Privacy Policy

1. INFORMATION WE COLLECT

We collect different types of information about our customers and Website visitors. In the past 12 months we may have collected:

• Contact Information: We may collect contact information, which includes personal information like name, email address, phone number, and physical address.
• Location Information: We may collect your location data in connection with your use of our Website, including geolocation, beacon based location, and GPS location. Our collection may depend on your device’s settings for location services.
• Device Information: When you visit our Website, interact with our Social Media Pages or online ads, or open our emails, we learn about your browser type and version, type of computer or mobile device, browser language, IP address, and other technical information about your device.
• Demographic Information: We may have access to demographic details about our Website users such as birth year, gender, zip code, and other similar details.
• Payment Details: We may collect your payment information, such as credit card number and expiration date, in connection with an order or your account.
• Call, Text, Mail, and Email Records: If you call, text, mail, or email our customer service agents, we may keep records of those conversations. Our calls with you may be monitored and recorded for quality purposes.
• Website and App Interactions: We collect information about your interactions with our Website or App including pages visited, interest in content, access times, search activity, the pages that you view, and other surfing behavior.
• Submitted Content: We collect any content you submit to our Website, App, Social Media Pages, or to us in person including photos, videos, posts, or review contributions. This information could include personal information, depending on what information you provide.
• Profile Information: We may have access to profile details about consumers such as your preferences and Website behavior.
• User Contacts: We collect information you submit to us or choose to share with us from your personal device when you invite others to join or become your friend on ISSA Social Media platforms.

2. HOW WE COLLECT INFORMATION

We may collect the information described above directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:

• You: We collect information directly from you, whenever you: make a purchase; visit our Website; contact us with questions or comments; upload content; enter our contests, sweepstakes, or promotions or contests or sweepstakes we are affiliated with; create an account; update your account profile; write a review; or use or like our Social Media Pages.
• Your Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Website or interact with our Social Media Pages or online advertising.
• Third Parties: We work with third parties who provide services to us such as payment processors, analytics, research, or advertising companies. Your information may be collected and processed independently in accordance with the third parties’ own privacy notices. These third parties may share information they have collected with us.
• Social Media Platforms: Social media platforms share information with us. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings.

Cookies: We use cookies, web beacons, tags, scripts, pixels, and other similar technologies to automatically collect information when you visit our Website. We also contract with third party advertising or analytics companies to serve you online ads on other websites. These companies use cookies or similar technologies to collect information about your interactions with our Website and interactions with other websites. These advertising companies may use and share the information gathered to deliver ads more tailored to your interests. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked with other information we collect about you. For a more thorough explanation of what cookies are and how they operate, please visit aboutcookies.org or allaboutcookies.org.

3. HOW WE USE THE INFORMATION WE COLLECT

We may use the information we collect for the following business purposes:

• Fulfilling Your Requests: Fulfilling your orders and other requests, including, but not limited to, processing your transactions and populating forms for future transactions.
• Advertising: Presenting advertising online, by email, or through other communication channels, including through partnerships with social media platforms and internet search engines.
• Understanding Our Customers: Analyzing your activity with us (including your interactions with our Website, Social Media Pages, App, and emails or other forms of communication), monitoring the effectiveness of our advertising and communications, and analyzing trends and statistics.
• Personalization: Using your preferences and other collected information to personalize our relationship with you, including presenting customized communication, advertising and experiences on our Website, App, emails, and ads on social media.
• Communications: Communicating with you about our services, responding to your inquiries, and providing you certain administrative, transactional, or legal messages.
• Promotions: Running contests, sweepstakes, or other promotions.
• Customer Experience: Serving content on our Website, App, and Social Media Pages, developing our services, and constantly improving our customers’ experience, including but not limited to, troubleshooting customer service issues and improving Website functionality.
• Security: Protecting ISSA and our customers from fraud, security threats, and other illegal or harmful activity.
• Legal Obligations: Complying with legal and regulatory requirements and responding to requests from courts or other government bodies.

4. SMS / MMS Text Message Marketing Program Privacy Policy

We will only use the information you provide through our SMS marketing program to transmit your mobile messages and respond to you, if necessary. This includes but is not limited to sharing information with platform providers, phone companies (carriers), and other vendors who assist us in the delivery of mobile messages. We use this information to send you text notifications, text marketing offers, and transactional texts. Opt-in data and consent for text messaging will not be shared with any third parties except for messaging partners for the purpose of enabling and operating our text message program.

Our website uses cookies to keep track of items you put in your shopping cart, including when you have abandoned your checkout. This information is used to determine when to send cart reminder messages via SMS.

We do not sell, rent, loan, trade, lease, or otherwise transfer for profit any phone numbers or customer information collected through the SMS marketing program to any third party.

We reserve the right to disclose any information as necessary to satisfy any law, regulation, or governmental request, to avoid liability, or to protect our rights or property. When you complete forms online or otherwise provide us with information in connection with the SMS marketing program, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If we believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the SMS program for an ulterior purpose, we may refuse you access to the program and pursue any appropriate legal remedies.

• Messaging Terms and Conditions: You agree to receive informational messages (appointment reminders, account notifications, etc.) from ISSA. Message frequency varies. Message and data rates may apply. For help, reply HELP or email us at support@issaonline.com. You can opt out at any time by replying STOP.
• Mobile opt in, SMS consent or numbers for the purpose of SMS are not shared with any third parties or affiliates.

5. HOW YOUR INFORMATION IS SHARED WITH SERVICE PROVIDERS AND THIRD PARTIES AND FOR WHAT PURPOSES

We may share personal information with third parties for certain purposes. For example, we share personal information with:

• Service Providers: We partner with third parties to assist with many aspects of our business, including providing you services, fulfilling your orders, advertising, analyzing your interests and activity on our Website and Social Media Pages, and helping us communicate with you. These third parties may provide services related to any of the purposes described in HOW WE USE THE INFORMATION WE COLLECT, and we may share with them any types of information described in INFORMATION WE COLLECT. We may also receive information collected by these third parties and combine it with the information we have collected. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices.
• Marketing Providers: We partner with third parties to assist with the advertising and marketing of our business. We may share with them the types of information described in INFORMATION WE COLLECT.
• Content Partners: We allow third party partners to use and display some of the public content available through the Website, such as your photos, reviews, and other information.
• Other Third Parties: We will disclose information about you, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law or to protect our Website users, our Website, or the public.
• Google Tag Manager (GTM) and your consent: We send cookieless, PII-free data to Google. Our consent manager communicates consent settings to GTM and GTM then conditions marketing pixels to fire based on user opt-in settings. By default, Google Analytics and Google Ad tags fire with special settings that do not rely on cookies and strip off any PII. Once opt in is received, Google Analytics and Google Ad tags begin collecting PII and GTM would fire any other marketing pixels. The IP address is exposed to GTM but is discarded or changed (Safari browsers change the IP address).
• Referral Partners: If you make a purchase through a co-branded partner page or partner discount code, we may share your contact information with that referring partner.

The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

If you are a California resident, you can learn more about your privacy rights below in the California Privacy Rights section or on our Do Not Sell My Personal Information page.

6. YOUR PRIVACY CHOICES

You can control the information we collect and use in the following ways:

• Location Information: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Website from accessing your location information. Note that some services may not be available if you disable location-based services.
• Emails: You can unsubscribe from emails and other electronic notifications by a link included in every such communication.
• Online Account: You can keep your contact information and payment methods accurate and up to date by logging into your account on our Website. If you wish to cancel your account, email us at privacypolicy@issaonline.com.
• Account Settings: When you sign up for an account or use certain features, you are opting to receive messages from other users, businesses, and from ISSA. You can manage some of your messaging preferences through your account settings, but note that you cannot opt out of receiving certain administrative, transactional, or legal messages from ISSA.
• Social Media: This Privacy Policy does not cover the privacy and security practices of social media platforms on which ISSA has Social Media Pages. Please review the terms, policies, and settings of those social media platforms if you have questions about how they collect and use your data.
• Online Advertising: For information about opting out of third party advertising, visit: https://optout.networkadvertising.org/ or https://digitaladvertisingalliance.org/. You will leave this Website for a separately managed online site where you can specify your preferences. We may use more than one third party company for placing this advertising, which would require you to opt out of each company.

7. CHILDREN’S PRIVACY

Our Website, App, and Social Media pages are intended for adults. No one under the age of 16 should share any personal information with us, including by creating an account or making a purchase from our Website. We do not knowingly collect personal information of children under the age of 16. To request the deletion of personal information relating to a child under the age of 16, please complete this form.

8. DATA RETENTION AND ACCOUNT TERMINATION

You can close your account by contacting us. We will remove certain public posts from view and/or dissociate them from your account profile, but we may retain information about you for the purposes authorized under this Privacy Policy unless prohibited by law. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Website or to comply with legal obligations.

9. SECURITY

We take steps to help protect the confidentiality and security of your personal information. Although we use measures to protect your personal information, in general, information transmitted through the Internet may not be completely secure. Accordingly, we cannot guarantee the security of information provided over the Internet. Your transmissions are, therefore, at your own risk. You can protect your information by selecting strong, unique passwords for the Website and any associated email addresses. If you have concerns about the security of your account, or wish to alert us of any potential vulnerabilities, please contact us at privacypolicy@issaonline.com.

10. SUPPORTED WEB BROWSERS AND DO NOT TRACK SIGNALS

We recommend that you use the latest web browser versions to optimize your experience. Older web browser versions may not be able to access or utilize all pages on our Website as intended. We may not be able to receive or honor web browser “Do Not Track” signals and our Website may continue to collect information in the manner described within this Privacy Policy.

11. WEBSITE TERMS AND CONDITIONS

This privacy policy constitutes an integrated part of ISSA’s Terms & Conditions.

12. UPDATE

We reserve the right to modify, alter or otherwise update this Privacy Policy at any time, so we encourage you to review this policy from time to time. Changes to this Privacy Policy are effective at the time they are posted and your continued use of our Website after posting will constitute acceptance of, and agreement to be bound by, those changes. If we make any material changes to our privacy practices, we will update this Privacy Policy and change the effective date at the top of this page.

13. CONTACT INFORMATION

Please send your privacy-related questions, comments, and concerns to us via email at privacypolicy@issaonline.com or by calling us at (805) 301-6034.

14. ADDITIONAL DISCLOSURES FOR SPECIFIC REGIONS

Some regions provide additional rights by law:

• California Privacy Rights
• Colorado Privacy Rights
• Connecticut Privacy Rights
• Virginia Privacy Rights
• European Economic Area, Switzerland and United Kingdom Privacy Rights
• Residents of Brazil Privacy Rights

If your Personal Information is subject to these regional laws, you may have certain privacy rights with regard to that information. Please view these rights in each regional section below.

How to Submit a Request

If you wish to exercise your right to access your Personal Information, to opt out of the sale of your Personal Information, or to request deletion of your Personal Information, please submit your request through this webform or call (805) 301-6034. Please help us by providing your full name, email, and home address, and clearly indicate which right you wish to exercise. The information collected through this process will be used only for responding to your request.

We are required to provide you with access to your Personal Information or delete your Personal Information only in response to a verifiable consumer request. We will compare the information you provide to us to any information we may have in our possession in order to verify your request. We may also contact you to request additional information in relation to your request. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Information is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used for verification purposes only.

For more information on your right to opt-out of the sale of your Personal Information, please visit our Do Not Sell My Personal Information page.

Requests Made Through Agents

Please note that you may authorize an agent to exercise any of these rights on your behalf. If you use an agent, we will take measures to verify your agent’s authorization similar to the verification described above for fulfilling any access or deletion requests. We may require more information to ensure proper verification of your agent’s identity and authorization.

Categories of Personal Information Sold

In the previous 12 months, ISSA may have sold (as defined under the CPRA) the following categories of Personal Information: device information, location information, website and app interactions, transactional data, social media usage, submitted content, and profile information. ISSA frequently works with the following categories of third parties: Marketing Providers and Content Partners.

Other Privacy Rights

You may request to opt-out from future sharing or selling of your personal information to third parties. If you would like to exercise your rights, please visit our data rights portal.

Categories of Personal Information Disclosed for a Business Purpose

We share personal information about you with service providers and third parties for business purposes, such as operational purposes and other purposes related to providing you with the products and services you seek from us. For more information about the business purposes for which we disclose personal information, please see HOW INFORMATION IS SHARED WITH SERVICE PROVIDERS AND THIRD PARTIES AND FOR WHAT PURPOSES, above, and please see INFORMATION WE COLLECT, above, for what types of information may be shared.

To make this request, please complete this webform.

CALIFORNIA PRIVACY RIGHTS

As a resident of California, you have rights under the California Privacy Rights Act, California Civil Code § et seq., (with any implementing regulations and as may be amended from time to time, “CPRA”) relevant to your Personal Information (as defined under the CPRA), as well as other laws. The rights described herein are subject to exemptions under the CPRA and other limitations under applicable law.

California Consumer Rights Under the CPRA: If your Personal Information is subject to the CPRA, you may have certain privacy rights with regard to that information. You may have the right to:

• Request that we provide you access to the following no more than twice in a 12-month period:
  • the categories and specific pieces of Personal Information that we have collected about you;
  • the categories of sources from which the Personal Information is collected;
  • the business or commercial purpose for collecting or sharing your Personal Information;
  • the categories of third parties with whom we share your Personal Information; and
  • the categories of Personal Information that are sold (as defined under the CRPA) and the categories of third parties to whom the Personal Information was sold.
• Request that we delete your Personal Information, subject to exceptions under the CRPA or other applicable law; and
• Request that we not “sell” or “share” your Personal Information by opting out of the sale or sharing of your Personal Information.
• Request that we correct inaccurate or outdated data under the CRPA.
• Request that we do not use your Personal Information in automated decision-making, including profiling.

California residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the CRPA, as described in this section. We will not discriminate against you because you have exercised any of your rights under the CRPA.

Additional California Privacy Rights

California residents may also ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. California residents may make one request per calendar year.

California Employees, Contractors, Job Applicants

Employees and Contractors: If you are an employee or contractor of ISSA, please contact the People Operations team for our privacy policy for employees and contractors. This Privacy Policy is separate from our internal privacy policy for employees and contractors.

Job Applicants: In connection with a job application or inquiry, you may provide us with data about yourself, including your educational background or résumé and other information, including your ethnicity where required or permitted by law. We may share this information with our parent corporations and their affiliates for the purpose of employment consideration. We may keep the information for future consideration unless you direct us not to do so.

COLORADO PRIVACY RIGHTS

As a resident of Colorado, you have rights under the Colorado Protection Act (CPA) (with any implementing regulations and as may be amended from time to time, “CPA”) relevant to your Personal Information (as defined under the CPA), as well as other laws. The rights described herein are subject to exemptions under the CPA and other limitations under applicable law.

Colorado Protection Act (CPA): If your Personal Information is subject to the CPA, you may have certain privacy rights with regard to that information. You may have the right to:

• Request that we provide you access to the following no more than twice in a 12-month period:
  • the categories and specific pieces of Personal Information that we have collected about you;
  • the categories of sources from which the Personal Information is collected;
  • the categories of third parties with whom we share your Personal Information; and
  • the categories of Personal Information that are sold (as defined under the CPA) and the categories of third parties to whom the Personal Information was sold.
• Request that we delete your Personal Information, subject to exceptions under the CPA or other applicable law; and
• Request that we not “sell” or “share” your Personal Information by opting out of the sale or sharing of your Personal Information.
• Request that we correct inaccurate or outdated data under the CPA.
• Request that we do not use your Personal Information in automateddecision-making, including profiling.

Colorado residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the CPA, as described in this section. We will not discriminate against you because you have exercised any of your rights under the CPA.

CONNECTICUT PRIVACY RIGHTS

As a resident of Connecticut, you have rights under the Connecticut Data Privacy Act (CTDPA) (with any implementing regulations and as may be amended from time to time, “CTDPA”) relevant to your Personal Information (as defined under the CTDPA), as well as other laws. The rights described herein are subject to exemptions under the CTDPA and other limitations under applicable law.

Connecticut Data Privacy Act (CTDPA): If your Personal Information is subject to the CPA, you may have certain privacy rights with regard to that information. You may have the right to:

• Request that we provide you access to the following no more than twice in a 12-month period:
  • the categories and specific pieces of Personal Information that we have collected about you;
  • the categories of sources from which the Personal Information is collected;
  • the categories of third parties with whom we share your Personal Information; and
  • the categories of Personal Information that are sold (as defined under the CPA) and the categories of third parties to whom the Personal Information was sold.
• Request that we delete your Personal Information, subject to exceptions under the CTDPA or other applicable law; and
• Request that we not “sell” or “share” your Personal Information by opting out of the sale or sharing of your Personal Information.
• Request that we correct inaccurate or outdated data under the CTDPA.
• Request that we do not use your Personal Information in automateddecision-making, including profiling.

Connecticut residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the CTDPA, as described in this section. We will not discriminate against you because you have exercised any of your rights under the CTDPA.

VIRGINIA PRIVACY RIGHTS

As a resident of Virginia, you have rights under the Virginia Consumer Data Protection Act (with any implementing regulations and as may be amended from time to time, “VCDPA”) relevant to your Personal Information (as defined under the VCDPA), as well as other laws. The rights described herein are subject to exemptions under the VCDPA and other limitations under applicable law.

Virginia Consumer Data Protection Act (VCDPA): If your Personal Information is subject to the VCDPA, you may have certain privacy rights with regard to that information. You may have the right to:

• Request that we provide you access to the following no more than twice in a 12-month period:
  • the categories and specific pieces of Personal Information that we have collected about you;
  • the categories of sources from which the Personal Information is collected;
  • the categories of third parties with whom we share your Personal Information; and
  • the categories of Personal Information that are sold (as defined under the VCDPA) and the categories of third parties to whom the Personal Information was sold.
• Request that we delete your Personal Information, subject to exceptions under the VCDPA or other applicable law; and
• Request that we not “sell” or “share [JS2]” your Personal Information by opting out of the sale or sharing of your Personal Information.
• Request that we correct inaccurate or outdated data under the VCDPA.
• Request that we do not use your Personal Information in automateddecision-making, including profiling.

Virginia residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the VCDPA, as described in this section. We will not discriminate against you because you have exercised any of your rights under the VCDPA.

THE EUROPEAN ECONOMIC AREA, SWITZERLAND AND UNITED KINGDOM PRIVACY RIGHTS

GDPR Statement

The General Data Protection Regulation (GDPR) is a European Union regulation which protects the rights of data subjects in the European Economic Area (EEA), with respect to the processing of their “personal data,” as such term is defined in the GDPR.

Compliance

The Websites are designed to meet the principles of the GDPR. Here are some of the actions we have taken to ensure our compliance with GDPR:

• We limit the personal data we collect;
• We have established a legal basis for the processing of that data;
• We only retain personal data for a limited time period, after which, the data is deleted

What Personal Data is Collected and How it is Collected

Please see the ISSA Privacy Policy, which describes the categories of information we process, the purposes for which we process personal data, and how we collect that personal data.

How Long is Personal Data Retained

We will keep personal information provided by customers for up to three months after the end of our business relationship and subject to our Terms and Conditions.

If you contact us directly using the contact information provided on the Websites, we will retain your contact information for a period of up to three months after we respond to your inquiry. After that, the communications will be deleted from our system, unless we are required by law to retain it longer.

Children's Privacy

Our Website, App, and Social Media pages are intended for adults. No one under the age of 16 should share any personal information with us, including by creating an account or making a purchase from our Website. We do not knowingly collect personal information of children under the age of 16. To request the deletion of personal information relating to a child under the age of 16, please complete this form.

Legal Basis for Processing

If you are a user of the Websites located in the EEA, we rely on legitimate interest as the legal basis for processing the personal data we collect via the website and platform.

Controller and Processor

ISSA is both Controller and Processor of personal data covered by the Privacy Policy for purposes of European data protection legislation.

Subprocessors

In connection with the operation of our website, ISSA may engage third parties (each a “Subprocessor”) to process your personal data. As a condition of permitting a Subprocessor to process your personal data, ISSA will enter into a written agreement with each Subprocessor containing data protection obligations at least as protective as the technical and organizational measures ISSA has put into place to protect your personal data from accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access.

We use the following Subprocessors to operate our website and provide our services:

International Data Transfers

If you are located within the EEA when you visit the Website, we may transfer your personal data outside of the EEA. When we do, we will ensure that an adequate level of protection is provided for the information by using industry-standard encryption at rest and in transit.

How to Contact Us

If you have any questions about this Privacy Policy or its implementation, you may contact us here or you can send correspondence to the following address:

ISSA
Attn: Privacy Compliance
2942 N 24th Street, Ste 115
PMB 28058
Phoenix, AZ 85016-7849

Your Data Protection Rights Under GDPR

If you are a resident of the European Union, you have certain data protection rights under the GDPR. ISSA will take reasonable steps to allow you to access, review, update, rectify, or delete any personal data we hold about you.

In certain circumstances, you have the following data protection rights:

• Right of access. The right to obtain access to your personal data.
• Right to rectification. The right to erase or rectify inaccurate or incomplete data.
• Right to erasure. The right to obtain the erasure of your personal data in certain circumstances.
• Right to portability. The right to move, copy, or transfer personal data.
• Right to restrict processing. The right to restrict processing of personal data.
• Right to object to processing. The right to object to processing of personal data for certain purposes.
• Right to be informed. The right to be informed about how your data is being used.
• Right not to be subject to a decision based solely on automated processing.

If you wish to exercise one of these rights, please contact us by using the contact details below. We may ask you to verify your identity before responding to these requests.

Direct Marketing

You may opt-out of receiving marketing communications at any time by unsubscribing from email marketing by opting-out of any emails we may send to you.

How to Contact Us

If you have any questions about this GDPR Statement, you may contact us online, or you can send correspondence to the following addresses:

If contacting us does not provide you with an adequate resolution and your inquiry is related to information collected about you in the European Union/European Economic Area, please contact the applicable EU Data Protection Authority.

Changes to this GDPR Statement

Please visit this page periodically to stay aware of any changes to this GDPR Statement, which we may update from time to time. If we modify this GDPR Statement, we will make the revised overview available at the URL of this page and indicate the date of the latest revision.

RESIDENTS OF BRAZIL PRIVACY RIGHTS

This section provides additional information required by Federal Law No. 13,709/2018 - General Data Protection Law of Brazil ("LGPD"). These provisions apply to residents of Brazil when the LGPD applies and supplement ISSA’s Privacy Policy and GDPR statement.

When ISSA acts as data controller with respect to collecting and processing personal data under LGPD, you may have the right to make the following requests:

• The right to confirmation of the existence of processing;
• The right to access the data
• The right to correct incomplete, inaccurate, or out-of-date data;
• The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD:
• The right to the portability of data to another service or product provider by means of an express request;
• The right to delete personal data processed with the consent of the data subject;
• The right to information about public and private entities with which the controller has shared data;
• The right to information about the possibility of denying consent and the consequences of such denial;
• The right to revoke consent

If you are located in Brazil, when you visit the ISSA website or platform, we may transfer your personal data outside of Brazil. When we do, we will ensure that an adequate level of protection is provided for the transfer.