ProACtive Privacy Policy

Last updated [2-29-2024]

Summary

This policy explains the rights of Connecticut residents regarding the collection, use, sale, and sharing of their personal information under the Connecticut Data Protection Act (CTDPA), effective July 1, 2023. We may update and make changes to this policy, so we encourage you to review it periodically.

• Personal Data We Collect About You. We collect information to provide goods and/or services to you, to help improve your customer experience, and to support our business functions. We [may] collect the following categories of consumer personal data:

• • Identifiers: Information that identifies, relates to, describes, or is capable of being associated with, a particular individual such as [name, signature, social security number, address, telephone number, driver’s license, passport number, and state identification card number]. 
  • Financial Information: [Account numbers, credit or debit card numbers].
  • Commercial information: [Purchase and transaction history].
  • Biometric information: [Fingerprints, voice prints, facial geometry, and retina scans].
  • Internet or other electronic network activity information: [Mobile device and online identifiers, Mac address, IP address, cookie IDs, browser activity, search history, social media information, and information regarding your interaction with our website or mobile application.]

• Precise geolocation data.

• Demographic Information. [Age, gender, race, citizenship, ethnicity, date of birth, family or marital status, household income, education, professional and employment information].
• Profile information. [Any form of automated process performed on personal data to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual’s economic situation, health, personal preferences, interests, reliability, behavior, location or movements.]
• Sensitive Data. [Data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation or citizenship or immigration status; the processing of genetic or biometric data for the purpose of uniquely identifying an individual; personal data collected from a known child; or precise geolocation data.] We will not process your sensitive data without obtaining your consent.

• Why We Use Your Personal Information. We use your consumer personal information for the following business purposes:

• [Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services];
• [Advertising or marketing];
• [Helping to ensure security and integrity and prevent fraud]; 
• [Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them];
• [Auditing or monitoring of transactions and engagements];
• [Compliance with our legal and regulatory obligations];
• [Performing our contract with you or taking steps at your request before entering into a contract];
• [Conducting research and analysis];
• [To conduct other activities for legitimate business purposes]

• Your Rights Under the CTDPA and How to Exercise Them. Residents of Connecticut have certain personal data rights under the Connecticut Data Protection Act (CTDPA) which may be exercised free of charge once per year, provided that in cases where the requests are manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or decline to comply with the request.

You have the right to:

• Confirm whether or not we are processing your personal data and access such data.
• Correct inaccuracies in your personal data.
• Delete personal data provided by or obtained about you.
• Obtain a copy of your personal data processed by us in a portable format.
• Opt-out of the processing of your personal data for targeted advertising.
• Opt-out of the sale of your personal data.
• Opt-out of profiling performed in furtherance of solely automated decisions that produce legal or similarly significant effects.
• Designate another person to serve as your authorized agent to act on your behalf and opt out of processing for targeted advertising, the sale of your data, and profiling as listed above.
• Non-discrimination or retaliation for exercising any of these rights.
• To designate an agent to exercise your rights on your behalf.

We are required to respond without undue delay but within 45 days of receipt of your request. Depending on factors such as the type and complexity of the request, we may extend the time for response once for 45 additional days, as long as we notify you within the original 45 days.

If we decline to take action regarding your request, we must notify you without undue delay, but within 45 days of the receipt of the notice and provide information on our appeal process. We are required to provide justification and provide information on the appeal process within a reasonable time after the communication of the decision to decline.

If you would like to exercise any of your rights as described in this Privacy Policy, you can do so here: https://proactivehomemakers.com/about. You may also call us at [toll-free phone number], or [email/write to] us at [contact information]. If you wish to designate an agent to exercise your rights on your behalf or are a guardian or conservator exercising consumer rights on behalf of another you can do so here: https://proactivehomemakers.com/about. You may also call us at [toll-free phone number], or [email/write to] us at [contact information].  If your request to exercise your rights is declined, you may appeal by contacting us at [method of contact] and following the process found here.

• Please note that you may only make a CTDPA-related data access or data portability disclosure request once within a 12-month period.
• If you choose to contact us directly by [website/email/phone/in writing], you will need to provide us with:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number) 
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

• We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.
• Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

• Categories of Personal Information We Have Shared with Third Parties. We have shared the following categories of personal information with third parties:

• • Identifiers: Information that identifies, relates to, describes, or is capable of being associated with, a particular individual such as [name, signature, social security number, address, telephone number, driver’s license, and state identification card number] 
  • Financial Information: [Account numbers, credit or debit card numbers].
  • Commercial information: [Purchase and transaction history].
  • Biometric information.
  • Internet or other electronic network activity information: [Mobile device and online identifiers, Mac address, IP address, cookie IDs, browser activity, search history, social media information, and information regarding a consumer’s interaction with an internet website, application, or advertisement.]

• Precise geolocation data.

• Demographic Information. [Age, gender, race, citizenship, ethnicity, date of birth, family or marital status, household income, education, professional and employment information]
• Profile information. [Any form of automated process performed on personal data to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual’s economic situation, health, personal preferences, interests, reliability, behavior, location or movements.]
• Sensitive Data. [Data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation or citizenship or immigration status; the processing of genetic or biometric data for the purpose of uniquely identifying an individual; personal data collected from a known child; or precise geolocation data.]

• Who We Share Your Personal Information With. We may share your personal information with:

• Our affiliates, including companies within the [company’s name] group;
• Service providers we use to help deliver our [products and/or services] to you, such as payment service providers, warehouses and delivery companies;
• Other third parties we use to help us run our business, such as marketing agencies or website hosts;
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• Credit reporting agencies;
• Our insurers and brokers;
• Our bank[s];
• External auditors;
• [Other].
• We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.
• We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
• We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
• [We do not share your personal information with any third party.]

Contacting Us.

If you need to contact us, you can reach us by email at info@proactivehomemakers.com