1.

The Types of Personal Information We Collect

For purposes of this Policy, “Personal Information” generally means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household, such as name, email address or phone number, account number or account information. 
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In order to access the Website, or when you otherwise interact with us via phone, email, mail, LSI will collect Personal Information. For example, you may provide your name, company name, address, institution, city, state, zip/postal code, country, email address, phone number, fax number, username, password, and any other information that you choose to provide to us in your subject line and message. 
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If you choose to not provide us with this or other personal information, you might not be able to access to certain information and services on the Website.
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We may also collect information about you via automated means. For example, when you visit the Website, we may collect your IP address, your browser type, your operating system, the pages you view on the Website.  We collect this information using cookies and other technical means. Cookies are small files that a webpage sends to your computer or device while you are viewing the webpage.  A more detailed description of cookies is described below.
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The Website may also use other technical methods to track visitor usage, including web beacons. “Web beacons” are small pieces of data that are embedded in images on the pages of a webpage. We use these technical methods to analyze the traffic patterns on the Website, such as the frequency with which our users visit various parts of the Website. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send users of the Website to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails.

2.

STATE-SPECIFIC INFORMATION

Certain states, including California, to the extent any of these state laws apply, require us to provide additional disclosures with respect to our collection, use, and disclosure of personal data. This information in this section is provided as a supplement to the rest of the information provided in this Policy. Please read the entire Policy for a full description of our privacy practices.

We do not sell or share Personal Information for cross context behavioral advertising nor have we done so in the past twelve months.

The Personal Information we collect includes information within the below categories of data. Note that the “category of data” column listed below refers to the category of personal data as defined under California law and represents the categories of personal information that we have collected, and how it has been shared, over the past 12 months, if applicable. Inclusion of a category in the list below indicates only that we may collect some information within that category. We do not necessarily collect all information listed in a particular category, nor do we necessarily collect all categories of information for all individuals. While the categories are defined under California law, the disclosures below also apply to residents of other states as well.

We may disclose personal information in each of the below categories with our affiliates and service providers, as well as with government entities as necessary, for our business purposes. However, we have not disclosed any personal data with our affiliates or third parties within the last 12 months. We have not and do not necessarily share all information listed in a category.

Category of Data

Source

Purpose of Collecting and Processing Information

Personal Identifiers

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

We collect information in this category:

  • directly from you or your interactions with our  Website; and/or
  • from records we have about you in the course of providing services or products.

A subset of this data is processed in connection with our operational functions, including:

  • to provide, maintain and improve our product services;
  • to monitor and analyze trends, usage and activity related to our products;
  • to detect, investigate and prevent fraudulent transactions and other illegal activities as well as protect the rights and property of us and others;

We also use this information for marketing purposes.

Information About You

Information that   identifies, relates to, describes, or is capable of being associated with, a   particular individual, including, but not limited to, your name, signature,   Social Security number, physical characteristics or description, address,   telephone number, passport number, driver’s license or state identification   card number, insurance policy number, education, employment, employment   history, bank account number, credit card number, debit card number, or any   other financial information, medical information, or health insurance   information.

We collect information in this category:

  • directly from you or your interactions with our Website; and/or
  • from records we have about you in the course of providing services or products
  • from third-party marketing providers

A subset of this data is processed in connection with our operational functions, including:

  • to provide, maintain and improve our product services;
  • to monitor and analyze trends, usage and activity related to our products;
  • to detect, investigate and prevent fraudulent transactions and other illegal activities as well as protect the rights and property of us and others;

We also use this information for marketing purposes.

Internet or other electronic network activity information

Data that relates to a consumer’s physical location.

We collect information in this category directly from you or your interactions with our Website.

A subset of this data is processed in connection with our operational functions, including:

  • to provide, maintain and improve our product services;
  • to monitor and analyze trends, usage and activity related to our products;
  • to detect, investigate and prevent fraudulent transactions and other illegal activities as well as protect the rights and property of us and others;
  • to defend our legal rights, as needed; and,
  • for sales related purposes.

We also use this information to advertise products/services that might be of interest to you.

Geolocation data

browsing history, search history, and information regarding a   consumer’s interaction with an Internet Web site, application, or   advertisement.

We collect information in this category directly from you or your interactions with our Website.

A subset of this data is processed in connection with our operational functions, including

  • to provide, maintain and improve our product services;
  • to monitor and analyze trends, usage and activity related to our products;
  • to detect, investigate and prevent fraudulent transactions and other illegal activities as well as protect the rights and property of us and others;

We also use this information for marketing purposes.

Sensory information

audio, electronic, visual, thermal, olfactory or similar information, including voice signatures and recorded calls

We collect information in this category directly from you or your interactions with our Website.

A subset of this data (especially calls to us, which may be recorded) is processed in connection with our operational functions, including

  • to provide, maintain and improve our services;
  • to detect, investigate and prevent fraudulent transactions and other illegal activities as well as protect the rights and property of us and others;

We also use this information for marketing purposes.

In addition to the categories of personal data above, we may collect the following categories of sensitive personal data. We only process your sensitive personal data for processes considered necessary under California law.

Category of Sensitive Personal Data

Source of Sensitive Personal Data

Purpose of Processing

Social security number, driver’s license, state identification card, or passport number.

This information is collected directly from you or our service providers.

This information is necessary to administer your relationship with us, including meeting our legal obligations, and providing you with benefits and services, as applicable.

Log-in credentials allowing access to an account.

This information is collected directly from you or our service providers.

This information is necessary to administer your relationship with us, including meeting our legal obligations, and providing you with benefits and services, as applicable.

It is also processed in order to help detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and for compliance management.

Retention of Personal Information
We consider the following criteria when determining how long a particular record will be retained, including any personal information contained in that record:
  • directly from you or your interactions with our Website; and/or
  • from records we have about you in the course of providing services or products
  • from third-party marketing providers
The same personal information about you may be included in more than one record and used for more than one purpose, each of which may be subject to different retention periods based on the factors listed above.
Your Rights and Choices Regarding Personal Information
Depending on your state of residency, and the type of data collected, you may have rights with respect to Personal Information about you. We may, at our discretion, choose to extend these rights to you even if we are not required to under applicable law.
Right to access/know – You may be entitled to request that we disclose to you the personal information we have collected about you, including the categories of personal information, the categories of sources from which we collected the information, the business or commercial purposes of collecting the information, the categories of third parties with whom we have shared the information, and the categories of personal information that we have shared with third parties for a business purpose. In some instances, you may have the right to receive the information about you we have collected in a portable and readily usable format.
Right to data portability – Subject to certain conditions, you may be entitled to request that we disclose to you the personal information we have collected about you in a portable, and to the extent feasible, usable format that allows you to transmit the data to another entity without hindrance.
Right to correct – Subject to certain conditions, you may request that we correct any mistakes in Personal Information about you or update your preferences; however, we may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect. We may delete the contested Personal Information as an alternative to correcting the information if the deletion of the Personal Information does not negatively impact you, or you consent to the deletion.
Right to deletion – Subject to certain conditions, you may be entitled to request that we delete personal information about you. Before deleting information, we must be able to verify your identity. We will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you if your personal information is a necessary element of the contract between us.
Right to non-discrimination – You may have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.
Right to opt-out of the sale or sharing of personal information – We currently do not sell or share Personal Information for purposes of cross contextual behavioral/targeted advertising.
Right to limit use and disclosure of sensitive personal information – We only process sensitive personal information for purposes considered necessary under applicable law, and therefore do not offer this option.
Right to opt out of receiving our marketing emails - To stop receiving our promotional emails, follow the instructions in any promotional message you get from us. If you object to our use of your information for direct marketing purposes, please email us at [info@lafayettesquare.com]. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions.
Right to limit how we use cookies and tracking tools – We typically only use essential cookies.  However, if we choose to employ third party cookies for analytical or marketing purposes, we will prompt you to select your choices for non-essential cookies when you first visit our site.  We will also periodically confirm your choices, which you can modify.  More information on cookies and related technologies is below, including how we also have tools in place to better detect and honor your requests made using the Global Privacy Control (“GPS”) signal. More information on cookies and related technologies is below.
We do not discriminate against you if you choose to exercise any of these rights. If we deny your request, you may also have the right to appeal that decision. Instructions on how to appeal any denial will be included in the notice of denial.

Depending on your residency, these rights may not apply to pseudonymous data if the information necessary to identify the consumer is kept separately and is subject to controls that prevent access to the information. Pseudonymous data is personal data that can no longer be attributed to a specific individual without the use of additional information, if the additional information is kept separately and is subject measures to ensure that personal data is not attributed to the specific individual.

Data solely retained for data backup or archive purposes is principally excluded from these rights until it is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.

Please note that under applicable privacy law, we are only obligated to respond to personal information requests from the same consumer up to two times in a 12-month period. In addition, under applicable privacy law, and for the protection of your personal information, we may be limited in what personal information we can disclose.
Additional Information for residents of Colorado and California (to the extent those laws apply): We will maintain all of your Consumer Data Rights requests for at least 2 years. This information will not be used for any other purpose except to review compliance processes; it will not be shared except as necessary to comply with a legal obligation. For residents of Colorado, to the extent Colorado law applies, sensitive data which we no longer have consent to process will be deleted or rendered permanently anonymized or inaccessible within a reasonable period of time after withdrawal of consent.

You may also be entitled to request in writing a list of the types of personal information that we have disclosed to a third party for their direct marketing purposes during the preceding year and to whom that information was disclosed.
Retention of Personal Information
We consider the following criteria when determining how long a particular record will be retained, including any personal information contained in that record:
  • directly from you or your interactions with our Website; and/or
  • from records we have about you in the course of providing services or products
  • from third-party marketing providers
The same personal information about you may be included in more than one record and used for more than one purpose, each of which may be subject to different retention periods based on the factors listed above.
Submitting Privacy Requests
You can exercise your privacy rights by submitting requests to us and by taking other steps that will limit how information about you is collected, used, and shared.

If your state grants the consumer rights referenced above, to the extent applicable, you may exercise your privacy rights by submitting a personal information request by downloading the Personal Data Request Form by clicking on this link, completing the form and emailing the completed form to [info@lafayettesquare.com] or by calling us at 786-598-2089.

We must verify your identity before fulfilling your personal information request. To verify your identity, we match information from you with information we have on file, including, to the extent applicable, your name, date of birth, contact information, or your account information. Information collected for purposes of verifying your request will only be used for verification and to respond to your Personal Information request. If you maintain an account with us, we may require you to log in to that account as part of submitting your request.

If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. We are not obligated to collect additional information in order to enable you to verify your identity. For deletion requests, you will be required to submit a verifiable request for deletion and then confirm separately that you want personal information about you deleted.

If you would like to appoint an authorized agent to make a request on your behalf, we require you to verify your identity with us directly before we provide any requested information to your approved agent. Alternatively, your authorized agent may provide evidence of having power of attorney or acting as a conservator for you. Note that we may require you to verify your identity with us directly before we provide any requested information to your authorized agent unless your authorized agent has power of attorney or acts as a conservator, in which case we will not contact you directly. We may also request that any authorized agents verify their identity and may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf. There may be circumstances where we will not be able to honor your request. We will notify you if we are unable to honor your request. Based on your residency, you may have the right to appeal our decision with regard to your request by using the “Contact Us” details provided at the end of this Policy.

3.

OTHER WEBSITES

The Website may contain links to websites operated by third parties. Should you choose to visit any of these third-party sites, you should review those sites’ privacy policies to ensure you understand and are comfortable with their practices concerning your information. We disclaim any responsibility for the privacy policies and information practices of any third-party website (whether such site is linked on). These links are provided to you for convenience purposes only, and you access them at your own risk.

We may link the information that we collect automatically with the information you provide us. And we may combine the information we collect online with information we collect offline or that is collected by third parties.

4.

NEWSLETTERS

Where you sign up to receive email notifications from us, we will send the communications that you have requested (including information about corporate events, press releases, presentations and company documents). You can opt-out of receiving such communications at any time by contacting us or by clicking “unsubscribe” in the email.

5.

COOKIES AND RELATED TECHNOLOGIES

Gathering and Use of Technical Usage and Personal Information 
Like most website operators, we gather technical usage information that web browsers, depending on their settings, make available. As we want to be responsive to you and to ensure the proper functioning of our products and organization, we may use the information collected to: 
  • ensure content from the Website is presented in the most effective manner for you and your device; 
  • allow you to navigate or browse through the Website quickly and efficiently; 
  • monitor and analyze trends, usage and activity in connection with the Website and services to improve the Website; 
  • administer the Website and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis; 
  • protect our rights, your rights and the rights of others;
  • investigate and respond to any complaints,
  • comply with legal obligations;
  • verify the user’s eligibility to access any restricted areas of the Site; and 
  • provide users with customer support. 
We may use information that does not reasonably identify you for any purpose.  For example, for research purposes we may prepare aggregated reports about how visitors to the Website tend to interact with the Website.
What are cookies? 
A cookie is a piece of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website using that browser. 

When you access the Website, we place cookies on your computer. A cookie allows us to determine that a visit has occurred within our site, as well as which pages were viewed. Through cookies, we may collect your Internet Protocol (“IP”) address, operating system and browser type, and the locations of the web pages you view right before arriving at, while navigating and immediately after leaving the Website. 

You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/. 
Do Not Track?
Various third parties are developing ways for consumers to express their choice about the collection of the individual consumer’s online activities over time and across third-party websites or online services. We typically only use essential cookies.  However, if we choose to employ third-party cookies for analytical or marketing purposes, we will prompt you to select your choices for non-essential cookies when you first visit our site.  We will also periodically confirm your choices, which you can modify. In addition, we have tools in place to better detect and honor requests made using GPC signal as requests to opt out of the sharing of Personal Information to the extent required by applicable law and to the extent we employ third party cookies. We endeavor to honor these requests with respect to any Personal Information connected to the GPC opt out request based on the information made available by GPC. Note that we may not be able to tie a GPC request to all Personal Information we have about you.

6.

LAFAYETTE SQUARE INSTITUTE’S SHARING OF INFORMATION WITH THIRD PARTY PROVIDERS

Service Providers
Sometimes we engage companies that act on our behalf in connection with the operation of the Website. For example, such companies may deliver products or services, improve the functionality of the Website, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you. Lafayette Square Institute endeavors to require our service providers by contract to collect, store, and use information about you only on our behalf, and in accordance with the provisions of this Privacy Policy.
Analytics Providers
We may engage third-party analytics providers to help us understand how users engage with the Website. These third-parties may use cookies and similar technologies to collect information about your use of the Website.
Disclosure of Personal Information to Selected Third Parties
We may share your information with selected recipients. These categories of recipients include: 
  • Where you have asked to be notified of corporate events we may use email management service companies.
And/or:
  • Service providers to perform certain services on our behalf such as: 
  • to process and store data, including your Personal Information; 
  • to track, analyze, and modify the Website;
  • for marketing, advertising, and distribution; 
  • for co-sponsoring or co-branding certain services, promotions or events;
  • to assist us in providing you with customer support; and
  • to support our IT and security efforts. 
We do not sell, transfer or use any Personal Information gathered via the Website with third parties. 
Other Sharing Practices
We may share your information with our affiliates and subsidiaries, and may also provide information to our attorneys, banks, auditors, and other service providers.

We may disclose information as:
    • required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency’s request;
    • to help to protect our rights or enforce our Terms of Use;
    • to support our detection, prevention, or response to fraud or intellectual property infringement;
    • to help protect your safety or security, including the safety and security of property that belongs to you; and
    We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.

    7.

    SECURITY MEASURES WE TAKE TO SAFEGUARD INFORMATION

    The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive.

    From time to time, we review and consider updates for our security procedures. Please be aware though that, despite our ongoing efforts, no security measures are perfect or impenetrable. This means that we cannot ensure or warrant the security of any information we collect about you, and therefore your use of the Website is at your own risk. 

    8.

    CHILDREN’S INFORMATION

    The Website is intended for use by those  18 years or older. We do not knowingly solicit or collect personal information from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted Personal Information through the Website, we will take reasonable measures to delete all such information and shall only use such information where necessary to protect the safety of the child or others as required by law.

    9.

    HOW CAN YOU CONTACT US?

    If you would like to contact us about this policy or the Website, please reach out to us via the Contact page. You can also write to our privacy lead at [info@lafayettesquare.com].