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Privacy Policy

Last Updated 07/11/2022

Contact Salucro Support through live chat, available 24 hours a day. You can also contact Salucro Support via email at support@salucro.com or by phone at (866) 430-7333 (option 2).

This Privacy Policy describes the way we collect, store, use, and protect your personal information.


By accessing or using www.salucro.com (the “Site”) in any way, you agree to the terms of this Privacy Policy, which terms are incorporated into the Terms of Use, available here (the “Terms”). This Privacy Policy describes how Salucro protects your information as well as how Salucro collects, stores, uses, and discloses the information for the purposes of operating the Site. This Privacy Policy applies solely to the information that we collect through the Site. This Privacy Policy does not address personal information that you provide to us in other contexts (e.g., through a business relationship not handled through the Site). Please refer to the Terms for any definitions of terms used but not otherwise defined.

We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it, unless otherwise indicated. If the modified Privacy Policy is not acceptable to you, your only recourse is to stop using the Site.

The Site may contain links to third-party websites and services that are not owned or controlled by Salucro. We are not responsible for the privacy practices or the content of third-party websites, services and advertisements, and you visit them at your own risk.


1. Introduction

We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Data that is shared with us as part of using the Site. As used in this Privacy Policy, "Personal Data" means any information that may be used, either alone or in combination with other information maintained by Salucro, to personally identify an individual. Examples of Personal Data include your name, address, phone number, and/or email address.

If you are a resident of California, or are in the United Kingdom or European Union, you may have additional rights, which are described below.


2. Information Collected

How We Collect Information

We may receive or collect Personal Data in the following ways:

2.1. Personal Data You Provide To Us. If you initiate contact with us in any way, register for an event, or sign up to receive updates, you may be required to provide us with certain information that may constitute Personal Data.

2.2. Information Collected Automatically. Certain information on the Site is collected automatically by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of the Site. Alone or in combination with other information, such automatically collected information may constitute Personal Data.

The information inside the log files includes internet protocol (“IP”) addresses, type of browser, Internet Service Provider (“ISP”), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may also use web beacons alone or in conjunction with cookies to compile information about your usage of the Site and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to the Site. We may use web beacons to operate and improve the Site and email communications.

Salucro and certain third parties that are used in connection with the Site may use cookies and other technologies to collect information about users. You are free to decline cookies if your browser permits but doing so may interfere with or prevent your use of the Site. See our Cookies Notice for additional information about our management of cookies.

Salucro does not currently respond to web browser "Do Not Track" signals or other mechanisms that provide a method to opt out of the collection of Personal Data because there currently isn't an industry or legal standard for recognizing or honoring them at this time. If we do so in the future, we will describe how we do so in this Privacy Policy.

Categories of Information Collected

We may collect the following categories of Personal Data:

  • Identifiers such as your name, alias, email address, mailing address, IP address, and online identifiers;
  • Certain categories of “Personal Information” (as described in subdivision (e) of California Civil Code Section 1798.80);
  • Geolocation data such as the precise GPS coordinates of a mobile device;
  • Internet or other electronic network activity information, including information on your usage of our Site;
  • Information used to create a profile about a consumer reflecting the consumer’s preferences or behavior;
  • Electronic, audio, visual, thermal, olfactory, or similar information;
  • Commercial information, including records of products or services purchased or other purchasing histories; and
  • Professional or employment-related information.

3. The Purposes For Which We Use Personal Data

If you submit or we collect Personal Data through the Site, then such Personal Data may be used in the following ways: (i) to provide, analyze, administer, and improve the Site and services; (ii) to contact you in connection with the Site and certain services, notifications, events, programs or offerings that you may have registered for; (iii) to send you updates and promotional materials that you have registered for; (iv) to identify and authenticate your access to the parts of the Site (e.g., client portals and extranet) and services that you are authorized to access; (vi) for customer service and support; (v) to provide notifications to customers or users of other Salucro web properties; and (vii) to protect our rights and/or our property and to ensure the technical functionality and security of the Site.


4. How We Disclose Personal Data

We do not sell, lease, rent or otherwise disclose the Personal Data collected from the Site to third parties unless otherwise stated below or with your consent.

4.1. Our Third-Party Providers. We transfer or provide access to Personal Data to our third-party service providers to perform tasks on our behalf and to assist us in providing the Site. For example, we employ service providers who analyze website traffic and demographics; enable sharing of content; and conduct marketing services. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Data. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Data transfers.

4.2. In the Event of Merger, Sale, or Change of Control. We may transfer or assign this Privacy Policy and any Personal Data to a third-party entity that acquires or is merged with as part of a merger, acquisition, consolidation, restructuring, the sale of substantially all of our ownership interests and/or assets, in connection with bankruptcy proceedings, reorganization, or other change of control.

4.3. Other Disclosures. We may disclose Personal Data about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our terms of use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Salucro, our users, or the public.


5. Retention of Personal Data

We reserve the right to retain any Personal Data as long as the Personal Data is needed to: (i) fulfill the purposes that are described in in this Privacy Policy (including, The Purposes For Which We Use Personal Data), and (ii) comply with applicable law and compliance obligations. We will take all reasonable steps to destroy, or erase from our systems, all Personal Data which is no longer required for the purposes for which the Personal Data was collected.


6. Data Security

The security of Personal Data is important to us. We take appropriate technical and organizational data security measures against unlawful or unauthorized processing of Personal Data, and against the accidental loss of, or damage to, Personal data. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Further, while we attempt to ensure the integrity and security of Personal Data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to Personal Data. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.


7. Children’s Privacy

We do not intend to collect Personal Data from anyone we know to be a child under the age of 18. If you are under the age of 18, please do not use the Site.


8. Contacting Us

Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to Salucro using one of the contact methods provided below:

Salucro - 3333 E. Camelback Road, Suite 250, Phoenix, AZ 85018

Contact Support - Email: compliance@salucro.com - Phone: (866) 430-7333 (option 2)


California Resident Disclosure

To the extent we are operating as a business for purposes of the California Consumer Privacy Act of 2018 (“CCPA”), this California Resident Disclosure is available for certain California residents who access or use the Site or the Services (“California Residents”) and provides information to California Residents of their rights under the CCPA. “Personal Information” in this Disclosure is limited to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Consumer or household or as otherwise defined under California law. For purposes of CCPA, Personal Information does not include any Health Information that is subject to protections under HIPAA.

1. Categories of Personal Information Collected, Used, and Disclosed In accordance with California law, we collected the information described in Section 2 above. We share each of these categories of Personal Information with our service providers to the extent necessary for them to facilitate our business purposes (including any purpose specified above in Section 5). We have not sold Personal Information in the twelve (12) months preceding the effective date of this Privacy Policy.

2. Rights for California Residents California Residents may have certain rights under the CCPA, including: (A) the right to request (for matters over the previous 12 months) the specific pieces of Personal Information regulated by the CCPA we collected; the sources of that Personal Information, the purposes of collecting the Personal Information, and any types of third parties that we may have shared the Personal Information with; (B) the right to request (in certain circumstances) deletion of your Personal Information that we collected; the right to have someone you authorize make a request on your behalf; and the right not to be discriminated against for exercising any of these rights. Please note that the CCPA sets for certain limitations on these rights and procedures available to Salucro to respond to and navigate these requests.

3. How to Exercise Your California Consumer Rights If a California Resident would like to exercise these rights, the California Resident should contact Salucro at compliance@salucro.com or (866) 430-7333 (option 2). Please be prepared to tell us which right you wish to exercise and to provide information sufficient to verify your identity. We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will be used solely for the purpose of verification.

You should contact Salucro for any concerns or questions you may have. Nevertheless, California Residents may file a complaint with the California Attorney General’s office at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or telephone: (916) 210-6276.


General Data Protection Regulation Disclosure

We have created this disclosure (“UK/GDPR Disclosure”) in relation to the General Data Protection Regulation (GDPR) and the UK General Data Protection Regulation (UK GDPR), collectively “UK/GDPR,” to explain how, in our capacity as a data controller under UK/GDPR, we process Personal Data about you as a data subject. As used in this UK/GDPR Disclosure, “Personal Data” means any information relating to a natural or identifiable nature person (“data subject”), and “process” or “processing” means any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1. Salucro's Basis for Processing The following sets out four lawful methods under the UK/GDPR pursuant to which we may process your Personal Data:

Basis
Description

Your Consent

Where you have given us consent to process your Personal Data for one or more specified purposes, such as to provide our Service and other services as requested by you.

To Perform a Contract

Where the processing is necessary for the performance of contract to which you are a party.

Comply with the Law

Where the processing is necessary for compliance with a legal obligation to which we are subject.

Legitimate Interests

Where the processing is necessary for the purposes of the legitimate interests pursued by Salucro or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.

2. Data Subject Privacy Rights. In certain circumstances, local data protection laws and certain local laws (including the UK/GDPR) may give you rights with respect to Personal Data if you are located in the United Kingdom or the European Economic Area. These rights differ by country/region, but may include the following:

Privacy Right
Description

Access to Your Personal Data

You may have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. You may also have the right to obtain a copy of the Personal Data undergoing processing.

Rectification

You may have the right to obtain from us the rectification of inaccurate Personal Data concerning you.

Erasure

You may have the right to obtain from us the erasure of Personal Data concerning you and we may be obliged to erase such Personal Data.

Restriction of Processing

You may have the right to obtain from us restriction of processing your Personal Data. In such cases, the respective data will be marked and may only be processed by us for certain purposes.

Data Portability

You may have the right to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and you may have the right to transmit those data to another entity without hindrance from us.

Object

You may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by us. If you have a right to object and you exercise this right, your Personal Data will no longer be processed for such purposes by us.

3. How to Exercise Your Rights. You may exercise these rights at any time by sending an email to compliance@salucro.com or write to us at: Salucro Attn: Compliance, 3333 E. Camelback Road, Suite 250, Phoenix, AZ 85018

Depending on where you live, you may have the right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Data about you. We encourage you to first reach out to us at compliance@salucro.com, so we have an opportunity to address your concerns directly before you do so. However, you are not required to contact us before you contact a supervisory authority or other regulatory agency.

4. UK / EU Representative Salucro’s representative in the United Kingdom and European Union is: Kim Walker, Shakespeare Martineau, 60 Gracechurch Street, London, EC3V 0HR, DX700, London City

5. Personal Data Transferred from the EU to the United States By using the Sites and our Services, please be aware that any Personal Data may be stored and processed in the United States or other countries outside of the United Kingdom and European Economic Area.