Penny Tone, Inc., User Privacy Notice

Penny Tone is a communications company offering a variety of services to help businesses
        grow faster. Penny Tone does business in the United States as Penny Tone, Inc. ("Penny Tone"). This Privacy
        Notice sets
        forth details regarding the information Penny Tone collects from its Users, and from those who visit our website
        (www.pennytone.com).

Definitions

As used in this Privacy Policy, the below terms have the following meanings: 

"Applicable Law" – "Applicable Law" means the applicable state and
    federal laws which govern the collection, use, and administration of Personal Data.

"Data Subject" – A "Data Subject" is any Penny Tone User.

"Personal Data" – "Personal Data" is information relating to an
    identified or identifiable natural person. Examples include a name, an identification number, personal or
    business contact information, location data, an online identifier, and factors specific to the physical,
    physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Personal Data Breach" – "Personal Data Breach" means a breach of
    security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or
    access to, personal data transmitted, stored or otherwise processed.

"Process" – "Process" means any operation or set of operations that
    is performed on Personal Data, such as collecting, using, storing, sharing, and destroying Personal Data.

"User" – A "User" is any individual who inquires about, contracts
    for, and/or uses Penny Tone’s business communications services, or who visits Penny Tone’s website or uses Penny
    Tone
    products or services.


    The information we collect



    In most cases, Penny Tone, collects Personal Data directly from the User. When you inquire
    about Penny Tone’s services, we will collect your name, your business title, your business contact information
    (email, phone number, and address), your IP address(es) and browser information.



    When you use the "Submit a ticket" form located on the "Contact Us" page on our website, we ask you provide us
    with your first and last name, your email address, your contact phone number, and your Penny Tone account or phone
    number, as well as the details about your issue/request. If you use the "live chat" feature, we request your first
    and last name, your email address, and your contact phone number, as well as details about your request. We also
    record your IP address for web analytics to improve our product and experience. When you submit a request to
    receive Penny Tone’s newsletter or marketing materials, we will Process your email address.



    We may also Process Personal Data that we receive from third parties. When we receive Personal Data from a third
    party, we will let you know to the extent required by applicable laws or regulations.



    

        Aggregate and anonymous data. 
        We collect some information on an anonymous basis and may
        anonymize the personal information we collect about you into data groups. When we employ non-Penny Tone
        companies to anonymize or aggregate data on our behalf, the requirements of this Policy apply. We may share
        aggregate or anonymous information in various formats with trusted non-Penny Tone entities, with whom we have
        contracted to aggregate such data and may work with those entities to do research and provide products and
        services. When Penny Tone jointly provides a service with a non-­Penny Tone company, your Personal Information
        may
        be subject to both this Policy and the privacy policy of the non-Penny Tone company. We encourage you to review
        the privacy policies of any non-Penny Tone company with which you do business to determine what information
        will be collected and how it will be used or disclosed to others.
    

    

        Customer Proprietary Network Information. 
        Customer Proprietary Network Information (CPNI) is information Penny Tone obtains when providing
        telecommunications
        services. CPNI includes the types of telecommunications services purchased, how services are used, billing
        information related to those services, and calling details (for example, the time, length, and destination of
        calls placed).
    

    

        Cookies.
        We may use cookies or similar technologies to record or log data. For example, we may use cookies to keep you
        logged in to the PennyTone platform. Some of the cookies we use are associated with your PennyTone account
        (including
        personal information about you, such as the email address you gave us), and other cookies are not. Penny Tone
        also
        uses cookies to store information that can be used to serve ads relevant to your interests, and to help our
        advertisers measure the effectiveness of a particular advertisement. This helps us tailor ads to your interests.
        These cookies not only help us ensure that you do not repeatedly see the same ads, but (if you opt-out) they can
        also help us prevent you from seeing targeted ads at all.

        

            You may opt out of Penny Tone's use of data for internet-based advertising. Please keep in mind that even
            after you opt-out, you may still continue to see ads, but they will no longer be tailored to your
            interests. Opting-out also does not remove Penny Tone cookies. They will remain on your computer, but we
            will
            not use the data connected to your cookie for our services. Please note that if you delete your cookies,
            you will need to opt-out again to avoid being served targeted ads in the future. Users can control the use
            of cookies at the individual browser level. If you reject cookies, you may still use our site, but your
            ability to use some features or areas of our site may be limited.
        

        

            To opt out of the benefits of our targeted ads, click here: Disable Penny Tone Cookie (http://www.aboutcookies.org).
        
    

    

        Children’s data. 
        Penny Tone, Inc. does not knowingly process the Personal Data of anyone
        under the age of 18 (a "Child") without parental consent. If you are a parent or guardian and you are aware
        that your Child has provided us with Personal Data, please contact us at privacy@Penny Tone.com so that we may take appropriate steps to
        remove
        that information from our servers.
    

    

        Social Media. 
        Penny Tone uses social media accounts (LinkedIn, Facebook, Twitter, Instagram)
        to engage with the public. Our social media accounts are produced and maintained by Penny Tone’s communications
        team, sometimes working with service providers. Through our social media engagement we are able to provide
        customer support, engage with users interested in our products or services, respond to messages through the
        comment, message, or chat functions, collect aggregated information about interactions with our content on
        or through social media, analyze trends, and conduct social media listening of conversations about our
        company and our products and services. When you engage with us through our social media channels, the
        platform providers will also process information about you. For further information, please consult the
        privacy policy of the platform provider.
    



    Why we Process and how we use Personal Data



    We Process your Personal Data at your request and with your consent to allow you to determine whether to contract
    for our products or services, and to allow us to troubleshoot issues you are having and respond to your inquiries.



    When you purchase products or services from Penny Tone, or when you sign up to receive Penny Tone’s newsletter or
    marketing communications, we may contact you regarding similar services or products that we believe may be of
    interest to you. You may opt out of such communications at any time by clicking on the unsubscribe link located in
    the email from us.



    We may use your Personal Data for a variety of other legitimate business interests, including:



    
to provide services;
    
to analyze, maintain, and improve our business offerings;
    
to enhance your website experience;
    
internal recordkeeping, audits, and investigations;
    
insurance purposes;
    
to protect against and identify fraud and other criminal activity; and
    
to exercise or defend against legal claims.



    You are under no statutory or contractual obligation to provide Personal Data to Penny Tone.
    However, if you do not provide certain information, we may not be able to enter into a business agreement with
    you or process your request for assistance.



    With whom we share Personal Data



    Penny Tone employees: 
    Your Personal Data is shared internally among Penny Tone employees, as is appropriate to allow us to serve your
    business needs and respond to your requests. Penny Tone’s customer support centers are located in the United States,
    Mexico, Ukraine, and possibly other locations where our customer support team is remotely located. If you reach
    out to Penny Tone’s support centers, your Personal Data will be processed in one of those locations. While different
    locations have different laws regulating the treatment of personal information, Penny Tone, Inc. has policies and/or
    contracts in place requiring that any Personal Data shared with Penny Tone employees located outside of the United
    States be provided the same level of protection as if that Personal Data were processed in the United States.



    Others working for us: 
    We may share your information with service providers
    who help us run our business, including hosting our sites, delivering our emails and marketing communications
    to you, analyzing the data we collect, helping us with sales attribution (e.g., to see if we showed you an ad
    on a platform site and then you bought a product from us) and sending you the products and services you
    requested. We also share your information with lawyers, auditors, consultants, information technology and
    security firms, and others who provide services to us. We share only the personal information needed for these
    companies to complete the tasks we request. They are required to protect your information in the same way we
    do and will not share it or use it for any other purpose than to provide us services.


Other third parties:

    

        Law Enforcement.
        We may share your Personal Data with law enforcement, other government
        entities, or our legal counsel: (1) if we believe there has been a violation of our Terms & Conditions or
        other user policies; (2) if we believe that someone may be causing injury to our rights or property, other
        users, or anyone else; (3) to respond to judicial process or to provide information to law enforcement; or
        (4) as otherwise required by law. To the extent we are legally permitted to do so, we will take reasonable
        steps to notify you in the event that we are required to provide your personal information to third
        parties as part of a legal process.
    

    

        Corporate restructuring.
        If Penny Tone, Inc. is involved in a merger, acquisition, asset
        sale, or transition of service to another provider, as well as in the unlikely event of an insolvency,
        bankruptcy, or receivership, your Personal Data may be transferred outside of the organization, and
        outside of the United States. Should this occur, we will use reasonable efforts to inform you of the
        transfer and to ensure the transferee uses your information in a manner consistent with this Privacy
        Policy.
    



Penny Tone does not sell or share Personal Data with third parties for marketing purposes.

How we protect your Personal Data
We take the
    security of your data very seriously. We have established electronic and
    administrative safeguards, including data encryption and restricted personnel access, designed to secure the
    Personal Data we collect, to prevent unauthorized access to or disclosure of that information, and to ensure
    it is used appropriately. We also have internal policies and measures in place to ensure that your data is
    not
    lost, accidentally destroyed, misused or disclosed, and is not accessed by anyone other than employees of
    Penny Tone and the above-discussed third parties in the proper performance of their duties. These policies and
    measures are regularly reviewed and updated as appropriate.

Although we strive to keep your Personal Data secure, no security measures are absolute,
    and
    we cannot guarantee that your Personal Data will never be disclosed in a manner inconsistent with this
    Policy
    (for example, as the result of unauthorized acts by third parties that violate the law or this Policy). We
    will make reasonable attempts to notify you if we determine that Penny Tone has experienced a Personal Data
    Breach, unless we are not required to do so under Applicable Law.

Automated Processing

Penny Tone uses data and information about you to make relevant suggestions to you and
    others.
    We use the information and data that you provide and that we have about Users to make recommendations or
    provide guidance as far as customer sentiment that may be useful to you. For example, we use data and
    information about you and information that you provide to us to let you know how your customers are
    feeling
    about you.

Where we store and how long we retain Personal Data

Your Personal Data will be stored in a variety of places, including Penny Tone’s IT
    systems.
    Penny Tone will retain your Personal Data only for as long as is necessary for the purposes set out in this
    Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal
    obligations (for example, if we are required to retain your data to comply with applicable laws), resolve
    disputes, and enforce our legal agreements and policies. Penny Tone, Inc. will also retain Usage Data for
    internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when
    this
    data is used to strengthen the security or to improve the functionality of our Service, or we are legally
    obligated to retain this data for longer time periods.

Account Set-Up

When selecting usernames and passwords for Penny Tone accounts, you should choose words or
    characters that are not obvious. Likewise, you should always keep Personal Information such as account
    numbers, usernames, passwords or similar information in a secure place and not share the information with
    others.

Third Party API Integration

Penny Tone products allow for the integration with third party Application Programming
    Interfaces (API) in order to provide consolidated communications through our platform. These APIs include
    those provided by Google and Microsoft. Integration with third party APIs is always optional and can be
    disconnected at any time, though some features within Penny Tone will be limited without this integration.
    Please
    note also: the process of accessing your Google and Microsoft accounts is configured through the use of
    OAuth
    to ensure that at no time does Penny Tone have access to your password for these services.

Penny Tone's use and transfer to any other app of information received from Google will
    adhere
    to the Google
        API Services User Data Policy, including the Limited Use requirements.

Calendar Integration

You can connect the Penny Tone platform with your calendar to make scheduling easier and
    more
    efficient. There are two types of calendars: online and offline. Online calendars like Google and
    Microsoft
    365 calendar are always available via their respective interfaces. With your permission, Penny Tone can store
    certain calendar data temporarily to improve performance (caching), modify Calendar events, upload files
    on
    your behalf to the Google Drive, and share Calendar information with other registered users of the Penny Tone
    platform. In either case, calendar data on the Penny Tone platform can be deleted at any time.

Email Integration

You can connect the Penny Tone platform with email accounts provided by one or more
    external
    providers, including Microsoft and Gmail. We allow you to connect your Microsoft or Gmail account in
    Penny Tone
    for the sole purpose of centralizing your communication channels in one place, making it easier to use
    email
    to communicate with your customers and to keep your emails organized along with other ways that you
    communicate with your customers, such as using Penny Tone Voice, SMS/MMS, Video, or Chat. We will never use
    your
    Microsoft or Gmail account to send Penny Tone marketing nor will we ever share your Microsoft or Gmail
    account
    with any entity outside of Penny Tone. We may send Penny Tone platform notifications if you have configured this
    as
    a preferred way to receive notifications outside of the Penny Tone web and mobile applications. The
    integration
    with Microsoft or Gmail accounts can be disconnected at any time, and when disconnected, email content
    associated with these integrations will also be removed from our system within a reasonable time period
    required to process said data.

Your rights

You have certain rights in respect of your information. In particular, you may have a
    right
    of access and correction. If you wish to exercise these rights, please submit the requested information at
    https://www.pennytone.com/x/ccpa-form/ or call us at (310) 409-0570.


Important Information for Nevada Residents

Residents of the State of Nevada may opt out of the sale of their Personal Information.
    Penny Tone does not, however, sell Personal Information of any person, including those under the age of 16.


Changes to this Privacy Policy

We reserve the right to update this Privacy Policy as necessary to reflect any changes
    we
    make and to satisfy legal requirements.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, or to exercise
    your privacy rights please reach out to privacy@Penny Tone.com.

Last Updated: April 14, 2022

Penny Tone^® CCPA Privacy Notice

This Privacy Notice supplements the information contained in the Penny Tone^® Privacy Policy, available at https://www.pennytone.com/privacy-policy.html and applies solely to visitors, users and others who reside in the State of California (“consumers”, “you” or “your”). Penny Tone, Inc. (“we”, “us” or “our”) adopts this notice in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms contained herein shall have the same meaning as set forth in the CCPA.

I. Personal Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information” or “PI”). Specifically, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Personal Information does not include publicly available information, consumer information that is de-identified or aggregated, and information that is excluded from CCPA’s scope, such as protected health information covered by the Health Insurance Portability Act of 1996 (HIPAA) and personal information covered by certain sector-specific privacy laws including the Fair Credit Reporting Act and the Gramm-Leach-Bliley Act. We will not collect additional categories of Personal Information without providing you with notice.

II. SOURCES OF PERSONAL INFORMATION

We obtain the categories of Personal Information listed, as detailed in Section I of this Notice, from the following categories of sources:

• From you and/or your agents. Penny Tone collects Personal Information directly from you through all forms of direct communication, including, but not limited to, email, fax, telephone, text, chat, surveys and questionnaires, webforms, and first party tracking technologies on our website.
• Ad networks. Penny Tone collects Personal Information about consumers that visit Penny Tone’s Website through third party cookies and other tracking technologies, from online advertising and other media advertising.
• Consumer data resellers. Penny Tone collects Personal Information about consumers from data resellers and lead generation services.
• Sales and marketing partners. Penny Tone collects Personal Information about consumers through Penny Tone’s channel partners, agents, affiliates, and other sales and marketing partners and service providers, including through trade shows, customer engagement, communication service providers and tools, and by other methods.
• Social media. Penny Tone collects Personal Information about consumers through social media (including, but not limited to posts) and business intelligence services.
• Recruiting services. Penny Tone collects Personal Information about job candidates through employment Web sites, recruiters, personality assessment services, and background check services.
• Commercial. Penny Tone maintains records of its commercial or employment relationship with you, including products offered for sale or purchase, patterns of usage of our services, and customer support cases.

III. USE OF PERSONAL INFORMATION

Penny Tone’s use of Personal Information is limited to that which is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or processed or for other operational purposes that is compatible with the context in which the Personal Information was collected. Penny Tone uses Personal Information, as detailed in Section I of this Notice, for the following Business Purposes and Commercial Purposes.

• Providing Services.
  • To initiate, assess, develop, deliver, and/or maintain quality and features of the Website, products and services provided by Penny Tone;
  • To improve, develop and enhance our products and services and for statistical and historical research, analytics and business intelligence;
  • To test and evaluate new products and conduct research for technological development and demonstration;
  • To send transactional communications (such as requests for information, responses to requests for information, orders, confirmations, and service updates);
  • Disaster recovery and business continuity, including transferring the information to a storage facility; and,
  • Debugging to identify and repair errors that impair existing intended functionality.
• Account Management.
  • Performing customer support;
  • Maintaining and servicing accounts;
  • Fulfilling orders and transactions, verifying customer information, and processing payments;
  • Performing accounting, finance, and dispute resolution purposes (such as accounts receivable and accounts payable) and for reporting;
• Auditing.
  • Internal audits and investigations and external audits;
  • To ensure quality control and to enforce company standards and policies;
  • Implementation and verification of business controls;
  • Verifying compliance with legal, regulatory, and contractual requirements;
  • Management and audit of Penny Tone’s service providers, partners, suppliers, and vendors;
  • For risk management and mitigation, including for audit and insurance functions, and as needed to license and protect intellectual property and other assets; and,
  • Assessment of advertising, referrals, and sales and marketing programs.
• Security Management.
  • Monitoring individuals with access to Penny Tone’s websites, applications, systems, or facilities, investigation of threats, and as needed for any Data Security Breach notification; and,
  • To investigate and prevent unauthorized access, protecting against malicious, deceptive, fraudulent or illegal activities related to the Website or the products and services provided by Penny Tone, and prosecuting those responsible for that activity.
• Human Resources Management.
  • Penny Tone collects Personal Information from employees, contractors, and applicants for legal and regulatory compliance and reporting;
  • Provide compensation and benefits, including insurance and statutory benefits;
  • Assess characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;
  • Provide and assess training.
  • Verification of employment, including for housing approvals, reference checks, loan approvals, and unemployment insurance;
  • Emergency contact information;
  • Engagement surveys; and,
  • H1B and other visa processes.
• Commercial Transactions.
  • Penny Tone may use Personal Information for relationship management and marketing. This purpose includes sending marketing and promotional communications to individuals who have not opted out of receiving such messages as may be appropriate given the nature of the relationship, such as product and service marketing, customer communications, customer satisfaction surveys, supplier communications, and Penny Tone news. Penny Tone may use pictures, recordings, and likenesses of employees, contractors, customers, and partners, with consent, for promotional and training purposes;
  • Penny Tone may use your Personal Information to communicate with you. We may contact you regarding products or services you have expressed an interest in. We may also contact you with offers for additional services we think you will find valuable if you give us consent, or where allowed based upon legitimate interests; and,
  • Penny Tone may use your Personal Information to develop inferences about products and services that may interest you, your experiences with the Website and Penny Tone’s products and services, or Penny Tone’s departments and organization, and to customize advertising and your experience using the Website and Penny Tone services.
• Other Uses.
  • Penny Tone may use your Personal Information to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As otherwise described to you when collecting your personal information or as otherwise set forth in the CCPA or the Penny Tone Privacy Policy.

We will not use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you with notice.

IV. SHARING OF PERSONAL INFORMATION

Penny Tone shares Personal Information, as detailed in Section I of this Notice, with the following categories of third parties for business and commercial purposes:

• Sales and Marketing. Sales channel partners, ad networks, commission management service providers, customer engagement services, and other related service providers.
• Recruiters. Job Posting Websites, Personality and Psychological Assessment Services, Recruiters and Background Check Services
• Financial Services. Payroll Service Providers, Travel Management Service Providers and Commission Management Service Providers, Accounting Services, Financial Institutions, Clearing Houses, Compliance Services and Auditors, Card Payment Processors and Enterprise Resource Planning (ERP) Services and Collection Agencies
• Human Resources. Employee Insurance and Benefit Service Providers and Partners
• Service Providers. Subcontractors, service installation partners, service providers and partners providing components of Penny Tone’s commercial service offerings, including message transcription, voice recognition, email gateways, analytics and inference generation, telecom services, SMS messaging services, data center and cloud storage and hosting service providers, multimedia services, video conferencing services, e911 services, hardware sales, rental, fulfillment and shipping services, and other products and services that Penny Tone may offer through partners currently or in the future.
• Other Third Parties. Third parties that may receive Personal Information from Penny Tone under special circumstances or for legal or compliance reasons.

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business or commercial purpose:

Category A: Identifiers

Category B: Personal Information Described in Cal. Civ. Code §1798.80(e)

Category C: Characteristics of Protected Classifications under California or Federal Law

Category D: Commercial Information

Category F: Internet of Other Electronic Network Activity Information

Category G: Geolocation Data

Category H: Sensory Data

Category I: Employment

Category K: Inferences

In the preceding twelve (12) months, we have not sold any Personal Information.

V. YOUR RIGHTS AND CHOICES

A. Right to Know About Personal Information Collected.

Up to twice in a twelve-month period, you may request that we disclose information about our collection and use of your Personal Information. This right excludes contractors, employees and job applicants of Penny Tone, and any person acting on behalf of a business providing a product or service to, or evaluating or receiving a service from Penny Tone. Upon our receipt and confirmation of a verified consumer request, we will disclose the following:

1. The categories and specific pieces of Personal Information we collected about you;
2. The categories of sources for the Personal Information we collected about you;
3. Our business and commercial purpose for collecting or selling your Personal Information;
4. The categories of third parties with whom we shared Personal Information about you;
5. If we sold your Personal Information, a list identifying the Personal Information categories that each category of recipient purchased; and,
6. If we disclosed your Personal Information for a business purpose, a list identifying the Personal Information categories that each category of recipient obtained.

B. Right to Request Deletion of Personal Information.

You have the right to request that we delete the Personal Information we have collected about you. This right excludes contractors, employees and job applicants of Penny Tone, and any person acting on behalf of a business providing a product or service to, or evaluating or receiving a service from Penny Tone. Upon our receipt and confirmation of a verified consumer request, subject to the following exclusions, we will delete your Personal Information from our records by:

1. Permanently and completely erasing the personal information on its existing systems with the exception of archived or back-up systems;
2. De-identifying the personal information; or
3. Aggregating the personal information.

Penny Tone will also direct our service providers to delete your Personal Information. Deleting data from backup systems may be delayed.

We may deny your request if retaining your Personal Information is necessary for us or our service providers to:

1. Complete the transaction for which the Personal Information was collected, provide a good or service that you requested, take reasonably anticipated actions within the context of our ongoing business relationship with you; perform any contract between Penny Tone and you;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and/or prosecute those responsible for that activity;
3. Debug to identity and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of your Personal Information may likely render impossible or seriously impair the research’s achievement, provided that you previously provided informed consent;
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
8. Comply with a legal or regulatory obligation; and,
9. Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the Personal Information.

If we are unable to honor your request to delete Personal Information, Penny Tone will not use your Personal Information for any other purpose than the reason(s) that the Personal Information was not deleted.

C. Right to Opt-Out of the Sale of Personal Information.

Penny Tone does not sell Personal Information of any consumer, including those under the age of 16. Penny Tone also does not provide Personal Information to third-parties for their own marketing purposes. If Penny Tone does engage in the sale of your Personal Information in the future, it will provide you with notice by updating these policies and you may opt out of the sale of your Personal Information.

D. Authorized Agent.

You have the right to authorize an agent to make Right to Know requests on your behalf. You must provide the agent with a power of attorney or written permission to act on your behalf. You must still verify your identity directly with Penny Tone. You may also make a verifiable consumer request on behalf of your minor child.

E. How to Make a Request.

In order to make a request, you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may submit a verifiable consumer request by either:

1. Calling Penny Tone at: (310) 409-0570

You will be required to provide information to allow Penny Tone to verify your identity and validate your request. You will be required to provide at least two (2) pieces of personal information maintained by Penny Tone. Authorized users on established accounts will be required to provide their account PIN. Non-account holders will be required to provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. In order to validate your request, Penny Tone will attempt to confirm you are the owner of the identifiers provided.

Penny Tone endeavors to respond to a verifiable consumer request within forty-five (45) days of its receipt of the request. If we require more time (up to ninety (90) days, we will inform you of the reason and extension period in writing. We will deliver our written response to you by mail or electronically, at your option. Any disclosures that we provide will only cover the twelve (12) month period immediately preceding our receipt of your verifiable consumer request. The response will explain the reasons that we cannot comply with your request, if applicable. Where you request the specific pieces of Personal Information that we have collected about you (a data portability request), we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another without hindrance.

Penny Tone may not fulfill your request if we cannot verify your identity with a reasonably high degree of certainty. Personal Information collected as part of the request process will be used for the purpose of validating and fulfilling the request and will be retained by Penny Tone for at least two (2) years. Making a verifiable consumer request does not require you to create an account with us.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

F. Right To Non-Discrimination for the Exercise of a Consumer’s Privacy Rights.

Penny Tone does not discriminate against consumers for exercising any of their CCPA rights. Unless permitted by the CCPA, we will not:

1. Deny you goods or services;
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
3. Provide you a different level of quality of goods or services; or,
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

VI. CHANGES TO THIS CCPA PRIVACY POLICY

We reserve the right to amend this Notice, as well as the Penny Tone Privacy Policy that this Notice supplements. When we make changes to this Notice, we will notify you by email or through a notice on our Web site.

VII. OTHER IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS

A. California’s “Shine the Light” Law.

California Civil Code Section 1798.83 permits users of Penny Tone’s Website who are California Residents to request and obtain from us a list of what personal information (if any) we shared with third parties or corporate affiliates for those entities' direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties.

If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 9451 East Via de Ventura, Scottsdale, AZ 85256. For all requests, you must put the statement "California Privacy Rights Notice" in the body of your request, as well as your name, street address, city, state, and zip code. You also need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

B. California Do Not Track Disclosures.

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how a website operator responds to "Do Not Track" (DNT) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks, and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, please visit: https://allaboutdnt.com.

VIII. CONTACT INFORMATION

If you have questions about this Notice, the Penny Tone Privacy Policy, the ways we collect and use your Personal Information, your choices and rights regarding your Personal Information and our use of that information, you may email us at privacy@Penny Tone.com or write to us at 9451 East Via de Ventura, Scottsdale, Arizona 85256.

Last Updated: January 14, 2022

Penny Tone, Inc. Prospective Employee Privacy Policy

Introduction

Penny Tone is a communications company offering a variety of services to help businesses grow faster. Penny Tone does business in the United States as Penny Tone, Inc. (“Penny Tone”). This Privacy Policy (the “Policy”) identifies and describes the way Penny Tone ("Penny Tone" or “we”, “us”, or “our”) uses and protects the information we collect about those who are applying for employment (“Prospective Employee(s)”, “you”, or “your”). All Prospective Employees of Penny Tone are subject to this Privacy Policy.

This Policy applies to all Prospective Employees. By visiting this website or submitting an application for employment,Prospective Employees agrees to this Policy.

Definitions

As used in this Policy, the terms listed below have the following meanings:

1. Prospective Employee - A "Prospective Employee" is anyone who visits our website, www.pennytone.com, submits an application for employment, participates in an interview for employment, or otherwise participates in Penny Tone’s recruiting process.
2. Personal Data - "Personal Data" is information that directly or indirectly identifies or reasonably can be used to identify an individual Customer or User. Examples include name, contact information (personal or business address, telephone number, and e-mail address), government identification number, or other information that you may voluntarily submit to us in your resume.
3. Anonymous Data - "Anonymous Data" means information that does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable.
4. Aggregate Data - "Aggregate Data" means information about groups or categories of Visitors, which information does not identify and cannot reasonably be used to identify an individual Visitor. Aggregate Information is a kind of Anonymous Information.
5. Data Subject - A “Data Subject” is any Prospective Employee.
6. Personal Data Breach - “Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
7. Process - “Process” means any operation or set of operations that is performed on Personal Data, such as collecting, using, storing, sharing, and destroying Personal Data.

What Personal Data does Penny Tone collect?

The information we collect

In most cases, Penny Tone collects your information and Personal Data directly from you. For example, we will ask you for Personal Data when you interact with us, such as when you interact through us through our website via submitting an application for employment, requesting information on our company, signing up to receive a report, or newsletter. For example, Penny Tone collects Prospective Employees’ information (including Personal Data) to help us contact you with regard to your inquiries and applications regarding potential employment.

We use cookies to collect information about your use of our websites and applications. We treat this information as Personal Data when it is associated with your contact information. For more information about cookies, please see the section Cookies below.

• Aggregate and anonymous data We collect some information on an anonymous basis and may anonymize the personal information we collect about you into data groups. When we employ non-Penny Tone companies to anonymize or aggregate data on our behalf, the requirements of this Policy apply. We may share aggregate or anonymous information in various formats with trusted non-Penny Tone entities, with whom we have contracted to aggregate such data and may work with those entities to do research and provide products and services. When Penny Tone jointly provides a service with a non­Penny Tone company, your Personal Information may be subject to both this Policy and the privacy policy of the non-Penny Tone company. We encourage you to review the privacy policies of any non-Penny Tone company with which you do business to determine what information will be collected and how it will be used or disclosed to others.
• Cookies We may use cookies or similar technologies to record or log data. Penny Tone also uses cookies to store information that can be used to serve ads relevant to your interests, and to help our advertisers measure the effectiveness of a particular advertisement. This helps us tailor ads to your interests. These cookies not only help us ensure that you do not repeatedly see the same ads, but (if you opt-out) they can also help us prevent you from seeing targeted ads at all.
  
  You may opt out of Penny Tone's use of data for internet-based advertising. Please keep in mind that even after you opt-out, you may still continue to see ads, but they will no longer be tailored to your interests. Opting-out also does not remove Penny Tone cookies. They will remain on your computer, but we will not use the data connected to your cookie for our services. Please note that if you delete your cookies, you will need to opt-out again to avoid being served targeted ads in the future. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. To opt out of the benefits of our targeted ads, click here: Disable Penny Tone Cookie.
• Children’s data Penny Tone, Inc. does not knowingly process the Personal Data of anyone under the age of 18 (a “Child”) without parental consent. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us at privacy@Penny Tone.com so that we may take appropriate steps to remove that information from our servers.
• Social Media Penny Tone uses social media accounts (LinkedIn, Facebook, Twitter, Instagram) to engage with the public. Our social media accounts are produced and maintained by Penny Tone’s communications team, sometimes working with service providers. Through our social media engagement we are able to provide customer support, engage with users interested in our products or services, respond to messages through the comment, message, or chat functions, collect aggregated information about interactions with our content on or through social media, analyze trends, and conduct social media listening of conversations about our company and our products and services. When you engage with us through our social media channels, the platform providers will also process information about you. For further information, please consult the privacy policy of the platform provider.

Why we Process and how we use Personal Data

If you apply for a job through the Penny Tone website, we, or a third party processor (such as a human resources company) assisting us, may ask you to provide self-identifying information in conjunction with laws and regulations enforced by local government and regulatory agencies. Providing self-identifying information is voluntary, but if you do provide us with that information, we may submit it to the local government and regulatory agencies for business-related purposes, including responding to information requests, fulfilling regulatory reporting requirements, and defending against employment related complaints. We will seek references and criminal background information only after a conditional offer of employment has been made to you, and we will inform you before doing so.

We strongly believe in both minimizing the Personal Data we collect and limiting its use and purpose to only that: (1) we have your consent; (2) we need it to perform a contractual obligation with you; (3) we are legally obligated to collect/process the info; (4) we need it to protect the your vital interests; (5) we need for the public interest; or (6) legitimate interests (using the Personal Data in a way that you would expect).

Penny Tone also uses Prospective Employees’ information to gather analysis or valuable information so that we can improve our candidate process, to monitor the usage of our Website, to detect, prevent and address technical issues, to investigate and prevent unauthorized access and fraudulent or illegal activities related to the Website or the products and ervices provided by Penny Tone.

We may use your Personal Data for a variety of other legitimate business interests, including:

• to provide services;
• to analyze, maintain, and improve our business offerings;
• to enhance your website experience;
• internal recordkeeping, audits, and investigations;
• insurance purposes;
• to protect against and identify fraud and other criminal activity; and
• to exercise or defend against legal claims.

You are under no statutory or contractual obligation to provide Personal Data to Penny Tone. However, if you do not provide certain information, we may not be able to consider you as a prospective employee.

With whom we share Personal Data

Penny Tone employees: Your Personal Data is shared internally among Penny Tone employees, as is appropriate to allow us to serve your business needs and respond to your requests. Penny Tone’s affiliate and subsidiaries are located in the United States, Mexico, Ukraine, Canada and possibly other locations where our customer support team is remotely located. If you apply for a position in a Penny Tone affiliate or subsidiary, your Personal Data will be processed in one of those locations. While different locations have different laws regulating the treatment of personal information, Penny Tone, Inc. has policies and/or contracts in place requiring that any Personal Data shared with Penny Tone employees located outside of the United States be provided the same level of protection as if that Personal Data were processed in the United States.

Others working for us: We may share your information with service providers who help us run our business, including hosting our sites, delivering our emails and marketing communications to you, analyzing the data we collect, helping us with sales attribution (e.g., to see if we showed you an ad on a platform site and then you bought a product from us) and sending you the products and services you requested. We also share your information with lawyers, auditors, consultants, information technology and security firms, and others who provide services to us. We share only the personal information needed for these companies to complete the tasks we request. They are required to protect your information in the same way we do and will not share it or use it for any other purpose than to provide us services.

Other third parties:

• Law Enforcement. We may share your Personal Data with law enforcement, other government entities, or our legal counsel: (1) if we believe there has been a violation of our Terms & Conditions or other user policies; (2) if we believe that someone may be causing injury to our rights or property, other users, or anyone else; (3) to respond to judicial process or to provide information to law enforcement; or (4) as otherwise required by law. To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of a legal process.
• Corporate restructuring. If Penny Tone, Inc. is involved in a merger, acquisition, asset sale, or transition of service to another provider, as well as in the unlikely event of an insolvency, bankruptcy, or receivership, your Personal Data may be transferred outside of the organization, and outside of the United States. Should this occur, we will use reasonable efforts to inform you of the transfer and to ensure the transferee uses your information in a manner consistent with this Privacy Policy.

Penny Tone does not sell or share Personal Data with third parties for marketing purposes.

How we protect your Personal Data

We take the security of your data very seriously. We have established electronic and administrative safeguards, including data encryption and restricted personnel access, designed to secure the Personal Data we collect, to prevent unauthorized access to or disclosure of that information, and to ensure it is used appropriately. We also have internal policies and measures in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed by anyone other than employees of Penny Tone and the above-discussed third parties in the proper performance of their duties. These policies and measures are regularly reviewed and updated as appropriate.

Although we strive to keep your Personal Data secure, no security measures are absolute, and we cannot guarantee that your Personal Data will never be disclosed in a manner inconsistent with this Policy (for example, as the result of unauthorized acts by third parties that violate the law or this Policy). We will make reasonable attempts to notify you if we determine that Penny Tone has experienced a Personal Data Breach, unless we are not required to do so under Applicable Law.

Automated Processing

We may use automated screening tools to verify that an application meets the minimum requirements for the position, as indicated in the job posting.

Where we store and how long we retain Personal Data

Your Personal Data will be stored in a variety of places, including Penny Tone’s IT systems. Penny Tone will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Penny Tone, Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Account Set-Up

When selecting usernames and passwords for Penny Tone accounts, you should choose words or characters that are not obvious. Likewise, you should always keep Personal Information such as account numbers, usernames, passwords or similar information in a secure place and not share the information with others.

Your rights

You have certain rights in respect of your information. In particular, you may have a right of access and correction. If you wish to exercise these rights, please call us at (310) 409-0570.

Important Information for Nevada Residents

Residents of the State of Nevada may opt out of the sale of their Personal Information. Penny Tone does not, however, sell Personal Information of any person, including those under the age of 16.

Changes to the this Privacy Policy

We reserve the right to update this Privacy Policy as necessary to reflect any changes we make and to satisfy legal requirements.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, or to exercise your privacy rights please reach out to privacy@Penny Tone.com.

Last Updated: May 06, 2022

Transparency in Coverage

This link leads to the machine readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.

Last Updated: June 16, 2022