Privacy Policy
Legal Information
This Privacy Policy informs how eLumpers (hereinafter also –” Controller”,” Owner”,” we”, “us” or “our”) processes information and personal data on the website http://localhost/elumpers/ as well as any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (hereinafter – Website). ELUMPERS LLC, 1001 BRICKELL BAY DRIVE, SUITE 2700-T1, MIAMI, FL 33131.
We strive to protect all personal information that we receive or generate. This Privacy Policy (“Privacy Policy” or “Policy”) explains our data protection practices for our visitors. This Privacy Policy also explains the nature of the personal information we collect, the means by which we collect it, the purposes for which we collect it, and how we use, process, protect, and share it.
Please read this entire Privacy Policy before submitting information to this Website. By accessing or using this Website for any purpose and by submitting any of your personal information to us, you are consenting to the terms and conditions of this Policy. If you disagree with any part of this Privacy Policy, please do not use this Website or any of our other services and do not share any personal information with us.
Disclosures. We may disclose your Personal Information with law enforcement and other government officials in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also disclose your information to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take necessary action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
Sale of Personal Information. We do not sell, rent, or loan your Personal Information to third parties for money. However, we may engage in activities, subject to your privacy choices, where sharing your information in the Identifiers and Internet or network activity data sections of the above chart, to social media platforms, analytics providers, and advertising companies may be considered a “sale” under certain applicable laws.
Retention of Personal Information. We retain your Personal Information so long as it is reasonably necessary for the purpose for which it was collected, compliance with our legal obligations, resolution of disputes, fraud prevention and enforcement of our agreements. To determine the appropriate retention period for your Personal Information, we consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it; whether we can achieve those purposes through other means; and the applicable legal requirements.
In some circumstances we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information. Upon expiration of the applicable retention period, we will securely destroy your Personal Information in accordance with applicable laws and regulations.
Collection of Information from Children. We recognize the importance of protecting the privacy and safety of children, and our website and services are directed towards a general audience and are not directed towards children. We do not knowingly collect information about children under the age of 16 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under 16 has provided Personal Information through one of our websites, we will use reasonable efforts to remove that information from our databases.
Transmission of Information to Other Countries. As a multinational company, we may transmit information between and among our affiliates. As a result, your information may be stored and processed in any country where we have facilities or in which we engage service providers. We take steps to treat Personal Information using the laws of the country in which we first received your information.
For certain jurisdictions your Personal Information may be subject to the laws of the country to which it is transferred, and if permitted by law, may be accessible without notice to you by the courts, law enforcement and national security authorities of that country. By using and participating in any of our Services or providing us with your information, you acknowledge the collection, international transfer, storage, and processing of your information.
Third Party Applications/Websites. We do not control the privacy practices of websites or applications that we do not own. Users are encouraged to read the privacy policy of those properties to make an informed decision regarding use of them.
Changes to This Privacy Policy. We may change our privacy policy and practices over time. We will post a notice to our website to inform you of any material changes to our privacy policy and indicate when it was most recently updated. Generally, material policy changes will apply only to information collected after the date of the change. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
Definitions And Legal References
Personal Data (or Data) – Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data – Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User – The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject – The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor) – The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner) – The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
Collenting Of Data
This section explains generally the sources from which, and the means by which, we collect and process personal information.
- Account Registration. Your name, email, phone number and other relevant information when you create an account. We also may collect information relating to the actions that you perform while logged into your account. The purpose for collection and use of this data is that we have a business need to provide account related functionalities to our users. Accounts can be used for easy checkout, save your preferences, select areas of interest, and transaction history.
- Lead Forms and Order Placement. We collect information when you use our lead and order forms on our Services. This may include your name, email, phone number, billing address, shipping address, and payment information (e.g., credit card number). In addition, these forms may ask for information specific to your request, such as car make and model for auto insurance, military service for secondary education, or other information requested by our business clients. The purpose of collection and use of this data is that we use your information to perform activities associated with a contract to provide you with products or services.
- Financial information. For certain Red Ventures’ Services, you may provide us with information such as national identifier, credit history, income, loan amounts, and account balances related to requesting financial products and services. Examples include credit card inquiries personal insurance quotes, and loan inquiries for products such as mortgages, personal loans, and student loans. In some situations, for certain Services, our GLBA notice may also apply to the collection, use and sharing of this financial information. The purpose of the collection is we have a business need to use this information to facilitate your request and connect you to lenders that deliver the products and services you request.
- Information You Post on the Services. When available on the Services, we may collect Personal Information from you when you provide or post information to our Services, including your username, comments, likes, interests, status, pictures, and references to your online presence. We may use this information for our purposes and/or make this information available to others as you request and/or permission.
- Information You Provide About Others. Sometimes, you may provide information about others, for example, to refer a friend for a newsletter. We may use this information to make our Services available to the people you refer to us.
- Surveys. When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy also applies to the collection, use, and disclosure of your information. The purposes of collection and use of this data are that we have a business need to understand your opinions and collect information relevant to our organization.
- Sweepstakes or contests. When you choose to participate in a sweepstakes or contest, we collect information about you, which includes contact information to notify you if you are selected. The purpose of collection and use of this data is that we have a business need to operate the contest or sweepstakes. In some contexts, we are also required by law to collect information about those that enter our sweepstakes.
- Mailing List. If you sign up for one of our mailing lists we collect your email address and/or postal address. The purpose of collection and use of this data is that we have a business need to share information about our products or services.
- Partner Promotion. We collect information that you may choose to provide as part of a promotion with another company. The purpose of collection and use of this data is that we have a business need to fulfill our promotions.
- Feedback/Support. If you provide us feedback or contact us for support, we may collect your name and e-mail address, as well as any other content that you send to us, to reply. The purpose for collection and use of this data is that we have a business need to receive and act upon your feedback or issues.
Information collected Automatically:
- E-mail Interconnectivity. If you receive email from us, we may use tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. The purpose for collection and use of this data is that we have a business need to understand how you interact with our communications to you.
- Mobile Devices (such as Phones, Tablets, Connected TVs, and Other Digital Media Streaming Devices). We may collect information from your Mobile Device, such as unique identifying information broadcast from your device when visiting one of our Services. The purposes of collection and use of this data are that we have a business need to identify unique visitors and understand how users interact with us on their devices.
- Website interactions. We use technology to discover how you interact with our website (e.g., session replay). This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. The purposes of collection and use of this data are that we have a business need to understand how you interact with our website to better improve it, and to understand your preferences and interests to select offerings that you might find most useful. We also have a business need to secure our Services and detect and prevent fraud.
- Location Data. When you use certain of our Services, we may solicit your permission to collect your location data. Some features within our Services (such as location-based offers) may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data. The specificity of the location data may depend on several factors, including the device you are using and how you are connected to the Internet. If you enable location services for our Services, we may collect location data periodically as you use or leave open our Services. Depending on the platform you use to access our Applications (e.g., Apple’s iOS, Google’s Android) you may be able to control whether location data is collected from with the controls on your device.
- Cookies, generally. We and our service providers operating on our behalf, and other businesses who collect information on our pages may automatically collect or receive certain information associated with you and/or your device(s) as part of your use of the Services through device-based tracking technologies such as cookies, pixels, tags, beacons, scripts or other technology. The purpose for collection and use of this data is that we have a business need to make our website operate efficiently, provide you with different website experiences, and to provide you with the ability to save your preferences such as login and preferred language.
- Cookies, for advertising. Some of our Services participate in behavior-based advertising, which means that technology (e.g., a cookie) is used to collect information about your use of our Services to provide advertising about products and services tailored to your interests on our Services, or on other websites. The purpose of collection and use of this data is that we have a business need to engage in behavior-based advertising and capture analytics on our Services. The information we collect may include geolocation data, such as (a) information that identifies the precise location of your mobile device (when you agree to allow an app or Service to collect this) and (b) your IP address, which may be used to estimate your approximate location. We use this information to ensure that the Services work properly, and to deliver customized content and advertising, including personalized ads, to you.
- Cross-Device Tracking. We and our service providers may collect and store information about users’ interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices or browsers, for instance, and then link those browsers and devices into a device graph. The purpose of collection and use of this data is that we have a business need to understand our users’ use of our sites across devices to allow users to use our services on one device and pick up seamlessly where they left off on another device. We also have a business need to provide personalized advertising on each device that is inferred from the browsing patterns on the devices.
- Data Analytics. We use certain web analytics services, including third-party services such as Google Analytics, to help us understand and analyze how visitors use our Services. We may collect information, including your browser type, operating system, Internet Protocol (IP) address, domain name, click-activity, referring website, and/or a date/time stamp for visitors. The purpose of collection and use of this data is that we have a business need to monitor our networks and the visitors to our websites. We may receive reports based on the use of these technologies on both an individual and aggregated basis. These analytics services, including third-party services such as Google Analytics, also use this information to place advertisements for our products on other websites that you visit after your use of the Site.
Information we may collect from other sources:
- Business Client Information. We may collect contact information such as name, e-mail, address and/or phone number of our business clients and their employees with whom we may interact. The purpose of collection and use of this data is that we have a business need to make our website operate efficiently and to provide our business clients with ability to save preferences such as login and preferred language.
- Financial information. We may collect information from credit reporting services and, with your permission, financial data aggregator(s) and your financial service provider(s) when you use certain of our Services. We use the information as needed while providing services you request, ongoing customer relationships, to service an account, and as permitted by state and federal law.
- Demographic Information. Personal Information such as your age, gender, family size, and/or educational level. The purpose of collection and use of this data is that we have a business need to customize content, advertising and learn about our audiences.
- Activity and usage information. including information about your interests, purchase behavior, and other navigation data, such as websites visited and advertisements viewed or clicked on, used to customize content and advertising.
- Publicly observed data. Such as activities on blogs, videos, and other online postings used to customize content and advertising.
- Social Media Platforms and Other Third-Party Services. Some of our Services may include features that are designed to interact with social media platforms and other third-party services (e.g., Facebook, Twitter, Instagram, and loyalty programs). If you access the Services using one of these social media platforms or provide us access to third-party services, we may receive information about you from those third parties such as account and profile data and we may combine this data with information we already have about you.
We may also collect information about you through interactive applications (e.g., mobile devices, third party social networking services, and embedded audio and video players), from co-branded partners and websites (e.g., on our Facebook pages), from our advertisers, and from commercially available sources (e.g., data aggregators and public databases). This Privacy Policy does not cover the practices of third parties, including those that may disclose information to us.
Purpose Of Data Collection
We use the personal information that we collect or receive from our Users for the purposes described in this Policy and for other business purposes allowed by law, including the development, delivery, and performance of our services, sharing with our affiliates for related business purposes, and as follows:
- To identify you when you engage with us and our Services.
- To provide content recommendations based on your interactions and interests.
- To make our Services available to you and to complete orders placed in our Services and with our Business Clients.
- To process transactions associated with your use of Services for which there is a charge, including to process payments and verify your identity or payment information for your security and protection.
- To communicate with you (e.g., about your account or updates to our terms) and to respond to inquiries related to support, employment opportunities, or other requests.
- To deliver marketing and promotional materials related to our Services in accordance with applicable laws, including information relating to our products, services, sales, marketing research or promotions.
- To provide you with personalized advertising on our Services based on your online activity. We use the information we have, to improve our advertising systems so we can show you relevant interest-based advertising, measure the effectiveness and reach of advertisements and services, verify delivery and track performance of an advertising campaign, and ensure that an ad is only delivered when a real person is visiting the site and that the same users don’t see the same ads too frequently. You may update your preferences regarding personalized advertising by visiting the Cookie Settings link in the footer of each site to manage your settings.
- To verify your entry into and eligibility to participate in contests, giveaways, or sweepstakes and inform you if you’ve won. If your entry information will be used for any other purposes, we will disclose that in the applicable rules governing that contest, giveaway, or sweepstakes.
- To monitor, improve, and conduct analytics on our Services and advertiser product offerings.
- For internal administrative purposes, such as safety and security of our Services, and to manage our relationships.
- To permit you to participate in social sharing, including live social media feeds and to implement Social Features you choose to use.
- The Apps in our Services may request to send you push notifications from time to time to update you about any events or promotions that we may be running. The Apps may also ask for your permission to access your camera and your photos. If you no longer wish to receive these types of communications, or if you’ve initially agreed for the application to access your camera and photos and you would like to stop the Apps from accessing them, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
- To detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity, including attempts to manipulate or violate our policies, procedures, and terms and conditions.
- To comply with legal obligations, to establish or exercise our rights, to defend against a legal claim, and to investigate, prevent, or take appropriate action regarding possible misconduct.
- For such other purposes not described in this Privacy Policy as you may consent (from time to time) and as otherwise permitted by law.
Methods Of Data Procesing
eLumpers takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to eLumpers, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by eLumpers. The updated list of these parties may be requested from the Owner at any time.
Transfers And Sharing Of Data
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with eLumpers using the information provided in the contact section.
eLumpers may store, process your personal data outside the European Union (EU)/European Economic Area (EEA). In this case, your personal data is processed in United States of America.
We may share your personal data with following recipients:
- Affiliates and Acquisitions. We may disclose your Personal Information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also disclose your Personal Information to that company using appropriate safeguards, including at the negotiation stage.
- Our Business Clients. When we collect information on behalf of our business clients, we disclose that information with those clients.
- Service Providers. We disclose your information to service providers. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, assist, or support our business operations and other administrative functions, process payments, and assist in the fulfillment of orders.
- Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by and/or associated with a third-party partner, then the information that you provide will be disclosed to them. Their use of your information is not governed by this privacy policy.
- Audience Measurement Services. We may disclose your Personal Information to audience measurement companies that help us and other websites measure and understand the audiences that view our content.
- Video Viewing Behavior. Consistent with applicable law, we may disclose your video viewing behavior with third parties including advertising companies, analytics partners, and social media sites.
- Aggregated and Anonymous Information. We may disclose aggregated, anonymous information with any third party. This information is not linked to Personal Information that can identify you or another individual person.
- Advertising. We may disclose certain data to Advertising Platforms, including Google and Social Networks such as Twitter, Facebook, LinkedIn, and Snapchat to allow us to target existing users and customers with highly relevant advertising campaigns. For the purposes of such campaigns. We may share a unique code (such as a hashed email address) with the applicable Advertising platform for that identifier to be matched against existing users of the relevant Advertising Platform and to identify potentially relevant audiences for targeted advertising.
- Public. Some of our Services may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on our Services, that information may be publicly available
Other Persons or Entities with Your Consent. With appropriate consent when required, certain Services may disclose your Personal Information with third party marketing partners, and they may contact you by email, telephone, postal mail or other common communication methods with marketing and promotional messages about their products or services. Sometimes we will give you the option to receive further communications from one of our advertising partners, for example when we run a competition with that advertiser. When you provide consent to receive communications from that third party advertiser, your personal information will be managed by that third party’s privacy policy. In some cases, we may also ask if you would like us to disclose your information to other third parties that are not described elsewhere in this Privacy Policy.
Retention Time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
- Personal Data collected for the purposes of a Contract between eLumpers and User shall be retained as long as there is a Contract between the parties.
- Personal data collected for the purposes of the Consent of the User will be retain for as long as User has given Consent.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
eLumpers may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Rights Under GDPR
Users may exercise certain rights regarding their Data processed by eLumpers. In particular, Users have the right to do the following:
- Access to Your Personal Information. You may request access to your Personal Information that we collect on our own behalf. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you.
- Changes to Your Personal Information. We rely on you to update and correct your Personal Information. Note that we may keep historical information in our backup files as permitted by law. If our Services do not permit you to update or correct certain information, contact us at the address described below. If we are processing your Personal Information on behalf of one of our clients, we will respond that we are operating as a Service Provider and are unable to act on your request.
- Deletion of Your Personal Information. When we collect information on our own behalf, we typically retain your Personal Information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your Personal Information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in some situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. If we are processing your Personal Information on behalf of one of our clients, we will respond that we are operating as a Service Provider and are unable to act on your request.
- Objection to Certain Processing. When we process information on our own behalf, you may object to our use of your Personal Information by contacting us at the address described below. For example, California residents may be entitled to object, or opt-out, of having their Personal Information sold to third parties. If you are a California resident and would like to opt-out of having your information sold. We do not discriminate against California consumers who exercise any of their rights described in this policy.
- Revocation of Consent. If you revoke your consent for the processing of Personal Information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
As required by law, we will require you to prove your identity for us to process your request. Depending on your request, we will require you to provide your name, phone number, and email address at the minimum. We may require additional information to verify your identity dependent upon the sensitivity of the personal information related to your request.
Changes Of This Privacy Policy
eLumpers reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to eLumpers. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities on the basis of the User’s consent, eLumpers shall collect new consent from the User, where required.
Latest update: March 08, 2023