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Effective Date: July 20, 2020
Last Updated: July 24, 2020
TransACT Communications LLC and its affiliates ActivityRight and InviteRight (collectively referred to herein as “TransACT”, “we”, “our”, or “us”) recognizes the importance of protecting the personal information we may collect from visitors and any other individual or entity (“Users”, “you”, or “your”). This privacy policy (“Privacy Policy”) applies to data collection and privacy practices of TransACT and when we collect personal information through your use of the website, www.transact.com, www.rightlabs.com, www.actpoint.com, and other TransACT-related sites, software, applications, communications, capabilities and services (“Services”) accessible on or by any top-level TransACT domain owned by us (each, a “Site” and collectively the “Sites”). Please note that this Privacy Policy excludes services that state that they are offered under a different privacy policy.
Our Privacy Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; (5) the choices we offer, including how to access and update information; (6) and the measures we take to keep your information safe. Specifically, our Privacy Policy covers the following topics:
By accessing or using the Sites or Services in any manner, you also agree to be bound by TransACT’s Terms of Use (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.
TransACT is the sole owner of the information collected on these Sites and Services. We collect information, including personal information, to provide better Services to all our Users. We will not sell or trade or rent your personally identifiable information to others in ways different from what is disclosed in this statement. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, information about your device, and certain metadata. TransACT collects Personal Information from our users at several different points on our websites.
In some instances, you may provide to us Sensitive Personal Information. We use the term “Sensitive Personal Information” as defined by the privacy laws in some countries, which means personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs, trade union membership or professional association, physical or mental health condition, medical treatment, genetic data, biometric information, and information about an individual’s sexual life or sexual orientation. We only process Sensitive Personal Information in your jurisdiction to the extent permitted by applicable law. You are not required to provide TransACT with any of your Sensitive Personal Information, and choosing not to do so will not prevent you from purchasing any Services from TransACT. We do not generally collect Sensitive Personal Information unless you volunteer it.
If you provide us or our service providers with any Personal Information relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Policy. If you believe that your Personal Information has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Information, please contact us by using the information set out in the “How to Contact Us” section below.
The Personal Information which we collect includes, but is not limited to, the following circumstances and data elements:
As you evaluate whether TransACT is the right solution for you, you may choose to provide us with Personal Information about yourself, including your name and email address by completing forms on our website, or when creating and signing into your account. We will also collect financial data such as payment card details and bank account numbers in order to process transactions for certain services.
In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Information about yourself when you report a problem or have a question about our services.
We post customer testimonials on our Site which may contain Personal Information. We do obtain your consent via email prior to posting the testimonial to post your name along with your testimonial.
We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on Your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties.
If you grant us access to your location, TransACT may collect information about your location when you use our Sites and Services. Your location can be determined by information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. The specificity of the location data collected may depend on a number of factors, including your Internet browser and the device you are using (e.g. laptop, smartphone or tablet) and how you are connected to the Internet (e.g., via cable broadband connection, WiFi). Depending on the platform or browser you use to access our Applications (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the Applications mobile application.
When using our Services, we or our service provider may collect your unique device ID. We may use such information for internal purposes and to provide you a better experience, such as to troubleshoot application problems you may experience. We may associate device ID with personal information you provide to us. You may learn more about opt out of any anonymous device ID collection via the privacy settings available within your mobile device.
In order to access these websites, a user must first subscribe through our online e-commerce site. During the subscription process, a user is required to give their contact information (such as name and email address). This information is used to contact the user about the services on our web sites for which they have expressed interest. We do not ask for unique identifiers such as government-issued identification numbers, income, gender, or medical information.
We request contact information and financial information (a district-issued Purchase Order number). This information is used for billing purposes and to complete the customer or user’s order. If we have trouble processing an order, this contact information is used to get in touch with the user.
To simplify the subscription process and verify user data, we have loaded a publicly available school district database that pre-fills user fields with a subscribing district’s full name, address, phone, fax and web site information. The user can update this information if it is incorrect and the update overwrites the original district data. See the How to Update User Information Section below to update user information after completion of the subscription process.
In order to allow other staff of subscribing districts to use www.transact.com, we offer opportunities for others in the district to “register”. The information gathered is the same contact information asked during the original order (full name, title, demographic information, phone and email address). Each user creates their own password; their email address becomes their username.
TransACT engages in co-marketing activities with several education-related non-profit agencies. We also have created a national advisory board comprised of several superintendents who are also customers. From time to time, a list of enrolled districts and their subscription services may be shared with these groups. At no time is any personal information about individuals shared or sold.
We send all new users a welcoming email to verify username and the subscription ordered. We also include information about how to distribute information to register other users in the district.
The original subscriber will occasionally receive information via email and/or fax on new products, services, special opportunities and newsletters. By subscribing at www.TransACT.com and providing an email address on the TransAct Sites, you agree that we may contact you in the event of a change in this Privacy Policy or to provide you with these Service Enhancement Communications and similar communications. Other users who register for personal access may or may not receive these special service emails.
Our Users are given the opportunity to “opt-out” of having their information used for purposes not directly related to use of these Sites. Users who no longer wish to receive our newsletters or promotional materials may unsubscribe by sending an email to TransACT support at the contact information listed below. Type the word “Unsubscribe” in the subject line of your email browser.
We give users up to 30 days to opt-out of receiving our newsletters or promotional materials after receipt of these communications; when we receive an opt-out request, we stop sending these types of communications within 10 business days to the requestor’s email address. We do not help a third-party to send email to that address or request a third-party send email on our behalf.
At any time, you can contact us through privacy@transact.com or the address or telephone number provided below to unsubscribe and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Information.
Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, to provide you with any service related notices, or to discuss important technical issues that may affect your service.
We periodically send our subscribers site and service update email announcements. Subscribers are not able to “unsubscribe or opt-out” from service announcements which contain important information about the service. We communicate with our subscribers to provide requested services or to discuss important technical issues that may affect their services.
We use various technologies to collect and store information when you visit one of our services to enable and improve our services and to monitor traffic only. This may include using encrypted cookies to store session information required to use our products, or similar technologies to identify your browser or device only for the purpose of enabling the functionality of our products. We also use these technologies to collect and store information when you interact with services from our partners to monitor traffic and improve our services. We do not use ADid and do not share DeviceID and do not sell or share unique identifiers with third-party service providers for advertising or commercial purposes. Our partners include Google, Wootric and similar partners.
Cookies. A cookie is a piece of data stored on the user’s hard drive containing information about the user. For instance, by setting a cookie on our site, the user would not have to log in a password more than once, saving time while on our site. If a user rejects the cookie, they may still use our site but may have limited access in some areas. Cookies help us track how our site is used, how often it is used, and what documents or content are accessed most by users.
We do not allow business partners to use cookies from our site.
Web Beacons. Pages of our Services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
We use IP addresses to analyze trends, administer the site, track user’s movements, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
We do not share Personal Information with companies, organizations and individuals outside of TransACT unless one of the following circumstances applies:
We attempt to notify Users about legal demands for their Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
We and our service providers may use IP addresses to understand the locations from which our Users are accessing the Services. Except where prohibited by applicable law or regulation, we may combine information collected through one source with information obtained through other resources. We also may supplement the information we collect with information obtained from third parties. We will treat any information that we combine with your personal information as Personal Information pursuant to this Privacy Policy.
TransACT may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”). We may disclose such de-identified information publicly and to third parties under agreement with us.
We may use your Personal Information in furtherance of our legitimate interest to provide you with the Services offered by TransACT. We may also use your information to manage our contractual relationship with you or to comply with our legal obligations.
We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.
These websites may contain links to other sites. Please be aware that TransACT is not responsible for the privacy practices of these other sites. We encourage our users to be aware when they leave our site and read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this Site.
We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Information.
TransACT only operates in the United States and Canada and we do not transfer Personal Information outside of North America. If we ever transfer your Personal Information out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Information is protected.
These Sites take precaution to protect our Users’ information. When Users submit sensitive information via these web sites, your information is protected both online and off-line.
All of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job are granted access to personally identifiable information. An example of which TransACT employees have access to this sensitive information is an accounting clerk processing purchase orders. Our employees must use password-protected screen-savers when they leave their desks. When they return, they must re-enter their password to regain access to your information. Most importantly, ALL employees are kept updated on our security and privacy practices. At least every quarter, or more often if necessary, our employees are notified and reminded about the importance we place on privacy and what they can do to ensure that our customers’ information is protected. Finally, our servers that store your personally identifiable information are kept in a world-class multi-million dollar, 24/7 secure environment.
TransACT maintains administrative, technical and physical safeguards designed to protect the user's Personal Information and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we and/or our service providers use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.
Although we take reasonable steps designed to protect your Personal Information, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks). We cannot and do not guarantee or warrant the security of your Personal Information or any information you disclose or transmit to us. We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Information that may affect you so that you can take the appropriate actions.
For your own privacy protection, we urge you to keep all passwords confidential. We also recommend that you do not include sensitive information such as passwords, social security numbers or payment information, in any emails that you send to us. If you become aware of any breach of the terms of this Privacy Policy or of the security of the Services, please notify us by email at privacy@transact.com.
If you have any questions about the security of our web sites, you can send an email to Business Services.
If a user’s Personal Information changes (i.e., phone number, email address, etc.), we provide a way to correct or update personally identifiable information. This can be done by the district subscriber known as the “Primary Contact” within the My Accounts section of the site. The Primary Contact invites other district users to register for personal access and may also update user or district information.
Our Site is not intended for children under 16 years of age. We do not intentionally gather Personal Information about visitors to our Sites who are under the age of 16 or sell products or Services to persons under the age of 16. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us privacy@transact.com. If we learn that we have inadvertently collected the Personal Information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible in accordance with applicable law.
TransAct does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.
California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes. To make such a request you should send (a) an email to privacy@transact.com with the subject heading “California Privacy Rights,” or (b) a letter addressed to TransACT Communications LLC, Attention: Privacy Inquiry, 5105 200th Street SW, Suite 200, Lynwood, Washington 98036. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
TransACT customers (“TransACT Partners”), engage us to deliver Services to their employees, agents other users. Partner Information, Information about our Partner’s Contacts and Archival Information (each defined below) are governed by this Privacy Policy, the TransACT Terms and Conditions and any other services agreements between TransACT and the applicable Partner.
We treat Partner Information, Information about our Partner’s Contacts, Archival Information and Automatically Collected Information as the confidential and proprietary information of our TransACT Partners, subject to the terms of the TransACT Terms and Conditions and any other service agreement between TransACT and the Partner. We do not share Partner Information, Information about our Partner’s Contacts, Archival Information or Automatically Collected Information with third parties unless directed to do so by our Partner, as may be necessary to provide services to the Partner, to our advisors, affiliates, representatives, agents, service providers, in connection with a business transaction (such as a merger or sale), as allowed under the terms of our agreement with our Partner, or in response to a court order, subpoena, warrant or to comply with a legal requirement or to cooperate with an investigation. We may disclose Partner Information, Information about our Partner’s Contacts, Archival Information or Automatically Collected Information for the aforementioned reasons, or in order to protect our rights or the rights of our affiliates, TransACT Partners, business partners or service providers.
We will retain Partner Information we process on behalf of our TransACT Partners for as long as needed to provide services to our Partner, or for the period of time requested by a particular Partner.
If we decide to change our Privacy Policy, we will post those changes on our Homepage of www.transact.com and www.actpoint.com so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by email. We will not reduce your rights under this Privacy Policy without your explicit consent. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.
If you have any questions, comments or concerns about this Privacy Policy, or if you would like to exercise the choices discussed above, please contact us:
Via e-mail: privacy@transact.com
By writing to us:
TransACT Communications LLC
Attn: Privacy Policy Inquiry
5105 200th Street SW
Suite 200
Lynwood, Washington 98036
Effective on: 07/20/2020
END of TransACT Privacy Policy Statement.
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