1.0 Our Commitment to Privacy
a. Palindrome Performance LLC respects the importance of consumer information security and personal privacy. Further, Palindrome Performance LLC is committed to handling a consumer’s information in a secure environment. Therefore, we have made it a critical focus to protect the confidentiality and security of the personal information you provide us.
2.0 The Information We Collect
a. We or our client network/vendors may collect two types of information: Personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (“Non-PII).
b. PII - PII is information that identifies a specific user of the Services and is provided by the user.
c. When you engage in certain activities on the Services, such as when you register to use the Services, you may be asked to provide certain information about yourself that we will collect and store. This information may include, but is not limited to: first and last name, physical address, email address, phone number and other information specific to the product you have expressed interest in.
d. Depending on what activity you are engaged in, some of the information that may be requested will be identified as mandatory or as voluntary.
e. If you do not wish to provide the mandatory information for a particular activity, you will not be permitted to engage in that activity.
f. You do not have to engage in the activities in which we ask you to provide such information. But if you choose to do so, additional information may be requested, such as your first and last name, gender, email address or date of birth.
g. We log Internet protocol (IP) server addresses for system administration purposes and catalog traffic patterns through the Sites. This information may or may not be linked to a consumer’s personal information at our discretion.
h. Non-PII: Non-PII is information that identifies your computer and its navigational patterns through the Services (but not a specific user).
i. We may automatically collect Non-PII information when you visit the Services, through the use of a variety of tools including cookies (small text files that are stored on a user’s computer for record- keeping purposes and which contain information about that user’s computer), or other available data analysis or collection technologies.
3.0 How We Use and Share Information
a. We use the information we collect to (a) provide, maintain, and protect the Services; (b) notify you of promotions, special events, new services and special offers, for example, through e-mails; (c) tailor our product offerings, customer service and overall experience; (d) improve the content, operation, appearance and utility of the Services; (e) conduct surveys, research and evaluations; (f) troubleshoot and resolve disputes; (g) gather demographic data and (h) accomplish other administrative tasks.
c. Cross-Device Advertising and Tracking: Palindrome Performance LLC may collect and use the above mentioned data for cross-device advertising purposes. This process allows consumers to experience a personalized, informative advertisement that targets specific product interests over multiple devices. The information may also be used for analytics, and reporting purposes such as an advertisement effectiveness and overall campaign success.
Palindrome Performance LLC may implement cross device advertising and tracking through two methods:
1. We may use a deterministic approach which may identify and track consumers across devices through identifying characteristics such as a consumer login account. This information may also be used to connect data across different devices.
2. We may also use a probabilistic method which may identify and track consumers through an IP address and the utilization of cookies. This information may also be used to connect data across different devices.
These methods allow information about your use of websites or applications on your browser or device to be combined and used with information from your other browsers or devices. I.e. Your tablet and cell phone. This enables delivery of advertisements or informational data to your multiple devices.
d. Push Notifications/Alerts: We may use push notifications and alerts to notify you of services and/or products that you have expressed interest in on multiple devices. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we may need to collect certain information about your device such as operating system and user identification information. You may opt-out of push notifications or alerts through your browser settings.
e. Third Parties: When you register with the Sites, you explicitly authorize us to share your information with our client network/vendors so that they may contact you via email, SMS, telephone and/or direct mail. Specifically, at registration you agree to receive autodialed or prerecorded calls (including to mobile numbers) and texts and emails from Palindrome Performance and its affiliates, partners, and vendors to the phone numbers (including mobile numbers) and email addresses you provide to Palindrome Performance today or in the future and to any phone numbers or email addresses subsequently associated with you by Palindrome Performance or its affiliates or marketing partners, affiliates or vendors. Message and data rates may apply. You understand and agree that your consent is not a condition, directly or indirectly of a purchase.
Palindrome Performance will share and/or sell the information that you provided with our network of clients including but not limited to: mortgage bankers, mortgage brokers, credit consultants, insurance brokers or any other business in our network that may be related to the service or product you have expressed interest in. As a result, different types of businesses may be provided your information and may contact you.
Your information, including your PII, may be sold to client network/vendors. We may also sell your information, including your PII to other affiliated companies, and with other vendors and business partners. Some business partners include companies who provide business services to us or on our behalf, such as to market products or services to you, monitor Services activity, help to maintain our customer database, and administer e-mails, surveys or other contests.
f. Opt-Out: If you decide that you are no longer interested in receiving SMS or email communications from us, you may follow the instructions in our SMS or emails to unsubscribe from our email list or by emailing us at: email@example.com. If you wish to opt-out of disclosure and to be excluded from our mailing list, please email us at: firstname.lastname@example.org. As to communications from our client network/vendors, affiliated companies, vendors and business partners, please follow the instructions to opt-out in those entities’ communications.
g. Legal Compliance/Other Information Disclosure: We also reserve the right to disclose your
information in good faith as required by law, in response to legal process including law enforcement requests, and with any person or entity that may acquire all or any part of our business or assets, in connection with any change in control of us, and where needed to prevent fraud and to protect the safety, property, or legal rights of users of the Services or our affiliates. We may also disclose your information to manage and protect our information technology infrastructure and security. We may also disclose your information for any other purpose with your consent. We may share non-PII at any time for any purpose.
4.0 Unsubscribe, Opt-Out or Revoke
5.0 Third Party Information Collection/”Do Not Track”
With respect to Ad Servers: To try and bring you offers that are of interest to you, we have relationships with other companies that we allow to place ads on our Site. As a result of your visit to our Site, ad server companies may collect information such as your domain type, your IP address and clickstream information. For further information, consult the privacy policies of the companies representing the ads or http://www.google.com/privacy_ads.html.
Third parties with whom we partner to provide certain features on the Site or to display advertising based upon your web browsing or application activity use Flash cookies and HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07. html
“Do-Not-Track” is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to Do-Not-Track signals.
If you wish to limit the collection of information by us or third party partners to provide you with advertising based upon your website browsing activities and interests, you may click [http://preferences-mgr.truste.com] to opt out. To opt out of targeted advertising on your mobile device, iOS users can click here: https://support.apple.com/en-us/HT205223 to learn how to limit ad tracking and Android users can click here: https://support.google.com/ads/answer/2662922?hl=en to learn how to opt out of interest-based ads. Please note that opting out of interest-based/targeted advertising does not limit all advertising. You will continue to receive generic advertisements.
6.0 Privacy Policies of Third Parties
c. We are not responsible for the policies or practices of third parties.
7.0 Editing and Requesting Your Information
a. We will permit you to change your profile settings. Even after you remove your information from your profile, copies of your information may remain viewable elsewhere to the extent it has been shared with others or it was copied or stored by other users. We may also be required to retain your information by law or for legitimate business purposes, such as to prevent identity theft or other misconduct.
b. We will permit you to request a copy of your PII that we have collected about you by emailing us at email@example.com.
c. You can also correct factual inaccuracies in this information by emailing us at firstname.lastname@example.org.
8.0 Storage and Security
a. We will retain PII, including user location information, only as long as our business needs require. We will then destroy or render unreadable any such information upon disposal.
b. We believe the security of your information is a serious issue and we are committed to protecting the information we receive from you. We use commercially reasonable security measures to protect against the loss, misuse and alteration of your information under our control.
c. Depending on site requirements, we may employ Secure Sockets Layer (SSL) encryption technology to transmit data between a consumer’s browser and our web server. To use our websites, a consumer will need an SSL-capable browser such as MS Internet Explorer 4.0 (or higher) or Netscape Navigator 4.0 or higher.
d. We require that client network/vendors handle consumer information under confidential conditions.
e. Notwithstanding such security measures, please be aware that no security measures are perfect or 100% secure, and we cannot guarantee the security of any information transmitted to or from the Services.
f. Although we have agreements and vetting procedures in place for third parties, We are not responsible for the actions of any third parties that may receive any such information.
g. You should note that the security of your personal information also depends on you. Please do not communicate any information to us through unsecured channels, such as when you are in public areas. Where we have provided you or you have chosen a password, access code, or similar security feature, you must keep the password, access code or security feature confidential. Please do not share your password with anyone. If you believe your password or account has been compromised, please contact us immediately at email@example.com.
9.0 Minors and Privacy Issues
a. Children’s Online Privacy Protection Act- This site is intended to be used by people the age of 18 and older. We do not knowingly allow any users under the age of thirteen to use our service. However, if you become aware of the existence of a user who is under the age of thirteen, or that an individual under thirteen has provided their information to us, contact us immediately with details at firstname.lastname@example.org. If you have been reported as being below thirteen by another person, we may request that you verify your age to us, including providing us a copy of your photo ID as a condition of your continued use of our service.
b. No part of the Services is designed to attract anyone under the age of 18.
c. Children under the age of 18 may not use the Services.
d. If you are a parent or guardian and believe that your child under the age of 13 has provided personal information to us, you may contact us to request this information be deleted.
c. Your continued use of the Services after the effectiveness of such revisions will constitute
d. If a change would authorize the use of your PII for a new or materially different purpose, then we will send you an email notification. It is your responsibility to ensure that we have a current, working email address on file for you.
b. For more information about protecting your privacy, you may wish to visit: http://www.ftc.gov.
Date last revised: June 10, 2019