspirevue.com.

When you visit our website https://www.aspirevue.com, the platform at https://my.aspirevue.com, or the mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this Privacy Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Sites or Apps and our services.

This Privacy Policy applies to all information collected through our website, mobile application, (“Apps“), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Services“). See our Terms of Service for details about what we are responsible for as well as user obligations that must be adhered to for continuation of the service.

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when using or registering at the Services or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or Apps (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:

• Publicly Available Personal Information. We collect first name, maiden name, last name, and nickname; phone numbers; email addresses; business email; business phone number; social media; and other similar data.
• Payment Data. We collect data necessary to process your payment if you make purchases, (such as a credit card number), and the security code associated with your payment instrument.
• Social Media Login Data. We may provide you with the option to register using social media account details, like your Facebook, X, Google, or other social media account. If you choose to register in this way, we will collect the Information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS” below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information Automatically Collected:

We automatically collect certain information when you visit, use or navigate the Services or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Services or Apps, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

Online Identifiers. We collect device’s geolocation; and other similar data.

Information collected through our Apps:

In Short: We may collect information regarding your geo-location, mobile device, and/or push notifications when you use our Services or Apps. Specifically, we may also collect the following information:

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s calendar, contacts, social media accounts, microphone, camera, reminders, storage, SMS messages, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
• Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
• Facial Images are uploaded to the app.
• Contact List. Your Contact List, including any facial images within the Contact List, will be uploaded when you download the app and updated as you updated your Contact Lists.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services or Apps for a variety of business purposes described below. We process your personal information for these purposes and those described in this Privacy Policy in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We will not use your information for other purposes without notice to you and, where required, you’re your consent except as required or permitted by applicable laws. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
• To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your notification preferences. You can opt out of our marketing emails at any time.
• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services or Apps.
• To post testimonials. We post testimonials on our Services or Apps that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us and be sure to include your name, testimonial location, and contact information.
• Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
• Request Feedback. We may use your information to request feedback and to contact you about your use of our Services or Apps.
• To protect our Services. We may use your information as part of our efforts to keep our Services or Apps safe and secure (for example, for fraud monitoring and prevention).
• To enable user-to-user communications. We may use your information in order to enable user-to-user communication with each user’s consent.
• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
• To deliver services to the user. We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose. For example, we share personal information of job applicants that use the AspireVue assessments. Such information will be handled and processed in accordance with the terms of a separate policy (“Informed Consent”).
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services or Apps. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
• Other Users. When you share personal information or otherwise interact with public areas of the Services or Apps, such personal information may be viewed by all users and may be publicly distributed outside the Services or Apps in perpetuity. If you interact with other users of our Services or Apps and register through a social network (such as Facebook, Slack, or LinkedIn), your contacts on the social network may see your name, profile photo, and descriptions of your activity. Similarly, other users may be able to view descriptions of your activity, communicate with you within our Services or Apps, and view your profile.
• Advertisement Offers. Our Apps may display a third-party hosted advertisement to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the third-party advertiser in order to prevent fraud and properly credit your account.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

5. DO WE USE MAPS?

In Short: Yes, we use third-party Map technologies for the purpose of providing better service.

By using our Maps API Implementation, you agree to be bound by the Terms of Service of the pertinent third-party technologies. You agree to allow us to obtain or cache your location. You may revoke your consent at any time. We use information about location in conjunction with data from other data providers.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services or Apps offer you the ability to register and login using your third-party social media account details (such as Facebook, Slack, or LinkedIn). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Services or Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.

The Services or Apps may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Services or Apps. You should review the policies of such third parties and contact them directly to respond to your questions.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as you maintain your account and as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us to keep your personal information for longer than 2 years past the termination of the user’s account. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal or other information protected by applicable laws that we process. However, please also remember that no platform is free from cybersecurity risks and we cannot guarantee that the internet itself is 100% secure, nor can we guarantee error-free performance Although we will do our best to protect your personal or otherwise legally protected information transmission of such personal information to and from our Services or Apps is at your own risk. You should only access the services within a secure environment. If you do not wish your personally identifiable information to be at any risk then you should not use the Service or apps or upload personally identifiable or otherwise protected information to the website or apps.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We comply with the Children’s Online Privacy Protection Act (COPPA), which specifically requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13 years of age and, specifically, we do not knowingly solicit data from or market to children under 18 years of age. By using the Services or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services or Apps.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account.

12. DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when we believe you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that we become aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information, we will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to your rights and freedoms.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

14. DO CALIFORNIA RESIDENTS AND RESIDENTS OF STATES WITH SIMILAR LAWS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, or a US state with similar laws that provide rights to website visitors and users of the services, including apps you may have specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us.

California Residents and Residents of States with Similar Privacy Laws or Regulations Disclosures to Third Parties:

Residents of California have the right to request a disclosure describing what types of Personal Information we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year. You may request a copy of that disclosure by contacting us at info@AspireVue.com. Residents of other states with privacy laws that have similar provisions may be entitled to request such disclosures as well. You are advised to review the privacy laws of your state of residence.

Do Not Sell or Share My Personal Information

AspireVue does not sell Personal Information, but the California Privacy Protection Act (CCPA), and laws of states with similar provisions, define sale more broadly than the traditional sense of an exchange of data for money and may encompass transactions in which we may disclose your Personal Information. The California Privacy Rights Act (CPRA) defines “Share” as the disclosure of Personal Information for use in cross-context behavioral advertising. Accordingly, you may, subject to exceptions in CCPA and CPRA, request that Company not “sell” or “share” your Personal Information by submitting this request to us at info@AspireVue.com. Residents of other states with privacy laws that have similar provisions may be entitled to request such disclosures as well. You are advised to review the privacy laws of your state of residence.

To exercise these rights, you may contact us at info@AspireVue.com or 949-275-8804. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent, please contact us via email or at 949-275-8804.

CCPA provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

Non-Discrimination

CCPA comprises provisions that explicitly prohibit us from making any adverse decisions about you or your account based upon your exercise of this right (“non-discrimination”).

Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA: Identifiers, including name, facial images, alias, postal address, email address, phone number, account name, IP address, and other similar identifiers, demographic information, Sensitive Information including your age and gender and those categories of Personal Information set forth in the Information We Collect sections of this Policy.

Right to Know and Delete

If you are a California resident or resident of a state with similar privacy law provisions, you have the right to delete the personal information we have collected from you in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific aspects of personal information we have collected about you.

To exercise any of these rights, please contact us at info@AspireVue.com, In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request in a timely manner. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Right to Opt Out

You have the right to opt out of receipt of communications from us. You may submit a request to opt-out please by contacting us at info@AspireVue.com. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Minors

We do not knowingly “sell” the personal information of minors under 16 years old who are California residents without appropriate authorization.

15. Canadian Residents

Personal Information of residents of Canada may be processed and stored in the United States and/or other jurisdictions in which federal and provincial laws comprising protections for Personal Information or Personal Data do not apply.

16. European Users

If you are located in the European Economic Area, the United Kingdom or Switzerland, you may have the right to:

• Request access to and receive information about the Personal Information we maintain about you for our own purposes, to ask us to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate subject to exceptions in applicable laws, or to obtain an electronic copy of the Personal Information we have collected pertaining to you and to exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

These rights may be limited in some circumstances by local law requirements or derogations (exceptions). You may exercise your rights by contacting info@AspireVue.com.

International Visitors and Customers

The Services are hosted in the United States. If you are visiting from the European Union (EU) or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data to the United States which does not have the same data protection laws as the EU and by providing your personal data or using the Service you consent to:

• The use of your personal data for the purposes identified above in accordance with this Privacy Policy and the transfer of your personal data to the United States as indicated above.

17. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

18. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at info@AspireVue.com.