Privacy Statement
Last Updated: May 5, 2023
At Copper Reef Enterprises d/b/a Plus Delta Partners (“Plus Delta”), we know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy.
By using or accessing the Service in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.
Remember that your access to and use of the products and services offered by Plus Delta (collectively, the “Services”) is at all times subject to our Terms and Conditions of Purchase, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms and Conditions of Purchase. Our Privacy Policy also applies to all users of the Plus Delta website (https://plusdeltapartners.com/ and any subdomains) or Plus Delta’s AGYL Services (apps.agyl.work).
Notwithstanding the foregoing or anything to the contrary in this Privacy Policy or the Terms and Conditions of Purchase, Plus Delta’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
What does this Privacy Policy Cover?
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we do not own or control or people we do not manage.
Changes to this Privacy Policy
Plus Delta may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our Services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will do our best to alert you to changes by placing a notice on the Plus Delta website, by sending you an email, and/or by some other means. Please note that if you have opted not to receive legal notice emails from us (or you have not provided us with your email address), those legal notices will still govern your use of the Service, and you are still responsible for reading and understanding them.
If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
What Personal Data does Plus Delta Collect?
We collect Personal Data about you from:
- You:
- when you provide such information directly to us, and
- when Personal Data about you is automatically collected in connection with your use of our Services.
- Third parties, both when they provide us with Personal Data about you and when we seek out information for Profiles, as discussed below (“Third Parties”). Third Parties that share your Personal Data with us
- Service providers. For example, we may use
- Other networks connected to the Services. If you provide any third-party account credentials to us or otherwise sign in to the Services through a third-party site or service (for example, using Salesforce, Blackbaud, or Ellucian), you understand some content and/or information in those accounts may be transmitted into your Account with us.
- Our clients. When Personal Data about you is automatically collected by our clients in connection with your use of our Services.
- Service providers. For example, we may use
The following chart details the categories of Personal Data that we collect and have collected over the past twelve (12) months. Throughout this Privacy Policy, we will refer back to the categories of Personal Data listed in this chart (for example, “Category A. Personal identifiers”).
|
|
|
Examples |
What is the source of this personal data? |
|---|---|---|---|
|
A |
Personal Identifiers |
Name, email, address, phone number, IP, username |
You Third Parties |
|
B |
Internet or other similar network activity information |
Website & application usage, browser/platform/device used, search history |
You Third Parties |
|
C |
Geolocation data |
IP, location data (city, country, state) |
You Third Parties |
The following sections provide additional information about how we collect your Personal Data.
Information You Provide to Us: We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Data such as your name, email address, phone number, and third-party account credentials (for example, your log-in credentials for
We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address
Information Collected Automatically: Like many other commercial websites, we may also gather information in connection with your use of the website or Service through the use of cookies and other similar technologies such as server logs, pixel tags, web beacons, user website activity and JavaScript (collectively, “Cookies”) to enable us to recognize your web browser or device and tell us how and when you visit and use our Service, to analyze trends, to learn about our user base, and to operate and improve our Service. Cookies are small pieces of data—usually text files—placed on your computer, tablet, phone, or similar device when you use that device to visit our Service. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).
We use the following types of Cookies:
Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Service. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Service, maintain your preferences over time and recognize you when you return to our Service. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Service such as by collecting information about the number of visitors to the Service, what pages visitors view on our Service and how long visitors are viewing pages on the Service.
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and this may cause some services and functionalities to not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
How We Use Your Personal Data
We process Personal Data to operate, improve, understand, and personalize our Services. We use Personal Data for the following purposes:
- To meet or fulfill the reason you provided the information to us.
- To communicate with you about the Services, including Service announcements, updates or offers.
- To provide support and assistance for the Services.
- To create and manage your Account or other user profiles.
- To respond to user inquiries and fulfill user requests.
- To market, improve, and develop the Services, including testing, research, analysis, and product development.
- To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.
- To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms and Conditions of Purchase.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
How We Share Your Personal Data
Disclosures of Personal Data for a Business Purpose
We disclose your Personal Data to service providers and other parties for the following business purposes:
- Performing services on our behalf, including maintaining or servicing accounts, providing client service, processing transactions, verifying client information, providing analytic services, or providing similar services on behalf of the business or service provider.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or we control.
We disclose your Personal Data to the following categories of service providers and other parties, who are located in the United States:
Service providers,
- Subscription management providers and payment processors
- Hosting and other technology and communications providers
- Analytics providers
- Client relationship management and client support providers
- Parties who acquire your Personal Data through an acquisition or other change of control.
- Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part)
- Other parties at your direction.
- Business partners
- In some cases, we may disclose information about your use of the Services to your employer or other users within your organization
Over the past twelve months, other than as described above, we have not disclosed your Personal Data to service providers or other parties for any purpose.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data,
- The Plus Delta website and Services use SSL (https).
- Account passwords are hashed when stored in our database.
- Plus Delta employees use passwords and enable screen locking.
- Access to AWS and Payment Processors is limited on a need-to-know basis and requires Two-Factor Authentication (2FA).
You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the privacy of your account and other Personal Data that we hold in our records, no security system is impenetrable, and unanticipated system failures or the efforts of malicious actors are an unfortunate reality on the Internet. Therefore, Plus Delta cannot guarantee that Personal Data during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide the Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data from children under 16. If you are a child under 16, please do not attempt to register for or otherwise use the Service or send us any Personal Data. If we learn we have collected Personal Data from a child under 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at privacy@plusdeltapartners.com.
California Resident Rights
If you are a California resident, you have the rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@plusdeltapartners.com.
Access
You have the right to request more information about the Personal Data we hold about you and request a copy of such Personal Data by emailing privacy@plusdeltapartners.com.
Deletion
You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Service or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
Emailing us at: privacy@plusdeltapartners.com.
Personal Data Sales Opt-Out and Opt-In
Plus Delta does not sell your data. If it does, Plus Delta will provide an opportunity for you to opt-out of such sale.
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months. However, you may change your mind and opt back in to Personal Data sales at any time by emailing us at privacy@plusdeltapartners.com.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may have different tiers of services as allowed by applicable data protection laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@plusdeltapartners.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
GDPR Privacy Notice
European Union Data Subject Rights
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) or the United Kingdom General Data Protection Regulation (UK-GDPR) with respect to your Personal Data, as outlined below.
For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the European Privacy Laws, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Plus Delta will be the controller of your Personal Data processed in connection with the Services. For purposes of this GDPR Privacy Notice, “Personal Data” includes (but is not limited to) Profile data, as defined above.
|
Category of Data |
Source of Data |
Purpose of Processing |
Grounds for Processing (e.g. contractual necessity, legitimate interest, consent) |
Specific Legitimate Interest (if applicable) |
|---|---|---|---|---|
|
Client Account Data (e.g. first last name, email, IP address) |
Data Subject |
Analytics |
Legitimate Interest |
Monitoring and conducting analytics on website & app use, pages/links clicked, traffic demographics, patterns of navigation, on potential security/spam breach, on performance issues, etc. |
|
Client Account Data (e.g. first last name, email, company) |
Data Subject |
Client Success Communication |
Legitimate Interest |
Personalized service and communications related to the client’s use of the product. |
|
Client Account Data |
Data Subject |
Marketing Campaign (email, list creation) |
Legitimate Interest |
Personalization, market research or direct marketing. |
|
Client Account Data (e.g. first last name, device type, browser) |
Data Subject |
Product Development |
Legitimate Interest |
Improving performance, troubleshooting bugs, other internal development needs. |
|
Client Account Data (e.g. first last name, email, company) |
Data Subject |
Sales Communication |
Legitimate Interest |
Targeted advertisement or direct marketing. |
|
Client Account Data (e.g. first last name, email) |
Data Subject |
Using Plus Delta Services |
Contractual Necessity |
Contractual Necessity |
|
User Session Data (e.g. utms, logged in, xsrf token) |
Data Subject |
Using Plus Delta Services |
Legitimate Interest |
Maintain logged-in state during a single browsing session. Maintain their logged in state across browsing sessions. Enable users to log back in when a new session is started. Prevent cross-site request forgery attacks. Product feature rollout, conducting analysis. Personalization of Web Content |
How and With Whom Do We Share Your Data?
We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us or you with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:
- Payment processors
- Fraud prevention service providers
- Analytics service providers
- Staff augmentation and contract personnel
- Hosting service providers
- Marketing service providers
- Product development service providers
- Client success providers
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
- Third party business partners who you access through the Services
We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including requests from law enforcement or other government agencies
- Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
- Maintain the security of our products and services
We also share information with third parties when you give us consent to do so.
Last, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
How Long Do We Retain Your Personal Data? We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with the Service. In some cases we retain Personal Data for longer if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@plusdeltapartners.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data by emailing privacy@plusdeltapartners.com.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by emailing privacy@plusdeltapartners.com.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about Plus Delta’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data: The Service is hosted and operated in the United States (“U.S.”) through Plus Delta and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Service, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Plus Delta in the U.S. and will be hosted on U.S. servers, and you authorize Plus Delta to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S.
Contact Information:
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, please do not hesitate to contact your Plus Delta representative or email us at privacy@plusdeltapartners.com.
Physical Address: 6965 El Camino Real, Suite #105-488, Carlsbad, CA 92009, USA