5. USER ACCESS AND CONTROL

If you would like to access personal information we hold about you, or delete or correct, personal information you have previously provided directly to us, you may contact us as outlined in Section 8.  In your request, please include your email address, name, and telephone number and specify clearly what information you would like to suppress.  We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that subject to applicable law, in some cases we may not comply with your request where we may require your information in order to comply with applicable law, or to protect, enforce or defend our rights or employee rights, or those of an Attain Affiliate.

If you are a resident of California, please see the section entitled “California Consumer Privacy Act Notice,” below, for more information about the rights you have under California law.

If you are a California resident, you may request that we not share your personal information on a going-forward basis with Attain Affiliates or unaffiliated third parties for their direct marketing purposes by sending an email as outlined in Section 8 with "Disclosure Opt-out" in the subject line and your full name, email address, postal address and the specific Attain Service you have subscribed to in the body of the email. We will try to comply with your request(s) as soon as reasonably practicable and consistent with applicable law. In the event that we are unable to fulfill your request, we will respond accordingly.

6. CHILDREN'S PRIVACY

We do not knowingly collect or solicit Personal Information about children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Information. If we learn we have collected Personal Information from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Information to us, please contact us at [email protected].

7. OTHER IMPORTANT INFORMATION

Updates to Privacy Policy.  Attain may modify this Privacy Policy.  Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised.  Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Attain Services. 

Location of Data.  The Attain Services are hosted in and managed from the United States.  If you are a user located outside the United States, you understand and consent to having any personal information processed in the United States or in any other country in which we have facilities or in which we engage service providers.  The United States and other countries’ data protection laws may not be the same as those in your jurisdiction.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States may be entitled to access your personal information.

Linked Services.  The Attain Services may be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies.  Attain is not responsible for the privacy practices of unaffiliated companies, and once you leave the Attain Services or click an advertisement, you should check the applicable privacy policy of the other service.   

In addition, Attain is not responsible for the privacy or data security practices of other organizations, any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the Attain Services.

Data Retention.  We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. 

Remember that even after you cancel your registration, or if you ask us to delete your personal information, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services.  Because of the nature of caching technology, your account may not be instantly inaccessible to others.  We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, for fraud detection or to comply with applicable law or our internal security or recordkeeping policies.  It may not always be possible to completely remove or delete all of your information due to technical constraints or contractual, financial or legal requirements.

8. CONTACT US

If you have any questions or comments about this Privacy Policy, please contact us at [email protected].

9. CALIFORNIA CONSUMER PRIVACY ACT NOTICE

If you are a California resident, you have the rights set forth in this section. Except as otherwise specified below, please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Information of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Information as a service provider, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at [email protected].

Categories of Personal Information Collected and/or Disclosed:

The categories of Personal Information that we collected, disclosed, and/or “sold” or “shared” are below, along with the categories of third parties to whom each category of Personal Information was disclosed, and/or “sold” or “shared.”  Please note that we disclose some categories of Personal Information in connection with certain types of advertisements, which could be considered a “sale” or “sharing” under the CCPA.  Also, depending on the California resident’s interactions with us, Attain may not have collected or disclosed each of these categories about each individual.

Category of Personal Information Collected

Examples of Personal Information We Collect

Categories of Third Parties to Whom Personal Information Is Disclosed

Identifiers

  • First and last name
  • Email
  • Phone number
  • Unique identifiers such as passwords or device identifiers
  • IP address
  • Domain server
  • Type of device/operating system/browser used to accept the  Services
  • Connection type
  • Service Providers
  • Advertising Partners
  • Analytics Partners
  • Business Partners
  • Parties You Authorize, Access or Authenticate

Payment Data

  • Payment card type
  • Credit or debit card number
  • Bank account information
  • Billing information
  • Payment processors
  • Service Providers
  • Business Partners

Web Analytics

  • Browsing or search history
  • Web page interactions
  • Referring webpage/source through which you accessed the Attain webpage
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and the Services 
  • Service Providers
  • Advertising Partners
  • Analytics Partners
  • Business Partners

Social Network Data

  • User name
  • Service Providers
  • Advertising Partners
  • Analytics Partners
  • Business Partners

Professional or Employment-Related Data

  • Job title
  • Company where employed
  • Service Providers
  • Advertising Partners
  • Analytics Partners
  • Business Partners

Categories of Data that may be Considered “Sensitive under the California Privacy Rights Act and the Virginia Privacy Rights Act

  • Account log-in, debit or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
  • Service Providers
  • Advertising Partners
  • Analytics Partners
  • Business Partners
  • Parties You Authorize for Access or Authentication

Geolocation Data

  • Non-precise location data
  • IP address
  • Service Providers
  • Advertising Partners
  • Analytics Partners
  • Business Partners

Inferences Drawn from any of the Personal Information Above 

  • Profiles reflecting user attributes, behavior, preferences or abilities/aptitudes
  • Service Providers
  • Advertising Partners
  • Analytics Partners
  • Business Partners