Privacy
Terms, Conditions, and Privacy
GUIDE CHANGE LLC ("GUIDE CHANGE," "our," "us," or "we") respects user and member privacy. We believe providing the best protection of their information reasonably possible is our responsibility. Subject to applicable laws, any information you submit to us will not be used in any manner to which you have not consented. This Terms, Conditions, and Privacy agreement (the “Agreement") is the binding contract into which you enter by signing up or otherwise using our service. It further outlines more specifically what information GUIDE CHANGE may collect from you and how that information may be used after it is collected. We want to assure you that your Personally Identifiable Information and Non-Personally Identifiable Information will be respected and we will take steps to ensure that such information will be used in ways that are in compliance with this Agreement and applicable laws. This Agreement relates to any Personally Identifiable Information and Non-Personally Identifiable Information collected, stored, owned, or used by GUIDE CHANGE; this includes, but is not limited to, the collection of information through the GUIDE CHANGE application (the "Web App") and any service or feature offered therein, including but not limited to the portal and any promotions that may be open from time to time.
This Agreement does not apply to any other websites, mobile applications, social media platforms, email lists, or any other information collected, owned or stored by any entity other than GUIDE CHANGE or through any other means other than the Web App.
Generally, use of our Web App may require you to provide information such as your name, company name, email address, address, telephone number, credit-card number and other relevant data. This information is used by us to identify you and provide you with support, services, mailings, sales, marketing, billing, and in order to meet our obligations to you.
Information Collected
GUIDE CHANGE may collect two (2) types of information from you: (1) Personally Identifiable Information and (2) Non-Personally Identifiable Information:
1. Personally Identifiable Information. Personally Identifiable Information refers to the types of information that can be used to identify or contact a single person, or to aggregate disparate pieces of information into one data picture of a single individual. The types of Personally Identifiable Information collected by GUIDE CHANGE may include:
(i) Contact Information. This includes but is not limited to your first and last name, company name, company address, phone number, fax number, date of birth, email address, website, and social media links.
(ii) Account Information. This includes but is not limited to the information we collect about you when you register for an account, and subsequently when you pay a bill, purchase services, or in any way interface or interact with the Web App;
(ii) Other information. All other information that can be used to identify a specific individual.
2. Non-Personally Identifiable Information. Non-Personally identifiable information is information that cannot be used to identify a specific individual, but we believe is nonetheless worthy of respect and reasonable protection. The types of Non-Personally Identifiable Information collected by GUIDE CHANGE either by virtue of your visiting or making use of the Web App or through your own submission may include:
(i) Internet Protocol (IP) address, Unique Device Identified (UDID), and protocol information;
(ii) Browser language and browser agent;
(iii) Domain Name System (DNS) requests;
(iv) Browsing history, limited only to the time spent on the domain, time and date of the visit, number of clicks, and referring link from which the user came;
(v) Hypertext Transfer Protocol (HTTP) headers and application information, system date, full request, status, and content length;
(vi) Operating System, and/or
(vii) Similar behavioral, usage, and/or device information.
How Information is Collected
GUIDE CHANGE permits users to sync and visualize their personal financial information through the Web App. In order to do this, the Web App must have access to your accounts with your various financial institutions. Any information, such as usernames and passwords, provided for this use will only be used for this use.
GUIDE CHANGE does not collect personally identifiable information about you through the Web App without your knowledge, action or without informing you of such collection. However, your information is requested, collected and stored through your use of specific features of the Web App. In the course of your visiting and interacting with the Web App, we may collect Non-Personally Identifiable Information and Personally Identifiable Information about you from the following sources:
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Information we receive from you through forms you complete or contacts you make with us, or information we receive from you, personally, through the use of the Web App, including, but not limited to your use of the Web App, your registering for the Web App, your syncing, linking, or connecting of your bank account or other third party services with the Web App, email newsletter registration, the "Contact Us" form or in conjunction with any promotion.
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Information we receive from your device through the use of the Web App.
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Information we receive from our partners, service providers, payment processors, or other members.
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Information we receive from our partners in conjunction with your submission of an application for an available position.
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Information we receive from other sources.
We may collect Non-Personally Identifiable Information from you, with your implicit consent by virtue of using the Web App, in the following ways:
HTTP Cookies. As is true of virtually all dynamic Web Apps on the internet, the Web App uses "cookies" (i.e., a small file that the Web App writes to a user's device) to help track your usage of the Web App, including what advertising you have seen and whether you have logged in. Cookies are used to "remember" settings you choose to enable on the Web App and to record your browsing activity on the Web App. Neither the Web App, nor the cookies, can read any data off of your device outside of our cookies; this includes any cookies saved by other websites. If you wish to not receive a cookie following your visit or use of the Web App, you must disable cookies globally or for the Web App specifically through your web browser. Similarly, you can delete all of the cookies you have saved through your web browser. Consult your web browser's documentation for assistance.
Web Beacons. A web beacon is an embedded image, usually invisible, in a website that is used purely to determine whether a user has accessed the website. The intent is to track who is reading a given website, when they are reading it, and from what device they are reading it from. The use of web beacons is commonplace, but it does mean a third party server will receive your internet protocol address, the type of web browser you are using, and the existence of any cookies previously saved to your device from earlier visits. The owner of the third party server can store all of the information, assign it a unique tracking token, and monitor your behavior on the website over a long period of time.
Unique Identifiers. Over the course of your visiting and utilizing the Web App, we may assign you a unique identifier to keep track of your future visits and usage. We use the identifier to gather aggregate demographic information and form a snapshot of who our users are as a whole, and we use it to personalize the information you see on the Web App and, at times, the information you receive from us via our mailing list. We keep this information purely for our own internal use, and this information is not shared with others, nor is an effort made to connect a unique identifier with an individual person's identity.
Use of Information Collected
Information we collect and aggregate about our users is used for a few purposes:
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To provide you with personalized recommendations.
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To compare one user’s information with anonymized information of other users.
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To provide you with information regarding the products, services or offerings you request.
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To improve our products, services and offerings.
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To communicate with you about our products, services and offerings.
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To respond to your submission of your contact information and resume in conjunction with a job opportunity.
Status as Data Controller or Data Processor
We process Personally Identifiable Information both as a Data Processor and as a Data Controller, as defined by the GDPR. We retain your information as long as is necessary to serve your account, and as long as your account remains active or your information is required to complete our contractual obligations to you or third parties, or to law enforcement. When your account is closed, by either you or Us, we may nevertheless continue to communicate with you via the means you provided us when you registered for your account. This includes, but is not limited to, USPS mail, email, text message, telephone, and mobile phone.
When Information Is Disclosed
Your Non-Personally Identifiable Information or Personally Identifiable Information may be disclosed when required by law, or when we believe that such disclosure is necessary to comply with a legal process, enforce this Agreement, respond to claims that any materials or information provided by you violates the rights of a third party, or to protect the rights, property, or safety of GUIDE CHANGE, its members, or the public.
We do all that we reasonably can to ensure Personally Identifiable Information that is disclosed to us by our users and members is secure. We may provide Non-Personally Identifiable Information or Personally Identifiable Information to our affiliates and other businesses or persons for the purposes of (1) processing such information on our behalf, and (2) promoting our services or the services of our affiliates and partners, as permitted by applicable privacy law. We require that these third parties agree to process your information in compliance with this Agreement or in a similar, industry-standard manner, in compliance with applicable privacy laws, and we use reasonable efforts to limit their use of such information and to use other appropriate privacy and security measures. The use of your information by a business partner may be subject to that party's own privacy policies and terms of use, and you should always read and understand the Privacy Policies of any entity to which you submit information.
We may share your Non-Personally Identifiable Information with third parties to illustrate Web App user usage patterns for any advertisement campaigns we may run, content we produce, the Web App's functionality, and the services we provide.
We must reserve the right to disclose Non-Personally Identifiable Information and Personally Identifiable Information to shield ourselves from liability, to investigate and defend any third party claims or allegations, to assist law enforcement agencies, to protect the security of the Web App, and to protect the rights, property and safety of GUIDE CHANGE, its members and users. We cannot make any representations regarding your information in the event GUIDE CHANGE ceases business activities, is sold, acquired or otherwise merges with another company, the Web App is shut down, the server is compromised, or the domain name expires. We cannot and will not be responsible for any breach of security by any third party or for any actions of any third party on the site that, despite our best efforts, receives any of the information that is disclosed to us.
Informed Choice Non-Disclosure
You are always free to opt-out of any of our services that necessitate the exposure of your Non-Personally Identifiable Information or your Personally Identifiable Information, however, you cannot opt-out of our use of information about you in connection with your merely visiting or making use of the Web App or viewing this Agreement.
Information from California Residents
California law permits California residents to request information from a business regarding the use of certain categories of Personally Identifiable information for the purposes of direct marketing. California residents that use the Web App may request this information by sending an email to INFO@GUIDECHANGE with the Subject “California Compliance”. If requesting by email, please include your name used on the Web App.
Information from Underage Persons
The Web App is intended for use by adults. We do not collect any Personally Identifiable Information from any person that are known to be under the age of thirteen (13) without permission from a parent or guardian. If we learn that we have collected Personally Identifiable Information from a child under the age of thirteen (13), we will delete that information as quickly and completely as possible.
Information from European Union Users
By using the Web App and providing us with your information, you authorize us to collect your information, use and store your information outside of the European Union ("EU"). All transfers of data within the European Economic Area (EEA) will be done in accordance with the data processing requirements of the GDPR.
International Transfers of Information
Personally and Non-Personally Identifiable Information may be processed, stored, and used outside of the country in which you are located. Data privacy laws vary across jurisdictions, and different laws may be applicable to your data depending on where it is processed, stored or used.
Privacy on Third Party Sites
The Web App may contain links to any number of other websites, including links to various third party service providers, used for the purposes of providing information or processing your requests. GUIDE CHANGE is not responsible for the privacy practices or the content of any of those websites. Please check those websites for privacy policies and read them thoroughly prior to using their website.
"Do Not Track"
Your browser may permit, or may even default, to transmitting a "Do Not Track" header to websites and online services you visit. There is currently no industry standard for what a website can, or should, do when a user transmits such a header. As a result, the Web App, along with most other sites, does not recognize or modify its behavior as a result of the receipt of a "Do Not Track" header.
Security
Maintaining the security of your information is important to us both philosophically and for business purposes. We provide reasonable security measures and safeguards in connect with securing your Personally Identifiable Information. However, there is no perfect security on the internet or offline, and data breaches happen. We cannot and will not be held responsible for any such breaches.
Social Networking Features
From time to time the Web App will contain "buttons" that link to various social networking platforms. Additionally, GUIDE CHANGE may maintain presences on various social networking platforms, which enable you to interact with us. These interactions range from communicating directly with GUIDE CHANGE to "sharing" or "liking" content posted by GUIDE CHANGE.
If you opt-in to using the social networking aspects of the Web App, information you post or provide access to may be displayed on the Web App, on the social networking platform, or elsewhere. Similarly, if you post information on a third party platform in a way that references GUIDE CHANGE, your post and the content or images in that post may be published on the Web App in accordance with the terms of this Agreement or the privacy policies or terms of use of the third party platform. By linking to us on a social networking platform, we may be able to find out more information about you, your connections to other users, and any other biographical information you share publicly on the social networking platform.
Any information we collect, store, or control remains subject to this Agreement. However, any information collected and stored by any third party, including social networking platforms, remain subject to those third parties' privacy practices.
Prizes, Promotions and Surveys
From time to time GUIDE CHANGE may conduct surveys or hold sweepstakes, contests, or other promotions that necessitate requesting Non-Personally Identifiable Information and Personally Identifiable Information for the purposes of administering the surveys or promotions, determining the winners, and awarding prizes. GUIDE CHANGE collects and stores this information, such as name, mailing address, date of birth, email address, and possibly additional information, in a manner that is appropriate to the sensitivity of the data and is used only to fulfill your request. The information collected for the purposes of surveys and promotions may be merged with other information GUIDE CHANGE already knows, such as your answers to any surveys or questions sent in conjunction with the promotion.
Applicable Law
The Agreement (and any non-contractual disputes/claims arising out of or in connection with it) are subject to the laws of the state of Texas, United States of America, without regard to choice or conflicts of law principles.
Your Consent to this Agreement
By submitting Personally Identifiable Information or by visiting or making use of the Web App, you consent to the collection, storage and use of information by us as specified elsewhere in this Agreement or as we otherwise deem appropriate, unless you inform us otherwise. If we decide to change this Agreement, we will update the Agreement on the Web App but may not otherwise draw your attention to it. Each time you provide information to us, or we receive information from you, following any amendment to this Agreement, you will be signifying to us your assent to and acceptance of the revised terms for all information already collected and information that will be collected from you subsequently. We may use comments, information, feedback and correspondence that you may submit in any manner that we deem appropriate without any notice or any compensation to you.
EFFECTIVE AS OF: 7/1/2019
LAST UPDATED: 1/22/2020