Privacy Policy

INTRODUCTION

We at Backstop Solutions Group, LLC and our affiliates (“Backstop”, “we”, “us”) care deeply about privacy, security, and online safety.  This Privacy Policy (“Privacy Policy”) is designed to inform you about how we collect, use, and disclose your Personal Information (as defined below), and our commitment to using the Personal Information we collect in a transparent and respectful manner.

This Privacy Policy applies to “Personal Information” we obtain from individuals (“you”) through our websites (collectively, our “Site”), products, and services (collectively, the “Services”), and from third party and publicly available sources, as further described below.  Please read this Privacy Policy carefully before you start to use our Services, whether online or offline.  When referenced in this Privacy Policy, the term “Personal Information” (i.e., Personal Data or other similar terms as defined by applicable law) includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including any information that is subject to applicable data protection laws. 

Backstop is the controller (i.e., responsible party) for the Personal Information practices described in this Privacy Policy.  However, we also provide and administer the Services on behalf of customers and act as a processor or service provider relative to such customers.  This Privacy Policy may not apply in that regard and we recommend that you review the privacy policy of such third-party customers with whom you are dealing directly as they will be responsible for the handling of your Personal Information.

California Consumer Notice of Collection

This Notice of Collection is provided to all California consumers subject to this Privacy Policy. 

You can access specific topics within this Privacy Policy by clicking on the relevant links below:

Introduction
Categories of Personal Information We May Collect
Sources of Personal Information
Use and Processing of Your Personal Information
Use of Your Sensitive Personal Information
Disclosures of Your Personal Information
Legal Basis for Collecting and Using Your Personal Information 
Security Measures 
Data Retention
Children’s Privacy
Data Transfers
Cookies and Other Tracking Technologies
Links to Other Websites
Your Rights 
Opt-out Preference Signal (Do Not Track) 
Changes to This Privacy Policy
Contact Us

CATEGORIES OF PERSONAL INFORMATION WE MAY COLLECT

The types of Personal Information we collect about you depends on how you interact with us. Depending on the Services you use, the following are the categories and specific types of Personal Information that we may collect, or have collected in the preceding 12 months:

• Contact Information/Identifiers, including name, email address, postal address, phone number, username, business contact information, or other similar identifiers and account information.
• Government Identifiers, including driver’s license number (in certain instances may be considered sensitive personal information).
• Information Specific to the Services, in certain instances, such as invoices, business and commercial communications, order status and history.
• Demographic Information, including age and gender, some of which may include characteristics of protected classifications under state or federal law.
• Device Information and Other Unique Identifiers, device identifier, internet protocol (IP) address, or similar unique identifiers.
  Internet or Other Network Activity, including browsing or search history, and information regarding your interactions with our websites, mobile applications, emails, or advertisements.
• Geolocation Data, including information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.
• Payment Information, including credit or debit card number, or other financial information.
• Inferences, inferences drawn from or created based on any of the information identified in this section.
• Sensitive Personal Information (where permitted and in accordance with applicable law), of the information listed above, social security number, racial or ethnic origin, username and password and/or health information are also sensitive personal information.

The provision of the Sensitive Personal Information listed above is voluntary.  In certain instances, we will not be able to process your request for our Services without the requested Personal Information.  

If you do not provide us with certain Personal Information, we may not be able to fulfill the requested purpose of collection, such as to respond to your queries or request for customer service or to provide the full functionality of our Site or Services to you.  However, unless otherwise specified, not providing your Personal Information will not result in legal or other consequences to you.

SOURCES OF PERSONAL INFORMATION

We collect your personal information in the following ways, pursuant to applicable law:

• Directly From You, such as when you use our services, create an account and profile with us; sign up with us to receive marketing communications; or otherwise reach out to us.
• Other Sources, including vendors, affiliates, and through tracking technologies. To learn more about our use of cookies and similar tracking technologies, please review the “Cookies and Other Tracking Technologies” section below.  

USE AND PROCESSING OF YOUR PERSONAL INFORMATION

We use your Personal Information and Sensitive Personal Information for the following business purposes (“Processing Purposes”) associated with our general business operations.  We may collect your Personal Information for the following Processing Purposes:

• To provide you the Services.
• To enable you to access and use our websites. 
• To communicate with you and to respond to your requests, questions, comments, and other inquiries.
• To understand what partner resources you use, if any, and to connect you to additional resources at your request.
• To offer you personalized advertisements, which you may be able to opt out of as explained in the “Your Rights” section. 
• To send marketing and promotional materials, including information relating to our products, Services, sales, or promotions or those of a third party.
• To administer, maintain, evaluate, and improve our websites and Services, and to develop new products and services.
• To conduct research and analytics related to our websites and Services.
• We may use Personal Information for marketing and promotional purposes to show you advertisements for products and/or services tailored to your interests on social media and other websites.
• To manage our business operations, perform our obligations and exercise our rights under any agreement that you or your organization has with us.
• For other purposes with your consent, or as otherwise permitted or required by applicable law.
• We use Personal Information to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
• We use Personal Information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of Backstop and our users, customers, employees, or others.

USE OF YOUR SENSITIVE PERSONAL INFORMATION

With regard to sensitive Personal Information you provide, if any, we only use your sensitive personal information to provide you with the requested products or services and to administer your account or application.  

DISCLOSURE OF YOUR PERSONAL INFORMATION

We respect the importance of privacy.  Other than as provided in this Privacy Policy, we do not sell your Personal Information, nor do we share it with unaffiliated third parties for their own marketing use, unless we have your consent, or we are required by law to do so.  Generally, we may disclose the Personal Information we collect to facilitate our communications with customers, to operate our business, to advertise or promote our Services, or with your consent.  To the extent that we have collected or processed your Personal Information in the prior twelve (12) months, we may have disclosed the above-listed Personal Information as described below.

We may disclose each category of Personal Information listed above to third parties in the following ways:

• Service Providers. We may disclose Personal Information to authorized third parties who perform services for us (including cloud services, data storage, sales, human resources, and marketing).  Our contracts with our service providers include commitments that they agree to limit their use of Personal Information and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy.  Remember that if you provide Personal Information directly to a third party, such as through a link on the Site, that processing is typically based on their standards.
• Affiliated Companies. We may disclose such Personal Information with subsidiaries, affiliates or strategic partners as needed to provide our products and services and generally as necessary in the administration of a global organization. 
• Corporate Transaction. We may disclose your Personal Information in connection with a proposed or actual corporate merger, acquisition, consolidation, sale of assets, bankruptcy, insolvency or other corporate change.  Such recipient will be bound by terms and conditions reasonably similar to those set out in this Privacy Policy.
• Other Parties. We may disclose your Personal Information to legal, governmental, or judicial authorities, as instructed or required by those authorities or applicable laws, or in relation to a legal activity, such as in response to a subpoena or an investigation of suspected illicit activity.  We may also disclose such Personal Information if we believe disclosure is necessary to prevent physical, financial, or other harm, injury, or loss.
• Deidentified Personal Information. We may disclose or use aggregated or de-identified data for any lawful purpose.  Deidentified information is generally not considered to be Personal Information under applicable laws.
• Other Disclosures With Your Consent. We may disclose your Personal Information with your consent to other unaffiliated third parties who are not described elsewhere in this Privacy Policy. 
• Social Media Platforms and Networks: Some of our websites have features such as, plugins, widgets, or and other tools made available by third parties that may result in information being collected or shared between us and the third party. The third party’s use of your information is not governed by this Privacy Policy. You may have the right to opt out of our use of these technologies, as further described in this Privacy Policy. 

LEGAL BASIS FOR COLLECTING AND USING YOUR PERSONAL INFORMATION

Backstop relies on the following legal grounds for the collection, processing, and use of your Personal Information:

• As necessary to provide a service or perform a transaction (such as when we respond to your requests);
• Consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies);
• As necessary for legitimate interests (such as when we act to maintain our global business generally, including maintaining the safety and security of the Site); and
• Compliance with legal obligations, particularly in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws.

SECURITY MEASURES

We use various reasonable safeguards (administrative, organizational, technical, and physical) to protect the Personal Information we collect and process.  Our security controls are designed to maintain an appropriate level of confidentiality, integrity, and availability of your Personal Information.  Nonetheless, no such measure is 100% effective; therefore, we do not guarantee that your Personal Information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such Personal Information.  In the event of an incident that we are required by law to inform you of, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.  We encourage you to use caution when using the Internet.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us as specified in the “Contact Us” section below.

DATA RETENTION

The time periods for which we retain your Personal Information depend on the purposes for which we use it and applicable law for the type of data and use.  Backstop will keep your Personal Information for as long as you are a registered subscriber or user of our Services or for as long as we have a valid business purpose to do so and, thereafter, for no longer than is required or permitted by law. The Personal Information we collect may be stored and processed in servers in the United States and/or other jurisdictions where Backstop, or our service providers, have facilities.

CHILDREN’S PRIVACY

Backstop does not knowingly collect Personal Information from children under the age of 13 (or other relevant age of majority) without first obtaining parental consent in accordance with applicable laws.  Users under the age of 13 should not submit any Personal Information to us.  If you believe we have collected Personal Information from your child in error or have questions or concerns about our practices relating to children, please notify us using the details in the “Contact Us” section below.  We will take prompt steps to remove the Personal Information from our systems. 

DATA TRANSFERS

Backstop is headquartered in the United States and we have operations, entities, and service providers both in the United States and throughout the world.  As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.  We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.  If you are located in the European Economic Area, Switzerland or the UK, we provide adequate protection for the transfer of Personal Information to countries outside of these areas, such as through the use of authorized EU Standard Contractual Clauses, the UK Standard Contractual Clauses, or the UK Addendum to the EU Standard Contractual Clauses.  Depending on your location, you may have the right to request a copy of such appropriate safeguards by contacting us as set out at the end of this Privacy Policy. 

Backstop is a participant in the EU/US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries transferred to the United States pursuant to the Privacy Shield.  Backstop has certified that it adheres to the Privacy Shield Principles (the “Principles”) and continues to do so, regardless of the European Commission invalidating the Privacy Shield on July 16, 2020.  To the extent that there is any conflict between this Privacy Policy and the Principles, the Principals shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.  Backstop is subject to the investigatory and enforcement powers of the Federal Trade Commission.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Every time you come to the website, our website’s web server automatically collects information, including, in some instances, Personal Information, through cookies, web beacons, and other similar tracking technologies (collectively “cookies”).  Cookies are small text files that are placed on your computer or mobile device when you visit a website.  Cookies help the website remember information about your visit, which can make it easier to visit the website again and make the website more useful to you.  Some cookies are deleted once you close your browser (session cookies), while other cookies are retained even after you close your browser so that you can be recognized when you return to a website (persistent cookies).  More information about cookies and how they work is available at www.allaboutcookies.org.  Generally, your email address and all other Personal Information is collected only when you voluntarily provide that data.

Cookies on our website are generally divided into the following categories:

We may use the information collected through cookies and related tracking technologies for the following purposes:

• To make our website easier to use and generally improve its performance.
• To gather metrics about how you interact with our website.
• For security reasons.
• To provide personalized content. For example, we may store user preferences, your default language, device and browser information, and your profile information, which includes the level of your usage of the website so we can identify you across devices and personalize the content you see.
• To advertise to you via behavioral-based/targeted advertising and allow others to do the same. 

Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent this.  If you disable cookies, your ability to use some features of the website may be limited.  For mobile devices, you may be able to manage certain cookies using your built-in mobile device settings and controls.  Any choices concerning cookies are browser and/or device specific. If you clear your cookies from your browser on any of your devices, your choices will need to be reset. You should check how to do this on your device(s) and operating systems. 

Some cookie providers may also offer opportunities to control your preferences.  To learn how to opt-out of Google Analytics, an Analytics cookie, please visit https://tools.google.com/dlpage/gaoptout. 

Some of these cookies may be placed by third party service providers to help determine the effectiveness of our advertising campaigns or email communications.  The use of cookies by third-party service providers is within their control and not ours.  We do not control their websites or their policies and practices regarding your Personal Information, and you should be aware that different rules might apply to the collection, use or disclosure of your Personal Information by third parties in connection with their advertisements or promotions and other sites you encounter on the Internet.  This Privacy Policy does not cover any use of Personal Information that a third-party service provider may directly collect from you, and we do not undertake to confirm, investigate, or police their practices.

LINKS TO OTHER WEBSITES

Our Site may contain links to other websites for your convenience and information.  These websites may be operated by companies not affiliated with Backstop.  Linked websites may have their own privacy policies or notices, which we recommend you review if you visit those websites.  This Privacy Policy only applies to Personal Information collected on this Site.  We have no control over third-party websites and are not responsible or liable for the content, privacy practices, or use of any websites that are not affiliated with Backstop.

YOUR RIGHTS

You may have certain rights regarding your Personal Information.  The rights available to you depend on our reason for processing your Personal Information and the requirements of applicable law (i.e., your rights will vary depending on whether you are located in, for example, California, the European Union, or United Kingdom). Specifically, you may have the following rights: 

• Right to access: You may have the right to obtain from us confirmation as to whether Personal Information concerning you is being processed, and, where that is the case, to request access to the Personal Information.  This access to information includes the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed, among other categories of information.  However, this is not an absolute right and the interests of other individuals may restrict your right of access.  You may have the right to obtain a copy of the Personal Information free of charge.  For further copies requested by you, we may charge a reasonable fee based on administrative costs.
• Right to rectification (right to correct inaccurate information): You may have the right to request that we correct any Personal Information about you that is inaccurate.  Depending on the purpose of the processing, you also have the right to request that we complete the Personal Information we hold about you where you believe it is incomplete, including by means of providing a supplementary statement.
• Right to erasure (right to be forgotten): You may have the right to request that we erase your Personal Information, under certain conditions. 
• Right to restrict processing: You may have the right to request that we restrict the processing of your Personal Information, under certain conditions.  In such case, the respective data will be marked and may only be processed by us for certain purposes.
• Right to object to processing: You may have the right to object to our processing of your Personal Information, under certain conditions, and we can be required to no longer process your Personal Information.  Such right to object may especially apply if we collect and process your Personal Information through automated decision making, such as profiling, to better understand your interests in our products and services or for direct marketing.  If you have a right to object and you exercise this right, your Personal Information will no longer be processed by us for such purposes.  Such a right to object may, in particular, not exist if the processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded. 
• Right to data portability: You may have the right to request that we transfer the Personal Information we have collected about you to another organization, or directly to you, in a structured, commonly used, and machine-readable format, under certain conditions. 
• Right to withdraw consent: Where we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. 
• Right to know what Personal Information is sold or shared and to whom, and right to prohibit the sale or sharing of Personal Information: We do not and have not in the preceding 12 months, sold or shared (in this context, share means use of your Personal Information for cross-contextual behavioral advertising) your Personal Information. However, the use of technologies, such as cookies may constitute “sale” or “share” of Personal Information under California law. To opt out of the “sale” or “share” of your Personal Information as described in this section, visit Do Not Sell or Share My Personal Information (Opt-Out).
• The following categories of Personal Information disclosed are considered “sale”/ “sharing” under California law: direct identifiers, device information, and geolocation data. 
• The following categories of third parties to whom personal information was disclosed are considered “sale”/”sharing” under California law: social media platforms and networks. 
• Right to limit the use and disclosure of sensitive Personal Information: We will only use sensitive or special Personal Information as needed for the purposes for which it was collected.   If this changes, we will notify you, and you may have the right to restrict such additional uses
• Right of non-discrimination/retaliation: We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy, nor do we retaliate against individuals who exercise these rights.   

Please note that many of the above rights are subject to exceptions and limitations.  Your rights and our responses will vary based on the circumstances of the request.  If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law.

If you are located in the State of California in the United States, a person authorized to act on your behalf may make a verifiable request related to your personal information.  If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf. 

In any circumstances, your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

To exercise your rights, please contact us as stated in the “Contact Us” section of this Privacy Policy.

If you are a current or former California Backstop employee, please reference our Backstop Employee Policy.  If you are a California applicant, please reference our Backstop Applicant Policy. 

OPT-OUT PREFERENCE SIGNAL (DO NOT TRACK)

Backstop generally recognizes commercially recognized opt-out preference signals (e.g., Global Privacy Controls). Recognition of this signal applies only to the specific device and/or browser that communicates the signal and does not cross over to all devices/browsers you use to access the Site or Services.

CHANGES TO THIS PRIVACY POLICY

As Backstop grows and our business changes, we may modify, expand, or update this Privacy Policy at any time as we deem appropriate to reflect those changes.  When we make changes to this Privacy Policy, we will post the updated Privacy Policy on the Site and update the Privacy Policy’s “last updated” date above. It is important that you check back from time to time and make sure that you have reviewed the most current version of this Privacy Policy.  If you do not agree with the changes, then you should stop using our Site and Services and notify us that you do not want your Personal Information used in accordance with the changes. 

CONTACT US

If you have questions or comments regarding this Privacy Policy or our privacy practices, please contact us by using the information below.  You may also have a right to lodge a complaint with a data protection supervisory authority.  You may also exercise your rights as noted above by following this link and completing the web form.

United States

Backstop Solutions Group, LLC
Attn: Privacy Team
233 S. Wacker Drive, Suite 3960
Chicago, Illinois 60606
Email: [email protected]
Phone: 1(312) 277-7702 or 1(888) 720-0299

Backstop Solutions UK, Ltd
20 St. Dunstans Hill
London
EC3R 8HL United Kingdom

This Privacy Policy includes an “effective” and “last updated” date.  The effective date refers to the date that the current version took effect.  The last updated date refers to the date that the current version was last substantively modified.

Effective Date: December 31, 2022
Last Updated Date: December 31, 2022

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.