Effective Date: March 1, 2021
Overview and Scope
This Policy applies to the Service, which includes our applications and software, and apcfire.com, its subdomains, and all of the websites and internet properties owned or operated by us, regardless of the medium by which the Service is accessed by Users (e.g., via a web or mobile browser).
Information We Collect
We are the sole owner and controller of information collected on the Service. We collect several types of information from and about Users of the Service, including:
Personal Information: We may collect PII from you when you complete forms, navigate web pages, and in connection with other activities, services, features, or resources we make available on the Service. PII means any information relating to an identified or identifiable natural person. The type of PII we may collect, use, store, and disclose include the following categories of information:
Category Type(s) of Information
Contact Information and Identifiers First Name, Last Name, Email, Postal Address, Phone Number
Internet Identifiers and Activities IP Address, Browsing History, Search History, Interactions with the Service
Deidentified Information: We may collect deidentified information from you that may not by itself reasonably identify you as the source when you navigate the Service (“Deidentified Information”). Deidentified Information may include: (i) device type, (ii) device operating system, (iii) internet browser type, (iv) internet service provider, (v) referring/exit pages, (vi) date/time stamp, and (vii) clickstream information. We will take reasonable measures to ensure that Deidentified Information we collect is not personally identifiable and may not later be easily used to identify you as required by applicable law.
We do not offer our services or promote the Service to, nor do we intentionally collect or retain PII from, children who are younger than 18 years of age. If we discover that we have inadvertently collected information from a child under 18 years of age, we will promptly take all reasonable measures to delete such information from our systems.
How We Collect Information
The information we collect depends on what Users do when they visit or utilize the Service. We collect PII and Deidentified Information in various ways, including:
Directly from You: We collect PII when you voluntarily submit PII to us while completing forms on the Service and in connection with other activities, services, features, or resources we make available on the Service. The PII we collect depends on what you do when you visit or utilize the Service or how you choose to communicate with us. Please note that we do not collect PII about you unless you voluntary provide such PII by completing forms available on the Service and/or contacting us regarding the Service or our products and services.
Through Your Use of the Service: We may collect PII and Deidentified Information that your browser transmits when you visit the Service. We may also collect Deidentified Information about how you access and interact with the Service through the use of automated tracking technologies, such as session cookies, persistent cookies, and web beacons.
A cookie is a small data file that is transferred to an internet browser, which enables the Service to remember and customize your subsequent visits. We may use session cookies to make it easier for you to navigate the Service. In particular, we may use session cookies to record session information, such as which web pages you visited and to track your activity on the Service. Session cookies expire when you close your browser. We may also use persistent cookies to track and target your interests to enhance your experience on the Service. Persistent cookies remain on your device for an extended period of time.
Most internet browsers automatically accept cookies. However, you can instruct your internet browser to block cookies or to provide you with a warning prompt before you accept cookies from the Service. Please refer to your internet browser’s instructions to learn more about these functions. If you reject cookies, the functionality of the Service may be limited and you may not be able to participate in several of the Service’s features.
Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the Service that allow us to gather information about your browsing activities on the Service.
From Third Party Services: We may collect PII about you from third parties whose privacy practices may differ from the practices described in this Policy. We do not make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available through third parties. Your use of third parties’ services and/or third party websites is governed by and subject to the terms and conditions of those third parties and/or third party websites. We encourage you to carefully review the privacy policies and statements of such third parties and/or third party websites.
How We Use Information
We may use Users’ PII for lawful purposes: (i) as necessary for the performance of our contract with Users (such as our [Terms of Website Use]), (ii) for our legitimate interests, so long as they are not overridden by Users’ own rights and interests, or (iii) as required by law. These purposes include:
Direct Marketing: We may use your PII to send you promotional materials. You have the right to opt-out of receiving direct marketing.
Customer Service and User Communications: We may use your PII to help us respond to your inquiries, questions, requests, and support needs more efficiently.
User Experience Personalization: We may use Users’ PII and/or Deidentified Information in the aggregate to analyze Users’ browsing and usage activities and patterns in order to understand Users’ interests and preferences with respect to the Service and our services. This will help us optimize your experience on the Service.
Business Optimization: We may use your PII and/or Deidentified Information to improve the content on our web pages, to customize the content and layout of our web pages, and in managing our everyday business needs. We may also use your feedback to improve the Service and our services. All of this is done with the intention of making the Service more useful for you.
We will not collect additional categories of PII or use PII we collected for materially different, unrelated, or incompatible purposes without providing you notice.
How We Disclose Information
We may disclose Users’ PII to third parties for a business purpose as described below. Otherwise, we do not sell or rent PII, and will not disclose Users’ PII to third parties without your permission.
To Our Affiliates: We may disclose your PII to affiliates, including companies within the APC, AAI, and Apollo America Inc. groups.
To Service Providers: We may disclose your PII to third party service providers that assist us in providing user support, communicating with Users, and promoting our services, as well as third party service providers that provide other services to us relating to our services and/or the Service.
Law Enforcement, Safety, and Legal Processes: We may disclose your PII to law enforcement or other government officials if it relates to a criminal investigation or alleged criminal activity. We may also disclose your PII: (i) if required or permitted to do so by law; (ii) for fraud protection and credit risk reduction purposes; (iii) in the good-faith belief that such action is necessary to protect our rights, interests, or property; (iv) in the good-faith belief that such action is necessary to protect your safety or the safety of others; or (v) to comply with a judicial proceeding, court order, subpoena, or other similar legal or administrative process.
Sale or Acquisition of Assets: If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if we are transferred to another company, we may disclose and/or transfer your PII as part of the transaction. If the surviving entity in that transaction is not us, the surviving company may use your PII pursuant to its own privacy policies, and those policies may be different from this Policy.
We may also disclose Deidentified Information and anonymized data with trusted third parties and partners for the purpose of evaluating our products or services.
The security and confidentiality of your PII is very important to us. We use commercially reasonable security measures to protect your PII on the Service. However, no data transmitted over or accessible through the internet can be guaranteed to be 100% secure. As a result, while we attempt to protect your PII, we cannot guarantee or warrant that your PII will be completely secure (i) from misappropriation by hackers or from other nefarious or criminal activities, or (ii) in the event of a failure of computer hardware, software, or a telecommunications networks.
GDPR Data Subject Rights
If you are a data subject located in the EEA, the GDPR grants you certain data privacy rights. Your rights include the:
• Right to Access: You have the right to request a copy of your PII.
• Right to Rectification: You have the right to request that we correct any mistakes in your PII.
• Right to Erasure: You have the right request that we delete your PII.
• Right to Restrict Processing: You have the right to restrict processing of your PII.
• Right to Object to Processing: You have the right to object to our processing or your PII.
• Right to Data Portability: You have the right to receive your PII in a structured, commonly used and machine-readable format.
To exercise your rights, please contact us at the Contact Information provided below. Please be aware that your rights are limited to the extent permitted by the GDPR.
California Privacy Rights
California’s “Shine the Light” law permits Users of the Service that are California residents to request certain information regarding our disclosure of PII to third parties for their direct marketing purposes. To make such a request, please contact us at the Contact Information provided below. Please be aware that your rights are limited to the extent permitted by applicable law.
Generally, we do not process PII based on consent. However, in the event we do, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on said consent before its withdrawal. If you would like to withdraw your consent, please contact us at the Contact Information provided below.
File a Complaint
If you would like to file a complaint with us about our privacy practices, please contact us at the Contact Information provided below. If you are a data subject located in the EEA, the GDPR grants you the right to lodge a complaint with a competent supervisory authority as well. To find a competent supervisory authority, please use the following resource: https://edpb.europa.eu/about-edpb/board/members_en.
Cross Border Data Transfer
To deliver the Service, it may be necessary for us to share data subjects’ PII outside the EAA. We may share data subject PII with Company affiliates and services providers located in United States of America. In the event we transfer PII outside the EEA, we will take commercially reasonable measures to ensure the transfer complies with data protection laws and PII is securely transferred. Our standard practice is to use standard contractual clauses approved by the European Commission to facilitate such data transfers. If you have any questions about our data transfer practices, please contact us at the Contact Information provided below.
We will retain Users’ PII while they maintain an account with us or to the extent necessary to provide the services through the Service. Thereafter, we will keep PII for as long as necessary: (i) to respond to any queries from Users; (ii) to demonstrate we treated Users fairly; (iii) for ordinary business continuity procedures; or (iv) to comply with any applicable laws. We delete PII within a reasonable period after we no longer need the information for the purposes set out in this Policy.
Do Not Track Disclosure
Some internet browsers may transmit “do-not-track” signals to websites with which the browser communicates. The Service does not currently respond to these “do-not-track” signals.
We do not participate in bulk email solicitations that you have not consented to receiving (i.e., “Spam”). We do not sell or disclose customer lists or email address lists to unrelated third parties. Except as otherwise provided herein, we do not share PII with any third party advertisers.
Third Party Links
The Service may contain links to other websites or applications (“Linked Services”) that are not owned by the Company. We do not control the collection or use of any information, including PII, which occurs while you visit Linked Services. Therefore, we make no representations or warranties for—and will not in any way be liable for—any content, products, services, software, or other materials available on Linked Services, even if one or more pages of the Linked Service are framed within a page of the Service.
Furthermore, we make no representations or warranties about the privacy policies or practices of the Linked Services, and the Company is not responsible for the privacy practices of those Linked Services. We encourage you to be aware of when you leave the Service and read the privacy policies of Linked Services.
Accessing, Updating, and Controlling Information
If you ever wish to access, update, change, delete, or opt-out of us sharing your PII, or exercise your privacy rights, where applicable, you may do so by contacting us at the Contact Information provided below. To help us process your request, please provide sufficient information to allow us to identify you in our records. We reserve the right to ask for additional information verifying your identity prior to disclosing any PII to you. Should we ask for verification, the information you provide will be used only for verification purposes, and all copies of the information will be destroyed when the process is complete.
If you wish to opt-out of receiving update messages and/or direct marketing communications from us, you may opt-out by following any instructions included in the communication or by contacting us at the Contact Information provided below. To help us process your request, please include sufficient information for us to identify you in our records. Please be aware that although you may opt-out of update messages and/or direct marketing communications, we reserve the right to email you administrative notices regarding the Service, as permitted under the CAN-SPAM Act.
We will make commercially reasonable efforts to respond to all requests without unreasonable delay and in any event within one month of receipt of a Users’ request. Where circumstances require, we may extend the reply period for an additional two months. Please be aware that requests may be limited to the extent permitted by applicable law, including the GDPR.
If you have questions about this Policy or wish to contact us with questions or comments, please contact us at:
Apollo America Inc.
25 Corporate Drive
Auburn Hills, MI 48326