Privacy Policy

(Effective November, 2023)

Who We Are

We provide temp CFO consulting services to privately held businesses at a fraction of the cost; delivering business owner solutions toward unlimited growth, decreased costs, and removing all barriers from maximizing profitability. Services are available throughout the United States.

 

Scope of Policy

This Privacy Policy explains how Pro CFO Consulting (ProCFO). and its subsidiaries, (“we,” “our,” “us”) collect, use, and share Your information, including through Our digital properties on which this Privacy Policy is linked (“Site”).  This Privacy Policy applies generally to the information We collect about You as a consumer, employee or contractor, prospective employee, member of the Network, prospective member of the Network, or about another person for whom You have the legal authority to represent, such as Your family member, friend, or client. (“You,” “Your,” “Yourself”).

This policy is limited to data of the United States. 

This Privacy Policy generally does not apply to data collected, controlled, or processed by independently owned and operated businesses, third-parties acting on behalf of ProCFO, except to the extent Your specific data has been collected by Us.  Inquiries regarding any marketing communications, employment or application records, or client records, must be directed to the corporate office.

If your data is collected, used, or shared in connection with your employment or contracting with ProCFO your data is also subject to the terms of all applicable employment policies, handbooks, rules, and agreements, which will control in the event of any conflict.

If your data is collected, used, or shared in connection with your status as a member of the ProCFO Network, your data is also subject to the terms of the applicable agreement(s) and written requirements, which will control in the event of any conflict.

 

Notice of Collection of Personal Information

We may collect the following categories of personal information:

  1. Identifiers
  2. Customer personal information under California. Civ. Code § 1798.80(e)
  3. Voluntarily provided information on personal characteristics of protected classes,
  4. Commercial information & financial information,
  5. Professional or employment-related information,
  6. Sensitive personal information,
  7. Website/Application interaction or similar network activity,
  8. Biometric Information
  9. Sensory data
  10. Health & Physical Characteristics, and
  11. Inferences drawn from the above.

We collect this information so that we may:

  1. Communicate with you
  2. For administration of our business
  3. Anonymize Your data for further internal and external use in a manner that does not identify You
  4. Enhance security and preventing fraud or illegal activity
  5. Perform our contractual duties and obligations or enter into an agreement
  6. Ensure compliance with legal obligations
  7. Facilitate of online or platform interactions, (excluding use of web tracking technologies for targeted advertising)
  8. Care coordination & customer service,
  9. Provide educational resources/ learning management
  10. Identify and test business innovations
  11. Perform market research and analytics
  12. Advertise/market for employment, recruitment, products and Services

We may share identifiers, customer personal information under California. Civ. Code § 1798.80(e), commercial information, and Website/Application interaction or similar network activity for purposes of targeted advertising.  We do not sell or share client information.

A more detailed description with examples is provided below in the Data We Collect, Data We Use and Data Sharing sections.

We will retain and use Your Personal Information for as long as necessary to satisfy the purpose(s) for which it was collected and to comply with our legal obligations, resolve disputes, and enforce our agreements.  Once data is aggregated, de-identified, or anonymized, it may be retained for a longer period as permitted by law.

 

Communications Consent

By utilizing our Services or providing information about You, You acknowledge and consent to the terms of this Privacy Policy. You agree not to provide us with information about any other person unless You have that person’s consent or other legal authority.

Your telephone communications with Us may be recorded or monitored for quality control purposes. By communicating with Us in this manner, You expressly consent to the recording for such purposes.

By providing Us with Your contact information, such as email or telephone number, You agree to be contacted by Us and by the providers we have contracted with to contact You on our behalf. You agree to be contacted by telephone call email address or text message at the telephone number You provided using automatic telephone dialing systems, even if You previously registered on a Do Not Call registry. Your consent is not a condition of purchase.

 

Communication Opt-Out or Unsubscribe

You may choose to have Your name taken off of our registration list, cease marketing communications or newsletters from us by using the opt-out option in any marketing emails or text messages You receive from us or contacting us using the information provided at the bottom of this Privacy Policy. We will respond to Your request within 10 days or as otherwise required by law.

Opting out of one form of communication does not mean You have opted out of other forms as well. For example, if You opt-out of receiving marketing emails, You may still receive marketing text messages if You have opted-in to receiving them.  However, if You submit a general opt-out request on this Site, we will take action to unsubscribe You based upon the information provided.  For example, if You provide Your name, email address, and phone number we will unsubscribe You from any lists linked to either Your name, email address or phone number. 

 

Managing Web Tracking Technologies

 

Consent

When You first visit our site, a banner will appear and request consent to our use of online technologies that are not necessary for the function of our site.  Our site only uses such optional online technologies when You consent.

If you accept the use of tracking technology, then a third party advertiser, search provider or ad network partner may collect information about Your activity on our website, on devices associated with You, and on third-party sites and applications to decide which ads You see both on our websites and applications and on third-party sites and applications. 

You may opt-in or opt-out of the placement of optional technology going forwards, at any time, via our Cookie Preferences using this link:

Cookie Preferences

 

Browser Settings

We generally use local storage (“LS”) also referred to as HTML5 to store web content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon Your web browsing activity use local storage to collect and store information. Service providers that collect tracking data on our behalf may provide an opportunity for You to choose not to be tracked online.  Various browsers may also offer their own management tools for removing HTML5 LS.

You may be able to adjust Your settings to limit ad tracking (e.g. “Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android). 

You may also be able to control receipt of targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers by visiting the Digital Advertising Alliance.

If You are seeing one of our advertisements on a third-party site, such as a social media site, You may also have the option to opt-out of such behavioral advertising through that site’s preference settings. Even if You opt out of personalized advertising, You may still see ads based on factors such as Your general location derived from Your IP address, Your browser type, and Your search terms.

Do Not Track

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting the user’s activity that such activity will not be tracked. If You are using a “do not track” function on Your web browser, our cookie manager software will recognize this as an opt-out preference signal, such that we will not collect or share Personal Information we associate with your browser or device for purposes of targeted advertising.

You may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”).

You can also opt out of Google Analytics by installing Google’s opt-out browser add-on.  We will process the GPC signal and Google’s opt-out browser add-on as a request to opt out.  When we receive a do not track signal, your opt-out of web tracking technologies will be automatic.

 

Data We Collect

There are four main ways we collect personal information:

  1. Data You Provide: Data You provide to Us;
  2. Automated Data:Data collected through electronic/automated means;
  3. Network Data: Data we are authorized to access and receive as from our affiliates, or as the ProCFO Consulting Network; and
  4. Other Data Sources: Data from other sources (such as our service providers.

We may combine data You provide to us with automated data and from other data sources. For example, we may receive automated data about those accessing our Site and combine that with data You provide or Network data to assess and improve the quality of our Site and services by and on behalf of the ProCFO Consulting Network. 

Data You Provide

We collect data You provide to Us when You use the Site or Our services, including communicating with Us over the telephone, email, SMS or completing a website form.  This includes personal information, which identifies (whether directly or indirectly) a particular individual. 

Personal information You provide includes the types of data listed below (with examples).

  1. Identifiers: name, postal address, phone number, or email address.
  2. Customer Personal information under California. Civ. Code § 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
  3. Personal characteristics of protected classes.  Age, gender and other information voluntarily provided, such as marital status, medical diagnosis, physical or mental disability.
  4. Commercial information. Records of Services obtained or considered, client payor sources, benefits, budgets or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
  5. Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments, invoices, and expenses relative to the Network or employees.
  6. Website/Application interaction or similar network activity–information You provide Us in our website contact forms, applications, or through any chat functionality.
  7. Professional or employment-related information.  We may receive employment-related information from applicants and employees, including: current and past employer name, positions held, physical demands of positions held, and wage information (where permitted); availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military (where applicable to the administration of benefits); and performance record.
  8. Sensitive Information.  Information that reveals a social security, driver’s license, state identification card, or passport number; an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and the contents of a consumer’s mail, email, and text messages; and information collected and analyzed concerning a consumer’s health.
  9. Website/Application interaction or similar network activity–information You provide Us in our website contact forms, applications or through any chat functionality.
  10. Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and health data that can be used to identify an individual.
  11. Sensory data. Audio or similar information, such as recording phone calls for quality assurance.
  12. Health & Physical Characteristics.  Medical conditions, diagnosis, care needs, and other similar information You provide.

Automated Data

As is true of most websites, we gather certain information about Your Site and web usage, patterns and location. We, our affiliates, and third-party vendors/service providers use technologies such as cookies, flash cookies, pixels, tags, scripts, software development kits, application program interfaces, and web beacons. 

These technologies may be used for many purposes including, for example, to:

  • Provide useful features to simplify Your experience when You return to or navigate our Site (for example, remembering the contact information You entered so You don’t need to re-enter it)
  • Deliver relevant content and advertising based on Your preferences, usage patterns and location;
  • Monitor, evaluate, and optimize the use and operation of our sites and applications; and
  • Analyze traffic on our sites and on the sites of third parties.

We may receive reports from our third-party vendors/service providers based on the use of these technologies that contain personal information, aggregate information, or anonymous information. 

Personal information we may automatically collect includes the types of data listed below (with examples).

  1. Identifiers: online identifier, Internet Protocol (IP) address, or unique device identifiers.
  2. Site interaction or similar network activity–interaction with the Site or advertisements including logs and session data, and browser, network, device and operating system information. We may also track the site You visited prior to our Site or what site You visit when You leave us.
  3. Sensitive Personal Information-Geolocation data–Physical location, such as country or state from which You access the Site.  This may include precise geolocation data.

Each franchise business is responsible for its data collection, use and disclosure; however, collection via the Site is subject to the terms and limitations of this privacy policy.

Network Data

We may require access to data of the Willows at Home Network for purposes such as maintaining brand standards and performing services on behalf of the Network.  Personal information we may access from the Network includes the types of data listed below (with examples).

  1. Identifiers. name, postal address, phone number, or email address.
  2. Customer Personal information under California. Civ. Code § 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
  3. Personal characteristics of protected classes.  Age, gender and other information voluntarily provided, such as marital status, medical diagnosis, physical or mental disability.
  4. Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information

  5. Professional or employment-related information. We may have access to employment-related information of the Network, including: current and past employer name, positions held, physical demands of positions held, and wage information (where permitted); availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military (where applicable to the administration of benefits); and performance record.
  6. Sensitive Personal Information.  Information that reveals a social security, driver’s license, state identification card, or passport number; an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, the contents of a consumer’s mail, email, and text messages, and information collected and analyzed concerning a consumer’s health.
  7. Health & Physical Characteristics.  Medical conditions, diagnosis, care needs, and other similar information You provide.
  8. Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments and invoices.

Other Data Sources

We may also collect Personal Information from other sources (such as our service providers, including lead generation services, or public sources).  Personal information we collect from other sources includes the types of data listed below (with examples).

  1. Identifiers. name, postal address, phone number, or email address.
  2. Customer Personal information under California. Civ. Code § 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
  3. Personal characteristics of protected classes.  Age, gender and other information You choose to provide, such as marital status, medical condition, physical or mental disability.
  4. Commercial information. Records of products or services purchased, obtained, or considered, or government payment sources and benefits.

  5. Professional or employment-related information.  We may have access to employment-related information of Our employees or applicants, including: current and past employer name, positions held, physical demands of positions held, and wage information (where permitted); availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military (where applicable to the administration of benefits); and performance record.  
  6. Sensitive Personal Information.  Information that reveals a social security, driver’s license, state identification card, or passport number; an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and the contents of a consumer’s mail, email, and text messages; and information collected and analyzed concerning a consumer’s health.
  7. Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and health data that can be used to identify an individual.
  8. Site interaction or similar network activity.  Information You provide for Us in any third-party contact form or chat functionality.
  9. Sensory data. Audio or similar information, such as recording phone calls for quality assurance.
  10. Health & Physical Characteristics.  Medical conditions, diagnosis, care needs, and other similar information.
  11. Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments and invoices.

Data Use

For each type of data we collect, we use such Personal Information for the business purposes set forth below:

  1. Communicating with You–For example, we may use client personal information to respond to an online or phone inquiry. 
  2. Verify and enhance quality of products and Services–For example, we may use data about caller inquiries, perform surveys or gather feedback to continuously improve the experience of those seeking Network services or employment.
  3. Administration of our business–For example, we may use your personal information for customary business functions like obtaining legal and tax advice, obtaining payment, audits, or for HR functions like applicant reviews, provision of offer letters, onboarding, payroll, reports, complaints, compensation reviews, and performance management.
  4. Anonymizing Your data for further internal and external use in a manner that does not identify You–For example, we may aggregate and de-identify data for analysis of survey results and related insights.
  5. Enhancing security and preventing fraud or illegal activity–For example, we may use personal information to verify your identity when you submit a data request. 
  6. Performing our contractual duties and obligations or entering into an agreement–For example, we may use personal information to enter into and administer a franchise agreement.  
  7. Ensuring compliance with legal obligations–For example, employment laws may require us to collect and maintain employee payroll records or other documentation.
  8. Facilitation of online interactions–For example, we may use web tracking technologies to improve your user experience on our websites.
  9. Franchise Client Lead Management, Engagement & Customer Service–For example, we may collect inquiries on behalf of the Network via our website.    
  10. Providing educational resources/ learning management–For example, we may document employee orientations and training for the purposes of confirming compliance with our requirements, payroll or compliance with regulatory requirements.                                   
  11. Identifying and testing business innovations–For example, we may receive data from franchisees that pilot business innovations.
  12. Market research and analytics–For example, we may use Personal Information about employees to determine where we should focus future recruitment and advertising efforts. 
  13. Advertising/marketing for brand promotion, employment, recruitment, products and services–For example, if you accept cookies on our website, we may use Personal Information to determine the effectiveness of our advertising.
  14. Qualification of prospective franchise owners or master franchise principals
  15. Network event planning and coordination–For example, we may host training events for the franchise Network and require information in order to coordinate and communicate about the event.                       

Public Sharing

You may post public testimonials, comments, feedback, or reviews on our Site, through a third-party site or one of our service providers. When You post, or authorize posting, such information publicly You understand that such information is no longer subject to this Privacy Policy and consent to Us posting Your testimonial along with Your name.

 

Data Sharing

We may disclose Personal Information to third-parties for business purposes as follows:

  1. Network & Affiliates. 

We may share the following categories of Personal Information with our Network and affiliates: identifiers, customer personal information under California. Civ. Code § 1798.80(e), commercial information, financial information, professional or employment-related information, Website/Application interaction or similar network activity, and Health & Physical Characteristics.

We may disclose such Personal Information for the purposes of: communicating with You, to verify and enhance quality of products and Services, administration of our business, anonymizing Your data for further internal and external use in a manner that does not identify You, enhancing security and preventing fraud or illegal activity, performing our contractual duties and obligations or entering into an agreement, ensuring compliance with legal obligations, facilitation of online interactions, franchise client lead management, engagement & customer service, providing educational resources/ learning management, identifying and testing business innovations, franchisor brand management, standards, and network support, and administration of our social purpose mission.

We may also share sensitive personal information concerning a consumer’s health, to the extent reasonably necessary for our Network or Affiliates to coordinate care, provide services, and verify and enhance the quality of Network services.

  1. Third-Party Service Providers

We may share all categories Personal Information collected with service providers, who have entered into an agreement to only process data on our behalf and not sell or share the data.

We may disclose such Personal Information for the purposes of: communicating with You, to verify and enhance quality of products and Services, administration of our business, anonymizing Your data for further internal and external use in a manner that does not identify You, enhancing security and preventing fraud or illegal activity, performing our contractual duties and obligations or entering into an agreement, ensuring compliance with legal obligations, facilitation of online or platform interactions, franchise client lead management, engagement & customer service, providing educational resources/ learning management, identifying and testing business innovations, market research and analytics, qualification of prospective franchise owners or master franchise principals, network event planning and coordination, franchisor brand management, standards, and network support, and administration of our social purpose mission.

  1. Legal and Administrative Authorities, Officials and Courts

We may disclose all categories of Personal Information where we believe it is necessary to comply with the law in special cases when we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may have breached our Terms of Use or who may be causing (whether intentionally or unintentionally) injury to or interference with our rights or property, other website users, or anyone else who could be harmed by such activities. We may also disclose Personal Information to law-enforcement personnel and agencies when requested to do so, as required by law, such as to comply with a subpoena.  We may also disclose Personal Information to public health authorities as required by law.

Such disclosures may include sensitive personal information to the extent reasonably necessary and proportionate to accomplish the legally permitted purpose of disclosure.

  1. Business Transfers.

We may disclose any category of Personal Information as part of any merger, acquisition, debt financing, sale of company assets, or other business transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, provided that we inform such third parties that they must use Your Personal Information only for the purposes disclosed in this Privacy Policy.  Disclosures will only include Personal Information to the extent reasonably necessary and proportionate to accomplish the legally permitted purpose of disclosure.

We may disclose or share Personal Information to third-parties for commercial purposes as follows:

  1. Third-party Vendors

We may share the following categories of Personal Information with third-party vendors who do not process data solely on our behalf or utilize the data for targeted advertising:  identifiers, customer personal information under California. Civ. Code § 1798.80(e), commercial information, and Website/Application interaction or similar network activity.

We may disclose Personal Information to such vendors for the purposes of: communicating with You and advertising/marketing for brand promotion, employment, recruitment, products and services.

You have the ability to opt-out of such sharing, as outlined in the Consumer Consent and Choices section.

Disclosure to such third-party vendors may be considered a “sale” or “sharing” of personal information under state law.  We do not provide Your data to third parties in exchange for financial gain. However, California law defines the “sale” or “sharing” of information as including any disclosure for use in targeted marketing.

We may otherwise disclose Your Personal Information to third-parties with Your consent or at Your direction, where permitted or required by law.

We do not use or disclose sensitive personal information of California residents for purposes other than those specified in regulation as not requiring the ability of consumers to limit use.

 

Links to Other Websites and Social Media

Our Site may offer links to websites that are not run by us but by third parties. If You visit one of these linked websites, Any information You give to those organizations is subject to their privacy policy, terms and conditions, and other policies. We are not responsible for the policies and practices of third parties. You understand and agree that by clicking on a link to a third party site You have left the Site, and this Privacy Policy is no longer in effect.

We may maintain profiles or accounts with various third-party social media providers, which may include Facebook, Twitter, Instagram, LinkedIn, TikTok and YouTube.  While our collection, use, and disclosure of information obtained through the Social Media Properties and/or the Features is governed by this Privacy Policy to the same extent as information gathered through the Site, the information third-party social media providers collect or access through Your use of the Social Media Properties is governed by such third-party’s privacy policy.  We encourage You to review the social media provider’s privacy policy before interacting with a Social Media Property and/or Feature.

The Site may offer publicly accessible blogs. You should be aware that any information You provide in these areas may be read, collected, and used by others who access them. You may contact Us to request removal of Your Personal Information from any blog we maintain.  In some cases, we may not be able to remove Your Personal Information, in which case we will let You know if we are unable to do so and why.

 

Security

In order to prevent unauthorized access or disclosure we have put in place reasonable security measures, including physical, electronic and managerial procedures to safeguard and secure Your Personal Information.

We use standard Transport Layer Security (TLS) certificates to secure pages used for inputting users’ Personal Information. However, unless we expressly advise You otherwise, the functionality on our Site does not provide a means for completely secure and private communications between us. Due to the open communication nature of the Internet, we cannot guarantee that communications between us will be free from unauthorized access by third parties.

If You believe that the Personal Information You have provided us has been compromised, or if You become aware of a potential security vulnerability in our Platform, please contact us using the contact Information provided below.

 

International Visitors

This Site is hosted in the United States and is intended only for United States visitors. This website is not intended for users located in other countries, including those within the European Economic Area. Please be aware that Your personal information may be transferred to and maintained on servers or databases located outside Your state, province or country and that such information is processed and stored in the United States. By providing Your personal information, You confirm Your consent to having such personal data hosted and accessed in the United States.

 

Guidelines for Children

We do not specifically collect information about children nor market our and our Network’s products or services to children. We have no reason to believe that the Site will attract children, or that children will access the Site or provide Personal Information.

 

State-Specific Data Privacy Rights

Certain states provide residents with privacy rights.  Such rights are not absolute and in certain cases are subject to conditions or limitations as specified in your state’s privacy law. We will not unlawfully discriminate against You because You exercised any of Your rights under applicable state privacy law.

 

Nevada Resident Privacy Rights

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell Your personal information to third parties as defined in Nevada law, and will not do so in the future without providing You with notice and an opportunity to opt-out of such sale as required by law.

Virginia Resident Privacy Rights

  1. 1.    Right to Access

You have the right to confirm whether we are processing your personal data and to access your personal data.

  1. Right to Correct

You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.

  1. Right to Delete

You have the right to delete personal data provided by or obtained about you.

  1. Right to Portability

You have the right to obtain a portable copy of the personal data that you provided to us.

  1. Right to Opt-Out

You have the right to opt-out of targeted advertising (as defined under Virginia law). We do not sell data as defined under Virginia law.

California Resident Privacy Rights

These rights are not absolute and in certain cases are subject to conditions or limitations as specified in California privacy law. We will not unlawfully discriminate against You because You exercised any of Your rights under California privacy law.

  1. Right to Know

You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.

  1. Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.

  1. Right to Delete

You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

  1. Right to Portability

You have the right to obtain a portable copy of the personal data that you provided to us.

 

  1. Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as those terms are defined by applicable law). We do not do not knowingly sell any personal information of children under age 16.

If You wish to opt-out of such sharing or “sale” of Personal Information, You may complete an opt-out request at the “Do Not Sell My Personal Information” link. 

Once You make an opt-out request, we will wait at least 12 months before asking You to reauthorize personal information sales.  We will respond to Your request within 15 days, or other period as required or permitted by regulation.

 

Exercising State-Specific Privacy Rights

Request Form

To exercise your state-specific privacy rights, you may submit an online Privacy Request Form or call us as indicated below in the “Contact Us” section.

You may use the same form to appeal our decision regarding a request related to your rights under Virginia law, if applicable.

To submit a request to opt out of the sale or sharing of your personal information, you may click on the link “Do Not Sell or Share My Personal Information” on the footer of our websites.   In the alternative, you may choose to enable online a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out as outlined in the Consumer Consent and Choices section above. 

Verification Process

To protect Your privacy, we will verify Your identity prior to responding to a request for data.  The request form will require some initial contact information that we will compare against our records. 

Upon submission of the form You will be required to confirm Your request via email.  You may receive an email from “On Behalf of Our Privacy Team” to which You must respond in order to verify Your identity and access our response(s). 

If You request disclosure of specific pieces of personal information, we may take additional steps as permitted or required by law.  For example, we may call You to verify Your request, in addition to matching at least three pieces of personal information You provide with information we maintain, and require a signed declaration, under penalty of perjury, that You are requesting Your own personal information.

Please note that state law may prohibit us from disclosing highly sensitive information in response to a request, including Your: social security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. We will, however, inform You if we have collected such information and identify the type of information with sufficient particularity.

If an authorized agent is submitting on Your behalf, we will require submission of either 1) a written authorization, signed by You, that authorizes that agent to make the specific request on Your behalf; or 2) other valid legal authorization.

Any personal information collected from You in connection with verification of Your request will be used solely for the purposes of verification.

 

Contact Information

If You have any questions about this Privacy Policy, the practices of the Site, or Your dealings with the Site, please contact us via the following methods:

ProCFO Consulting

Attn: Privacy Team
2601 Hemingway Ln, Mahwah, NJ 07430

 (201) 401-6904

We will not retaliate against any person for filing a privacy complaint. Your privacy and confidence in our abilities is of utmost importance to us.

Policy Updates

This Privacy Policy may change from time to time. This Privacy Statement is in effect as of the date above. If we change this policy, we will post the revised version here and change the “effective date” to show the date from which the new policy will apply. We may also contact You directly where we deem appropriate to do so under applicable law. If you object to any changes, you must cease using the Services immediately.  We encourage You to check here regularly for the most up-to-date version.

Accountability

Responsibility for our privacy management program and this Privacy Policy rests with designated individuals and an appointed privacy officer.  We also have systems in place to respond to requests from individuals with respect to their Personal Information.