Privacy Policy
Last updated 20th, Feb 2023
Introduction
Fullgap, Inc. (“Fullgap” “We”, “Us”) is sensitive to your concerns about how we use the personal information we collect from you through Fullgap’s website (the “Site”) and other plug-ins exchanging information with Fullgap (“Applications”).
(The Site and Applications are sometimes collectively referred to as “Online Services” for simplicity.) This Privacy Policy covers Fullgap’s treatment of the Personally Identifiable Information we collect when you use the Online Services. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
This Privacy Policy also explains how and why Fullgap collects, uses, and shares personal information when you interact with or use our Site or Service. It also includes any information Fullgap collects offline in connection with the Service, which we may combine with information from the Site and Service. By reading this Privacy Policy, you will understand your privacy rights and choices.
When we say “Fullgap”, we mean Fullgap Inc., and any of its affiliates. When we say “Site”, we mean fullgap.co, and when we say “Service”, we mean the Site plus any websites, features, applications, widgets, or online services owned or controlled by Fullgap and that post a link to this Privacy Policy.
Accessibility
By using Fullgap Online Services, you accept the terms of this Privacy Policy. If you have questions or concerns about the Privacy Policy, please contact Customer Care at support@fullgap.co For purposes of data protection laws, Fullgap Inc., 447 BROADWAY, 2ND FLOOR SUITE #1279 NEW YORK, NY 10013 is the entity responsible for your information.
By using Fullgap Online Services, you accept the terms of this Privacy Policy. If you have questions or concerns about the Privacy Policy, please contact Customer Care at support@fullgap.co For purposes of data protection laws, Fullgap Inc., 447 BROADWAY, 2ND FLOOR SUITE #1279 NEW YORK, NY 10013 is the entity responsible for your information.
1. Information Collection
What information do we collect?
Information You Provide to Us
When you use the Service, you may provide us with information about you. This may include your name and contact information, financial information to make or receive payment for services obtained through the Fullgap platform, or information to help us fill out tax forms. When you use the Service, we may also collect information related to your use of the Service and aggregate this with information about other users. This helps us improve our Services for you. You may also provide us with information about your contacts or friends if, for example, you’d like to add those contacts to a message room. Agencies may also provide us with information about Freelancers associated with the Agency.
Fullgap requires each customer to provide us with personal information (collectively “Personally Identifiable Information”) to access and use Fullgap products and services. Personally, Identifiable Information is captured when a visitor accesses Fullgap’s Services, or speaks on the phone with or emails an Fullgap employee, and willingly discloses that information. This disclosure may occur when a visitor registers with an Online Service, engages in transactions, contacts customer service, or participates in contests, promotions, surveys, forums, content submissions, requests for suggestions, or other aspects of services offered by Fullgap.
Depending upon our relationship with you, we may collect the following categories and types of personal information from and about you:
Categories of Personal Information We Collect
Types of Personal Information Collected
Categories of Sources of Personal Information
Categories of Personal Information We Collect
Identifiers
Name, Email Address, Phone Number, Date of Birth, Social Media Account Information, Profile Data, IP Address
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations.
Sensitive Personal Information
Social Security Number, Driver’s License, State Identification or Passport Number, BVN, NIN
Directly from You
Verify your identity and to detect fraud, identity theft, or other misuse of your account.
Commercial Information
Transaction Data
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations.
Financial Data
Credit card or other financial account information, and billing address
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations.
Internet or Other Network or Device Activities
Unique device and app identifiers, browsing history or other usage data, , the browser and operating system you are using, the URL or
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service
Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and
Identifiers
advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites
providers and other users)
Regulatory Obligations.
Geolocation Information
Your Location
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations.
Sensory Information
Audio recordings if you call our customer service, video recording (if you provide permission).
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations.
Financial Data
Credit card or other financial account information, and billing address
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations.
Other information that identifies or can be reasonably associated with you
User-generated content, (e.g., community posts, feedback and job postings), photographs, examples of your work, information on work previously performed via the Service and outside
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and
the Service, skills, tests taken, test scores, hourly pay rates and earnings information.
Personally Identifiable Information includes: (i) “Contact Data” (such as your name, address, city, state, zip code, phone number, and email address); (ii) “Financial Data” (such as your credit card number, expiration date, and verification code or bank account information); (iii) “Demographic Data” (such as your zip code and sex).
Calls/Electronic Communications. In the regular course of our business, Fullgap may monitor and record phone conversations or email communications between you and Fullgap employees for training and quality assurance purposes. We may receive a confirmation when you open or click on content in an email from us, which helps us make our communications to you more useful and interesting.
Surveys, Sweepstakes, and Contests. We may provide you the opportunity to participate in surveys on our site, to measure customer satisfaction. If you participate, we may request certain personally identifiable information from you. Participation in these surveys, sweepstakes, or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes name, email address, and mailing address.
Testimonials and Reviews. We may display personal testimonials of satisfied customers. We will ask for your specific consent as part of the survey. If you wish to update or delete your testimonial, you can contact us at support@Fullgap.co. We may also display customer reviews. If you provide a review that we display and wish to update or delete it, you can also contact us at support@Fullgap.co
Information We Collect Automatically.
Traffic Data. Fullgap or its third-party service providers may collect a variety of visitor data such as IP addresses, browser settings, internet service provider (ISP) information, referring/exit pages, operating systems, date/time stamps, and clickstream data (collectively “Visitor Data”). The Fullgap internal servers and software automatically recognize Visitor Data. The Site may use Visitor Data to compile traffic data about the types of visitors who use the Site at specific intervals (collectively “Traffic Data”).
We may use Traffic Data to analyze Site traffic. We may also use Traffic Data to diagnose problems with our server, administer our Site, or display content according to your preferences. Visitor Data and Traffic Data may also be disclosed to business partners, affiliates, or advertisers on an aggregated and anonymous basis.
Cookies. Fullgap may use the standard cookie feature of major browser applications and third-party providers, including Google Analytics features (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration and
Google Analytics Demographics and Interest Reporting), or employ internally developed cookies, clear GIFs, pixel tags, tracking codes, and other technologies that allow Fullgap to store a small piece of data on a visitor’s computer, or any other device a visitor uses to access Online Services, about his or her visit to the Site or use of Applications. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited.
Location Information. When you use the Online Services, we may collect general location information (such as general location inferred from an IP address).
Information from Other Sources. We may collect information about you from third parties, such as marketing partners and researchers. Our customers may give us information about you, such as your Contact Data, in order to facilitate contracting through our Online Services. We may combine this information with information we collect from you and use it as described in this Privacy Policy.
2. Use of information
How do we use the information we collect?
We use information we collect from the Online Services to: provide you with the Online Services; communicate with you; process your orders and transactions; manage and remember your preferences and customize the Online Services; analyze and improve the Online Services or any other products and Online Services we provide; improve our advertising and marketing; verify your identity; facilitate your transactions with our third-party marketing partners; inform you of offers and discounts; comply with our legal obligations or as permitted by law; protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or the Online Services; and prevent fraud and enforce our legal terms.
We may combine information that we collect from you through the Online Service with information that we obtain from other sources. We may also aggregate and/or de-identify information collected through the Online Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes.
How do we disclose the information we receive?
Except as disclosed here, we do not rent, sell, or disclose your personal information to third parties. We disclose customer information as follows:
Order Processing. Fullgap, sometimes with the assistance of a third party or Fullgap subsidiary, may use your Personally Identifiable Information to process your payment through merchant account services, and to generate the products and services you order. Your Contact Data may be used to follow up with you on transactions you initiate through Online Services, respond to inquiries made through Online Services, inform you of changes to Online Services, and send you additional information about Fullgap and its products and services.
Third Party Marketing. Unless specifically authorized by you, we do not provide Personally Identifiable Information to third parties for marketing purposes. If you express interest in a third party offer or purchase a package that includes a third party offer, we may provide your Personally Identifiable Information to that third party solely in connection with the offer you have selected.
Required by Law. We may also disclose your personal information: as required by law, such as in response to a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a legal request.
Visitor Demographics. Contact Data and Traffic Data are used to gather general statistics about our customers and visitors. We may use Demographic Data to generate collective information about our users, but not in a way that identifies any user specifically. For example, we may inform third parties about the number of registered users and unique visitors, and the pages most frequently browsed.
Service Providers. We may disclose your Personally Identifiable Information to companies that provide support services to us (such as a printer or email service provider), or help us market our products and services. These companies may need information about you in order to perform their functions.
Blogs and Forums. The Site may include a publicly accessible blog and interactive forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. You should use caution when deciding whether to disclose your personal information in these areas of the site. To request removal of your personal information from our community forums, contact us at support@Fullgap.co 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.
Other Transfers. We may disclose Personally Identifiable Information and other data to businesses controlling, controlled by, or under common control with Fullgap. If Fullgap is merged, acquired, or sold, or if some or all of our assets or equity are transferred, we may disclose or transfer Personally Identifiable Information and other data in connection with the associated transactions.
Bankruptcy. In the event of an Fullgap bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used. If such an event occurs, your Personally Identifiable Information may be treated like any other Fullgap asset and sold, transferred, or disclosed to third parties, or used in ways not contemplated or permitted under this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on our site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Consent. In addition to the disclosures described in this Policy, we may disclose information about you whenever you consent to or direct such disclosure.
Analytics & Advertising
Analytics. We may use third-party web analytics services on the Online Services, such as those of Google Analytics. These service providers use the sort of technology described in the “Information We Collect Automatically” section above to help us analyze how users use the Online Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Service. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.
Advertising. Our partners and affiliates, including Google Analytics (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics and Interest Reporting), may use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. This means that these partners and affiliates may show our ads on sites across the Internet based upon your previous visits to our site. Together with our partners and affiliates, we may use these cookies and web beacons to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to our site.
The use of tracking technologies by our service providers, technology partners or other third party assets (such as social media links) on the site is not covered by our Privacy Policy. We do not have access or control over these technologies.
If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://aboutads.info/choices. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your online display advertising opt-out choice. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page.
Do Not Track. We do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
Fullgap does not respond to Do-Not-Track signals.
Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context.
Like many websites and online services, Fullgap does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com
Data we process on behalf of our customers
We receive information from and on behalf of our customers when they use our Online Services. Because of the nature of the services, this information may contain any type of personal identifiable information, including Contact Data, Financial Data, Demographic Data, and Legal Data (such as social security numbers, company information, trade secrets, inventions, and idea submissions and other sensitive information necessary to generate legal documents). We process such data only in accordance with our customers’ instructions. For such data, the customer is the "data controller" (for purposes of GDPR) or the “business” (for purposes of the CCPA) and is responsible for most aspects of the processing of the personal information. If you have any questions or concerns about how your personal information is processed in these cases, including how to exercise your rights as a data subject, please contact the customer. If we receive any rights requests concerning instances where we act as data processor, we will forward your query on to the relevant customer.
We may also collect the information of third party individuals on behalf of our customers. For example, our customers may use our service to collect counterparty information to populate a contract. Fullgap primarily uses this information for the purpose of administering and improving its services for our customers. Where the third party individual chooses to create an Fullgap account with us, however, we will process their information in accordance with this Privacy Policy.
Third-Party Websites
Fullgap may maintain links to other websites and other websites may maintain links to the Online Services. This Privacy Policy applies only to Fullgapapp.com and not to other websites accessible from Fullgap or that you use to access Fullgap, each of which may have privacy policies materially different from this Privacy Policy. If you visit other websites, Fullgap is not responsible for the privacy practices or content of those sites. It is your responsibility to review the privacy policies of non-Fullgap websites to confirm that you understand and agree with them.
Your Options
You may choose not to provide Fullgap with Personally Identifiable Information or you may turn off cookies in your browser by changing its settings. If you make these decisions, you may continue to use the Online Services and browse its pages. However, Fullgap cannot process orders without Personally Identifiable Information.
User and Authorized Contact Access to Order Information. We do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
Deleting Your Information. Â If you no longer desire our services, or if you want to remove your Personally Identifiable Information from our Site, you may terminate your account by contacting support@fullgap.co
Opting Out of Marketing. Â We send promotional emails and newsletters from time to time to users who have registered on the site and to those who have opted in to receive such emails. You can opt-out of promotional communications by following the unsubscribe instructions in any communication or by emailing us at support@fullgap.co Generally, you may not opt-out of service-related or transactional communications, which are not promotional. If you do not wish to receive service-related communications, however, you may terminate your account by contacting support@fullgap.co
3. Data Retention
At minimum, we will retain your information for as long as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Fullgap may maintain some or all of this data in its archives even after it has been removed from the Site.
We will only retain your personal information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
Unless you request that we delete certain information we retain government-issued identification documents you submit to verify your identity for 30 days, selfies you submit to verify your identity for 180 days, a copy of the headshot image from your identity document for 3 years, and other information we collect for longer. Your information may persist in copies made for ongoing fraud prevention, backup, and business continuity purposes for additional time.
4. Information Sharing and Disclosure
We do not sell your personal information as that term is traditionally defined, however, we may use cookies on our Site that are placed by a third party for the purposes of advertising or marketing to you. This may be considered a “sale” of personal information under applicable data protection laws. We may share information about you to provide the Services, for legal and investigative purposes, in connection with sweepstakes and promotions, or if we are part of a merger or acquisition. We may also share non-identifying information with third parties. You have choices as to whether we share your personal information with third parties for their own marketing purposes.
We may share aggregated Non-Identifying Information and we may otherwise disclose Non-Identifying Information (including, without limitation, Hashed Information) to third parties. We do not share your Personal Information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in to or opt-out of such sharing. We may also share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy, or in the following circumstances:
Information about Freelancers Shared with Clients, Agencies, Fullgap Payroll Vendors, and Partners of The Fullgap Foundation Initiative: We share information regarding Freelancers who have entered into a contract with a Client or who have elected to participate in Fullgap Payroll services, including information in work history, with Clients, Agencies and Fullgap Payroll vendors.
Note that if a Freelancer is suspended from the Fullgap Service, we may share that information with Clients for whom that Freelancer has worked or submitted proposals for work. We may also share information with Agencies to whom Freelancers are associated for a particular work project. If you choose to view a job post or submit a proposal for work as a Freelancer via the Service, we may share relevant information with the applicable Client(s), including, but not limited to, the information contained in your Freelancer Profile.
Information about Clients and Agencies Shared with Freelancers: If you have entered into a service contract or agreed to use Fullgap Payroll with another user, we may provide him/her with your name, company address, billing address, or tax ID or VAT number in order to complete the transaction or to facilitate the resolution of a claim or dispute. The user receiving your information is not allowed to use it for purposes unrelated to the transaction, such as to contact you for marketing purposes, unless you have expressly consented to it.
Service Providers: We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of Fullgap’s features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf.
What Happens If You Agree to Receive Information from Third Parties or Request that We Share Your Information: You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of an SNS or similar interactive feature or third party application, that we share information about you with a third party and we will typically do so under those circumstances.
Legal and Investigative Purposes: Fullgap will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of Fullgap or a third party,
(b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
(b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
Sweepstakes, Contests, and Promotions: We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration.
5. Data Security
We strive to make certain that our servers and connections incorporate the latest encryption and security devices. We have implemented physical, electronic, and managerial procedures to safeguard and secure the information we collect. Credit card and personal information are transmitted by secure servers (SSL). In the event that we mail you documents, documents are delivered to you via UPS or similar overnight delivery services, the United States Postal Service, or email. Unfortunately, no data transmission is guaranteed to be 100% secure and we therefore cannot guarantee the security of information you transmit to or from the Site, Applications, or through the use of our services, and you provide this information at your own risk. ACCORDINGLY, WE DISCLAIM LIABILITY FOR THE THEFT, LOSS, OR INTERCEPTION OF, OR UNAUTHORIZED ACCESS OR DAMAGE TO, YOUR DATA OR COMMUNICATIONS BY USING THE SITE, APPLICATIONS, AND OUR SERVICES. YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND ASSUME THESE RISK
IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED THROUGH USE OF OUR WEBSITE, APPLICATIONS, OR OTHER SERVICES, PLEASE CONTACT US IMMEDIATELY AT support@fullgap.co
6. Your Choices and Rights
You may have certain choices and rights associated with your personal information. You may request Fullgap to honor these rights by contacting us, or submitting a request here
IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED THROUGH USE OF OUR WEBSITE, APPLICATIONS, OR OTHER SERVICES, PLEASE CONTACT US IMMEDIATELY AT support@fullgap.co
EEA, Switzerland, and UK Individuals
Legal Bases for Use of Your Information. Our legal grounds for processing your information are as follows:
To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ requests in anticipation of entering into a contract with them. For example, we handle personal data on this basis to allow you to sign up for our Online Services.
To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ requests in anticipation of entering into a contract with them. For example, we handle personal data on this basis to allow you to sign up for our Online Services.
Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes: operating our business and the Online Services; providing security for our websites, products, software, or applications; marketing; receiving payments; preventing fraud; and knowing the customer to whom we are providing the Online Services.
Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations (such as our obligation to disclose data to tax authorities).
Data Subject Rights: Residents of the European Economic Area (“EEA”), Switzerland, and the UK can exercise certain data subject rights available to them under applicable data protection laws. Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. If these rights apply to you, they may permit you to request that we:
provide access to and/or a copy of certain information we hold about you
prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
update information which is out of date or incorrect delete certain information which we are holding about you
restrict the way that we process and disclose certain of your information
transfer your information to a third party provider of services revoke your consent for the processing of your information
For more information on how to exercise these rights, please contact us using the information in the “Contact Us” section below. If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
In instances where we process personal information on behalf of our customer, rights requests should be directed to the relevant customer. Any request sent directly to us that pertains to information collected on behalf of a customer will be forwarded on to that customer.
International Data Transfers. Information submitted to Fullgap will be transferred to, processed, and stored in the United States, or for certain customers, the European Union or Japan. If you post or transfer any information to or through the Online Services, you are agreeing to such information, including Personally Identifiable Information, being hosted and accessed in the United States, the European Union, and Japan. Please note that the privacy laws of the United States, the European Union, and Japan may be different from those in the place where you are a resident.
Where required, we will use appropriate safeguards for transferring data outside of the EEA, Switzerland, and the UK. This includes signing Standard Contractual Clauses that govern the transfers of such data, which may be used in conjunction with additional safeguards. For more information about these transfer mechanisms, please contact us as detailed in the “Contact us” section below.
Supplemental Privacy Notice for California Residents
This Supplemental Privacy Notice supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents. It applies to personal information we collect on or through the Online Services and through other means (such as information collected offline, in person, and over the telephone). It does not apply to personal information we collect from our employees and job applicants in their capacity as employees and job applicants. It also does not apply to personal information we process as a service provider.
Summary of Information We Collect
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” and "sensitive personal information" (as defined in the California Consumer Privacy Act (“CCPA”)).
Throughout our Privacy Policy, we describe the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the CCPA, we also have to provide you with the "categories" of personal information we collect and disclose for “business purposes” (as those terms are defined by applicable law). Those categories are identifiers (such as name, address, email address, phone number, other account information, and cookies); commercial information (such as transaction data); financial data (such as credit card and other financial account information); internet or other network or device activity (such as IP address or service usage); geolocation information (general location); inference data about you; sensory information (such as audio recordings if you call customer service); professional or employment related data; education data; insurance (including health insurance) information; medical information; physical characteristics or description; legally protected classifications (such as gender); other information that identifies or can be reasonably associated with you.The categories of sensitive personal information are account log-in, financial account information, and password or other credentials allowing access to your account.
We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Online Services; (3) affiliates; and (4) third parties such as social networks and other Fullgap users.
We or our service providers may collect and disclose the above categories of information for the purposes described in our Privacy Policy. This includes the following business or commercial purposes (as those terms are defined in applicable law):
Our or our service provider’s operational purposes; Auditing consumer interactions on our site;
Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity; Bug detection and error reporting;
Customizing content that we or our service providers display on the Online Services;
Providing the Online Services (e.g., account servicing and maintenance, order processing and fulfilment, customer service,
advertising and marketing, analytics, and communication about the Online Services);
Improving the Online Services and developing new services (e.g., by conducting research to develop new products or features);
Other uses that advance our commercial or economic interests, such as third party advertising and communicating with you about relevant offers from third party partners;
Other uses about which we notify you.
We may also use the above categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.
We describe our information disclosure practices in our Privacy Policy. We may disclose certain categories of personal information with third parties (as defined by the CCPA) for the business purposes described above. For example, we may disclose identifiers and other information that identifies or can reasonably be associated with you with counterparties to your agreements. We may disclose identifiers with our marketing partners, and we may also disclose any of the categories described above with our subsidiaries and affiliates. If you connect your account with social media services or interact with social media plugins or links on the Online Service, we may disclose identifiers, commercial information, internet or other network or device activity, or general location with those social media services.
Consumer Rights
If you are a California resident, you may have certain rights. California law may permit you to request that we:
Provide you the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for "collecting," "selling," or "sharing" your personal information; the categories of third parties to whom we disclose or "sell," or with whom we "share," personal information; and the categories of personal information we "sell."
Provide access to and/or a copy of certain information we hold about you. Delete certain information we have about you.
Correct inaccurate personal information that we maintain about you.
You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Online Services to you. If you ask us to delete it, you may no longer be able to access or use the Online Services.
If you would like to exercise any of these rights, you can submit a request at legal@fullgap.co call _________________________ or submit the Fullgap Consumer Rights Form You will be required to verify your identity before we fulfill your request. To do so, you will need to provide information to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
“Sale” of Personal Information
California residents may opt out of the "sale" of their personal information. The CCPA broadly defines "sale" in a way that may include allowing third parties to receive certain information such as cookie identifiers, IP addresses and/or browsing behavior to add to a profile about your device, browser or you. Such profiles may enable delivery of interest-based advertising by such third parties within their platform or on other sites.
Depending on how you use the Service, we may disclose the following categories of information for such interest-based advertising, which may be considered a “sale” as defined by the CCPA: identifiers (such as IP address, device identifiers, and cookies) and internet ) and and device activity. To opt out of such "sales," please submit a request to legal@fullgap.co or submit the (Fullgap Customer Rights Request Form)
"Sharing" of Personal Information
California residents may opt out of the "sharing" of their personal information. The CCPA defines "sharing" as the targeting of advertising to a consumer based on that consumer's personal information obtained from the consumer's activity across websites. We "share" information for these purposes to provide more relevant and tailored advertising to you regarding our Services. As part of this advertising, we may "share" identifiers (such as IP address, device identifiers, and cookies) and internet and device activity with advertising platforms and advertising networks. To opt out of such "sharing," please submit a request to legal@Fullgap.co submit the (Fullgap Customer Rights Request Form)
Global Privacy Control
Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control. Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them. For more information on how to use the Global Privacy Control, see www.globalprivacycontrol.org.
Children Under 16
We do not knowingly "sell" or "share" the personal information of children under 16.
Sensitive Personal Information
The CCPA also allows you to limit the use or disclosure of your "sensitive personal information" (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.
Retention of Your Personal Information Please see the "Data Retention" section above. California Shine the Light
We do not disclose personal information to third parties for their direct marketing purposes.
Children’s Privacy
The Online Services are not directed to children under the age of 13. We do not knowingly collect personal information (as that term is defined in the Children’s Online Privacy Protection Act (COPPA)) from children under 13. If we discover that an individual under 13 has provided us with personal information, we will delete the personal information to the extent required by COPPA.
We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible.
We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible.
7. Cross-Border Data Transfers
Because we are a U.S. company, we process and store your information in the United States and our service providers may process and store it elsewhere.
Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.
Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.
8. Links to Other Sites
Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.
9. Changes to This Policy
We may change this Privacy Policy. If we make substantial changes, we will provide notice.
This Privacy Policy is effective as of the date stated at the top of this page. Fullgap may update this Privacy Policy at any time and any changes will be effective upon posting. By accessing or using the Service after we notify you of such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.
We may also update this privacy policy to reflect changes to our information practices. If we make any material changes a notice may be posted on this page along with the updated Privacy Policy prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
10. Contact Us
If you have any questions or concerns regarding our Privacy Policy, please contact us at legal@fullgap.co