Privacy Policy

1 Introduction

This Privacy Policy (the “Policy”) explains how Geo-Logic Associates, Inc. (“GLA” or “we”/ “our”/ “us”) collects, uses, shares, and otherwise processes the personal information we collect about consumers. This Policy details what information we collect, how we use it, and the choices and rights you have regarding its use. Our aim is to give you the necessary insights to make informed decisions about your interactions with us, including online. By using our Online Services (defined below) and providing your personal information to us, you give us permission to process your personal information as described in this Policy. If you do not agree with the data collection practices described in this Policy, do not access or use our Online Services.

2 Scope of This Policy

This Policy describes the various contexts and circumstances in which we collect personal information, including through our “Online Services”. These Online Services include:

Digital Interactions: This encompasses your online engagements with us, which may occur through our Online Services, including:
- Our Websites: Any that link to this Policy, such as www.geo-logic.com
- Social Media and Affiliates: Interactions on our social media pages.
- Other Digital Platforms: Includes interactions such as clicking on our ads on third-party sites and subscribing to our electronic communications.
Online Customer Services: Including communications with our service representatives or features via chat functions, email, text, or phone.
Third-Party Information Gathered in the Online Context: This policy also extends to information we may collect about you from third parties related to your use of our Online Services, even in the absence of direct interactions with us.

For questions regarding the scope of this Notice, please contact us as set forth in the Contact Information section.

3 How We Obtain Information

We obtain the information we collect about you through various means and sources, including:
• Direct Interactions. We collect personal information when you provide it directly to us, such as when you submit forms via our Online Services, or otherwise provide us with information via phone, email, or online communications. The information collected online may be entered into our systems and combined with other information we collect about you directly or from third parties. We may also share this data with our service providers, affiliates, and marketing partners, and others. Please see below for more information about how we share your personal information.
• Automatically Using Data Collecting Tools. We use various data collecting tools, including cookies, to collect certain information about your use of our Online Services. These tools can help us improve site performance and understand how our services are being accessed.
• Third-Party Sources. We may collect personal information from third parties, including social media platforms, public forums and databases, and other relevant parties based on your interactions with us. This information may be combined with other data we collect about you to enhance our Online Services.

4 Information Collected and How We Use It

We collect and use personal information for several purposes, including to provide our Online Services and continually improve them. The personal information we collect, and how that information is used, depends on how you interact with us, the choices you make when engaging with us, and the Online Services you use.

This section provides an overview of the types of personal information we may collect about you and the general purposes for which they are used in particular contexts. Please note that the actual information collected, and its use, may vary depending on your interactions with us and the Online Services you use.

1.1 Personal Information We Collect Directly From You

This section describes the personal information we collect about you when you provide it directly to us through our Online Services, including in an electronic communication.

1.1.1 What We Collect or Process

Contact Information (Identifiers). We collect your name, email address, telephone number, and any other personal identifier you provide in a form or online communication.
Submitted Content. If you upload, submit, or transmit documents or content to us using our Online Services, we will collect any personal information contained within that content. We ask that you ensure that you respect the privacy of any individuals whose personal information may be in the content you transmit to us.
Commercial Activity. We keep track of the services and projects for which you have engaged us, or about which you have inquired.

1.1.2 How We Use It

To Communicate With You. We will use your personal information to facilitate our communications with you. For example, we will use your email address to respond to your email requests. The length of time we maintain your contact information and your communications varies depending on the context.
Service Fulfillment. We use your personal information to perform a variety of services essential to the customer experience or our business, such as transaction processing and fulfillment, billing and payment processing, and customer service across multiple channels.
Business Operations. We use personal information to perform business operations, such as document management and record keeping, training and development, generating business intelligence reports, strategic decision making, auditing and compliance, maintaining the security and integrity of our Online Services and offline operations, including protection against fraudulent or illegal activities. This may include validating your identity as necessary.
Quality Assurance and Improvement. We use personal information to maintain and improve the quality and safety of our Services.
Additional Uses Described. In any other way we may describe when you provide the information or any other purposes for which you provide your consent.

1.2 Personal information Collected Using Online Data Collecting Tools

We collect, use, and disclose personal information gathered in connection with your online interactions with us, including your use of our websites and their features. We may also collect personal information in connection with electronic communication services like email and electronic messaging, and our social media pages (though not the platforms on which they are maintained). When you use our Online Services, we collect some information automatically and combine it with other information we collect about you. In many cases we utilize third parties to assist with this collection. In such cases, your personal information is made available to other entities for processing on our behalf or at our direction.

Some of this information is collected and logged because of your access to our servers, by various technologies such as cookies, scripts, tags, and other software code that store and transmit personal and other information (collectively “data collecting technologies”).

1.2.1 What We Collect or Process Using Data Collecting Technologies

Identifiers and Contact Information. We collect identifiers associated with you or the device you are using to access our Online Services, such as IP addresses, cookie IDs, and other similar identifiers.
Device and Browser Data. We collect information about your device and the software and systems you use to access our Online Services, such as your browser type/version, screen size/resolution, and other information contained in your browser’s communication with our website.
User Interaction Data. We may collect data about how you navigate to/from our Online Services (such as the URLs that referred you to our website), browsing activity on our Online Services (such as the web pages you viewed and buttons you clicked), and other metrics associated with your access and use of our Online Services.
Electronic Communication Records. We collect records related to your electronic communications with us, including email records, call records and recordings/logs, and other electronic messages and communications.
User Preferences. We record your online preferences, such as communication preferences, language, time/zone, and general location information, and privacy choices and configurations. We do this to facilitate such preferences.

1.2.2 How We Use It

To Provide Our Online Services in a safe and secure manner, such as to present our website and its content to you, to communicate with you about changes to our Online Services, to validate your identity as necessary to ensure the security of our services and systems, and to maintain and improve the security and performance of our Online Services.
Communications and Support, such as to review and respond to your requests or inquiries, provide updates, notices, and requested communications, send you important transactional information, request feedback, or as necessary to fulfill our obligations to you.
For Our Legitimate Business Operations, such as to make strategic decisions concerning our business operations, enforce, and review compliance with, the legal terms that govern our offerings, comply with our legal obligations, protect the rights, safety, and property of the Online Services, our users, and third parties, and anonymize, aggregate, or de-identify your personal information (so it can no longer identify you) in furtherance of conducting research and analysis.
To Send You Promotional Materials, such as updates, newsletters, surveys, or other information regarding events, and/or other GLA services that may be of interest to you based upon information you have provided to us. Promotional materials may be conveyed in emails, or through other means if you have provided your consent.
Analytics. We use personal information to conduct research and analytics, including to improve our Online Services. We also use your personal information to understand how you interact with our websites and communications with you.
Data Aggregation. We may aggregate your personal information with that of other users for analytical and reporting purposes. This aggregated data is anonymized or deidentified and does not identify you personally. Aggregated data may be used for various purposes, including statistical analysis, without further notice to you and without obtaining additional consent.
With Your Consent. We use information about you where you have given us consent to do so for a specific purpose not listed above.

1.2.3 Third Parties Who Provide Online Services

We may use third-party services for various purposes, including but not limited to analytics and customer support. Below are some specific third parties that we may use. To learn more about the types of entities who deploy cookies and data collecting technologies on our websites, please review “Disclosure of Personal information.”

Font and Content Providers. Various third parties assist us in providing content and features for our Online Services. Because these services send the content to your browser on our behalf, they typically have access to information about your device and browser, including your IP address, the URL of the pages you visit, and information about your device. They use this information to ensure that the content is delivered to you in the correct format and size.
Web Hosting Providers. Our website hosting and infrastructure providers will receive personal information about your device, including your IP address, device, and browser information, as well as your activity on our websites, in order to provide the hosting services.
Analytics Providers. We allow third-party partners and service providers (such as analytics providers and social media platforms and networks) to gather data when you interact with our Online Services for our analytics purposes.
- Google Analytics: We employ Google Analytics for detailed user interaction analysis. This service collects data such as your originating location, visit frequency, viewed pages, and actions taken within our Online Services. Google Analytics uses cookies to collect this information. The use and sharing of this data by Google are subject to the Google Analytics Terms of Service. For options to opt-out of Google Analytics tracking, you may disable cookies on your browser or follow these specific instructions provided by Google.

1.2.4 Your Privacy Choices Regarding Online Data Collecting Technologies

“Do Not Track” Signals. Do Not Track (“DNT”) is a privacy preference that you can set in your web browsers, which allows you to opt out of tracking by websites and online services. Like many websites, we do not currently respond to ‘Do Not Track’ browser settings or signals. For more information about DNT, please see eff.org/issues/do-not-track.

“Global Privacy Control.” Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including the “sharing” of your personal information. Since GLA does not sell or share personal information, we do not respond to GPC signals.

1.3 Data Collected from Other Parties

We obtain information from businesses which provide us with our business and Online Services, such as our data analytics providers, fraud prevention service providers, vendors that provide services on our behalf, and publicly available sources. We also create information based on our analysis of the information we have collected from you. We use this information for our business operations purposes, including offering and improving our services, providing customer support, accounting and transaction purposes, and to enforce our terms and policies.

1.4 Other Purposes for Processing Personal information

While less frequent, there are other scenarios where we may use or disclose your personal information:

Audits Involving External Entities: Sharing data with external organizations, including those we collaborate with or those that evaluate our business operations, to ensure compliance with industry standards, certifications, or legal obligations.
Legal Obligations: Fulfilling legal obligations such as responding to subpoenas, court orders, or other binding government requests. In the rare event of litigation, we may use your data to establish, exercise, or defend legal claims.
Reorganization: In the event of a business transaction such as a sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, your personal information may be shared or transferred. This also includes any subsequent integration activities post-transaction.
Business Transfers: In the event of a divestiture, investment, or other asset transfer that is not part of a broader business transaction like a merger or acquisition, your personal information may be shared or transferred.

With Your Consent: We use information about you where you have given us consent to do so for a specific purpose not listed above.

5 Disclosure of Your Personal information

We may disclose the above information to the following types of parties:

Other GLA Group Entities (Affiliates). We may share personal information between the GLA entities that are related by common ownership or control. We share personal information for our routine business purposes and to develop new and improve existing services.
Authorized Persons and Agents. We may disclose personal information to marketing, analytics and other services providers with whom we interact on your behalf.
Business Services Providers. These are persons or entities with whom we have a relationship to provide business operations services and support to GLA. These providers may include the following:

IT Operations Providers.These include cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers.
Business Operations Providers.These include service provider with whom we partner to provide day-to-day business operations, including payment processors, security vendors, business software service providers, banks, facilities management providers and similar entities.
Professional Service Providers. These include lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.
Marketing Providers. These include marketing providers, marketing consultants, and similar services providers.
Law Enforcement/Government Agencies. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.
Corporate Transaction Disclosures. Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.

Authorized Disclosures. To any party when authorized by the individual to whom it pertains to share it.

6 Data Retention

We retain your personal information only as long as needed to fulfill the purposes we collected it for, including satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of your personal information; (iii) the purposes for which we process your personal information and whether we can achieve those purposes through other means; and (iv) the applicable legal requirements related to our processing activities. Additionally, we may de-identify or anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. If you have any questions about the specific retention periods for different types of your personal information, please feel free to contact us using the Contact Information provided below.

7 Your Privacy Choices

You can control the collection and use of personal information for some of our processing activities. Below are the avenues through which you can manage the types of communications you receive from us:

Email: To opt out of promotional emails, you may follow the ‘unsubscribe’ instructions located at the bottom of each email. Alternatively, you may contact us directly using the information provided in the Contact Information section. Please be advised that opting out of promotional communications will not preclude you from receiving transactional emails, such as those related to services you have purchased.

8 Your Privacy Rights

8.1 Description of Your Privacy Rights
Depending on your location and applicable laws and regulations, you may also have data privacy rights regarding GLA’s processing of your personal information. Based on the legal requirements applicable to your jurisdiction, and subject to any legal restrictions or exceptions, you may have the choices and rights described below.
• Right to Access. You may request access to the personal information we hold about you. This may include the right to be informed about the categories and specific pieces of personal information we have collected, the sources from which we collected it, the purposes for collecting it, and the third parties with whom we have shared it.
• Right to Correct. You may request that we correct any inaccurate personal information relating to you without undue delay. In this context, taking into account the purposes of the processing, you may also have the right to request the completion of incomplete personal information – also by means of a supplementary declaration.
• Right to Delete. You may request the deletion of your personal information, subject to certain exceptions. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if the processing is necessary for the performance of a contract.
• Right to Portability. You may request that we provide you with a copy of your personal information in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer this information to another data controller, where technically feasible.
• Right to Opt Out of Sale. You may direct us not to sell or share your personal information with third parties. In the preceding twelve (12) months, GLA has not “sold” personal information as this term is defined in the CCPA. Therefore, we do not offer such a right.
• Right to Opt Out of Targeted Advertising. You may request that we not disclose, disseminate, or transfer your personal information to a third party for targeted advertising (also known as “cross-context behavioral advertising”). In the preceding twelve (12) months, GLA has not disclosed personal information for targeted advertising purposes. Therefore, we do not offer such a right.
• Right to Restriction of Processing. You may request that we restrict processing of your personal information. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
• Right to Opt Out of Certain Data Processing. You may withdraw your consent that you have previously provided for GLA’s collection, use or disclosure of your personal information, subject to reasonable notice and any contractual or legal exceptions. Note that this will not affect the lawfulness of our processing of your personal information based on consent before its withdrawal.
• Right to Opt Out of Automated Individual Decision-Making. You may have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Note that this right shall not apply if such a decision is necessary as part of a contract we have with or want to conclude with you, we have your consent, or we are permitted by law to engage in such automated decision making. Where applicable, in these cases, we will implement measures to safeguard your rights and freedoms and legitimate interests, and you may contest the decision by contacting us as set forth below.
• Right Against Discrimination. You have the right not to be discriminated against for exercising any of your data protection rights. This means that we will not deny you goods or services, charge you different prices or rates, or provide you with a different level or quality of goods or services based solely on your exercise of these rights.
• Right to Appeal. Depending on your residency, you may have the right to appeal if we decline to act regarding your privacy request. To do so, please follow the instructions for exercising your privacy rights below, or use the contact information provided in this Policy.
Residents of California may also have additional rights pertaining to their personal information, as described in “California Privacy Rights.”

1.2 Exercising Your Privacy Rights

To exercise any of the rights outlined above, please contact us as set forth in the Contact Information section of this Policy.

To ensure the security and confidentiality of your personal information, we have established verification measures that must be completed prior to fulfilling any request to exercise your data rights. These measures may involve confirming your identity through a series of questions or requiring documentation that substantiates your identity or authority to make the request. Should we be unable to verify your identity or authority adequately, we reserve the right to decline the request and will provide an explanation for our decision. Upon receiving a verified request to exercise your data rights, we will acknowledge receipt of the request. We will aim to respond substantively to your request within time permitted under the applicable law. If we require more time to process your request, we will inform you of the reason and extend the period by the notified number of days.

Please note that not all requests will be granted. Certain legal exceptions may apply, such as if we are unable to verify your identity, or if there are legal or contractual reasons that prevent us from fulfilling a deletion request. Regardless of the outcome, you will receive a written response that either details the actions we took or explains why no action was possible. If you are dissatisfied with our initial response, you may seek further review. To initiate an appeal, please contact us within 30 days of receiving our initial response using the method provided in the response. You should include a copy of your original request, our response, and a detailed explanation of why you are seeking reconsideration. You may also attach any additional supporting information and documents that you believe are relevant. We will review your appeal and provide a final determination within 60 days.

9 Security

We implement recognized physical, technical, and organizational safeguards tailored to protect the confidentiality, integrity, and availability of the specific categories of personal information we collect and process. These safeguards are designed to prevent unauthorized or unlawful access, destruction, loss, alteration, or disclosure of your personal information. However, despite our best efforts, no controls can provide absolute protection against all security threats, and we cannot guarantee that unauthorized access or loss will never occur. We have procedures in place to deal with any suspected data security breach. We will notify you and/or any applicable regulator of a suspected data security breach where we are legally required to do so in accordance with any legally prescribed timeframes.

10 Children’s Privacy

Our Online Services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe that your child has provided us with personal information, please use our Contact Information. If we become aware that we have collected the personal information of a child, we will take steps to promptly delete such information.

11 Updates to This Privacy Policy

We reserve the right to modify this Policy at any time to reflect changes in our practices, services, or legal obligations. Any modifications will be effective upon the date specified in the updated Policy. If we make material changes to this Policy that significantly affect your rights or the way we use your personal information, we will notify you through the most appropriate channels. Generally, this will be done by updating the date at the top of this page. However, other notification methods may include sending an email to the address you have provided, posting a notice on our Online Services, or other methods as required by law. Your continued use of our Online Services following the posting of changes constitutes your acceptance of such changes.

We will indicate the date of the last revision at the top of this Policy. We encourage you to periodically review this Policy to stay informed about how we are protecting your personal information.

12 California Privacy Rights

his section is tailored to meet the specific requirements imposed by California law. While this section outlines state-specific rights for California residents, the preceding sections of this Policy also apply to them.
12.1 Additional Notice to California Residents
California law requires us to disclose the following additional information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of the Policy.

Description of Information Practices Regarding CCPA-Defined Categories of Personal Information
Category	Examples	Collected	Disclosed for a Business Purpose	Shared for Cross-Context Behavioral Advertising
Identifiers	A real name, alias, postal address, unique personal identifier (e.g., employee ID), online identifier, Internet Protocol address, email address, driver’s license number, passport number or other similar identifiers.	✔	✔	✔
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	✔	✔
Protected classification characteristics under California or federal law	Age (40 years or older), citizenship, marital status.
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	✔	✔
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity	Browsing history, information on a consumer’s interaction with a website, application, or advertisement.	✔	✔	✔
Geolocation data	Physical location or movement.
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information	Current or past job history or performance evaluations.	✔	✔
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sensitive Information	Government identifiers (social security, driver’s license, state identification card, or passport number); complete account access credentials (usernames, account numbers, or card numbers combined with required access/security code or password); precise geolocation; racial or ethnic origin; mail, email, or text message contents; genetic data; data concerning health, sex life or sexual orientation.

For a comprehensive understanding of the types of personal information we collect, the sources from which we collect it, and the purposes for which we use it, please refer to the “Information Collected and How We Use It” section of this Policy.
12.2 California-specific Privacy Rights
California law grants rights specific rights to California consumers regarding their personal information. Note that these may be duplicative of the rights described above in “Your Privacy Rights”. They are as follows:
• Right to Know. You can request, up to two times each year, that we disclose the categories and/or specific pieces of personal information that we collect, use, disclose, and may sell, the sources from which we collected it, the purposes for collecting, selling, or sharing it, as applicable, and the categories of third parties with whom we have shared it.
• Right to Correction of Personal Information. You have the right to have inaccurate personal information corrected.
• Right to Deletion of Personal Information. You can ask us to delete the personal information that we have collected from you, subject to certain exceptions such as to complete a transaction for you, to exercise our rights, or to comply with a legal obligation.
• Right to Opt out of Sales of Personal Information. You have the right opt out of the sale of your personal information to third parties. In the preceding twelve (12) months, GLA has not “sold” personal information as this term is defined in the CCPA. Therefore, we do not offer such a right.
• Right to Opt Out of Sharing of Personal Information. The CCPA defines “sharing” as disclosing or making a consumer’s personal information available to a third party for cross-context behavioral advertising. In the preceding twelve (12) months, GLA has not shared personal information for such targeted advertising purposes. Therefore, we do not offer such a right.
• Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer. GLA does not use sensitive personal information beyond the CCPA’s permissible purposes.
• Right against Discrimination. You are entitled to exercise the rights described above free from retaliation as prohibited by the CCPA.
• Right to Appeal. If we deny your request to exercise a right, you have the right to appeal our decision.
To exercise your California privacy rights, please use the contact methods described below. We may request specific information from you to help us confirm your identity and your rights. We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to verify your identity, process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision.
You have the option to designate an authorized agent to submit requests on your behalf for exercising your data rights. An authorized agent can be either a person or a business entity that you have formally authorized to act on your behalf.
To use an authorized agent:

Signed Authorization: You must provide the authorized agent with a signed written authorization to act on your behalf. This document should clearly indicate that you grant them the authority to submit requests for you.
Agent Submission: The authorized agent can then submit a request via the methods outlined above. The agent should attach a copy of the written authorization you provided.
Identity Verification: We may contact you directly to confirm that you have authorized the agent to act on your behalf. This is a security measure designed to protect your personal information.
Please note that we reserve the right to deny requests from agents who do not provide proof of authorization or if we cannot verify the agent’s identity.

13 Contact Information

If you have any questions or concerns about this Policy or our data practices, you can reach out to us through the following means:
Email:
info@geo-logic.com
Mail:
2777 East Guasti Road
Ontario, CA 91761

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