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Privacy Policy

Last updated: October 12, 2021

SoftLedger (“Soft Ledger, Inc.”, “SoftLedger”, “we” or “us”) is respects and understands the privacy of our customers and those who use our websites, (the “Site”), and our products and services, including our cloud-based products or services, online and mobile applications and add-ons (the “Services”). This Privacy Notice describes SoftLedger’s policies and practices regarding our collection and use of your personal data or information and sets forth your privacy rights. We will from time to time update this Privacy Notice as we adopt new privacy practices and policies in response to updates in the law, to align with changing industry best-practices, and to reflect our product enhancements.

This Privacy Notice covers the following:

Types Of Information We Collect

Use And Processing Of Information

Sharing Of Information

Your Choices

How We Protect Personal Information

How Long We Store Your Information.

International Data Transfers

Other Important Information

Jurisdiction Specific Provisions

Types Of Information We Collect

The following provides examples of the type of information that we collect from you and how we use that information.

ContextTypes of DataPrimary Purpose for Collection and Use of Data
Customer InformationWe collect the name, username, and contact information, of our customers with whom we may interact.We have a legitimate interest in contacting our customers and communicating with them concerning normal business administration such as projects, services, and billing.
Customer User Account informationWe collect personal data from our customers when they create an account to access and use the Services or request certain free Services from our Site. This information could include business contact information such as name, email address, title, company information, and password for our services.We have a legitimate interest in providing account related functionalities to our users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, we use this information to fulfill our contract to provide you with Services.
Customer User Business DataUsers of our Services may store data inside your SoftLedger account, whether entered manually, through an import, via the SoftLedger API, through an integration, or by any other means (“Business Data”). This Business Data includes, but is not limited to a user’s, customer, vendor, employee, other contact information, financial transactions, tasks, and custom data. When you integrate SoftLedger with other systems (including, but not limited to QuickBooks, Binance, Poloniex, Yodlee), personal and financial information will sync with your SoftLedger account, at which point SoftLedger treats this data as your Business Data.We have a legitimate interest in collecting Business Data on behalf of our customers in order to fulfill our contract to provide Services.
Vendor User InformationWe collect personal data from a customer’s vendors when they create an account to access and use the Services or request certain free Services from our Site. This information could include business contact information such as name, email address, title, company information, and password for our services.We have a legitimate interest in providing account related functionalities to our vendor-users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, in some cases, we use this information to fulfill our contract to provide vendor-users with Services.
Cookies and first party trackingWe use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookie Policy for more information.We have a legitimate interest in making our website operate efficiently.
Demographic InformationWe collect personal information, such as your age or location. We have a legitimate interest in understanding our users and providing tailored services.
Email InterconnectivityIf you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.We have a legitimate interest in understanding how you interact with our communications to you.
EmploymentIf you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations.
Feedback/SupportWe collect personal data from you contained in any inquiry you submit to us regarding our Site or Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support requests, or to report an issue. When you communicate with us over the phone, your calls may be recorded and analyzed for training, quality control and for sales and marketing purposes. During such calls we will notify you of the recording via either voice prompt or script.We have a legitimate interest in receiving, and acting upon, your feedback, issues, or inquiries.
Mailing ListWhen you sign up for one of our mailing lists we collect your email address or postal address.We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.
Order PlacementWe collect your name, billing address, e-mail address, phone number, and credit card number when you place an order.We use your information to perform our contract to provide you with products or services.
SurveysWhen 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 applies to the collection, use, and disclosure of your information.We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.
Website interactionsWe use technology to monitor how you interact with our Site. 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.We have a legitimate interest in understanding how you interact with our Site to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Web logsWe collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.We have a legitimate interest in monitoring our networks and the visitors to our Site. Among other things, it helps us understand which of our services is the most popular.
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.  For example, if you submit a job application, or become an employee, we may conduct a background check. Use And Processing Of Information In addition to the purposes and uses described above, we use information in the following ways:
  • to identify you when you visit our Site.
  • to provide our Services.
  • to improve our Services and offerings.
  • to promote the security of our Site and Services.
  • to conduct analytics.
  • to respond to inquiries related to support, employment opportunities, or other requests.
  • to send marketing and promotional materials including information relating to our products, services, sales, or promotions, or those of our business partners.
  • for internal administrative purposes, as well as to manage our relationships.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.  For example, if you sign up for Services, we may collect your information to complete that transaction, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your Services.  As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business. Sharing Of Information In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
  1. Affiliates and Acquisitions. We may share information with our corporate affiliates (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 share information with that company, including at the negotiation stage.
  2. Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
  3. Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
  4. Public. Our Site offers a community forum and a blog in which you may post information on a publicly accessible site.  If you decide to submit information on these pages, that information may be publicly available. You have the right to post anonymously as there is no identifiable information tied to a post other than your chosen username.  Similarly, we may make available on our Site, or link to, features that allow you to share information online (e.g., SoftLedger community). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online, you may receive unsolicited messages from other parties.
  5. Service Providers. We share your information with service providers. Among other things service providers help us to administer our Site, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
Your Choices. SoftLedger uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run SoftLedger products, services and websites. Although SoftLedger Integration Incorporated owns the code, databases, and all rights to SoftLedger products, you retain all rights to your data. You can make the following choices regarding your personal information:
  1. Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. We will provide this information in a portable format, if required.  Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
  2. Changes To Your Personal Information. We rely on you to update and correct your personal information. Our Site allows you to modify or delete your account profile.  If our Site does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
  3. Deletion Of Your Personal Information. Typically we 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 or to provide the Services. SoftLedger will retain account information which is required to substantiate our financial reporting to the Canada Revenue Agency and the United States Internal Revenue Service, for at least seven years after our business relationship ends. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. 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 many 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.
  4. Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
  5. Online Tracking. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we currently do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
  6. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive promotional emails, we may still send you service related communications.
  7. 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.
Please address written requests and questions about your rights to or call us at 1-800-682-1707. Note that, as required by law, we will require you to prove your identity.  We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files. In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  We will require verification that you provided the authorized agent permission to make a request on your behalf.  You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.  If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
  1. A completed written notice indicating that you have authorization to act on the consumer’s behalf signed by you and the consumer.
  2. If you are a business, proof that you are registered with the appropriate Secretary of State to conduct business in California.
If we do not receive both pieces of information, the request will be denied. How We Protect Personal Information The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it.  However, no method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law. Our Site permits you to create an account.  When you do you will be prompted to create a password.  You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you.  You should notify us of any unauthorized use of your password or account How Long We Store Your Information. Generally, we will hold your personal data for as long as you are a customer and use the Site and/or our services to ensure accuracy and to help maintain quality of service or if we are obliged to retain such information for legal, regulatory, fraud prevention and legitimate business purposes. We are obliged by law to retain AML-related identification and transaction records for six years from the date of the transaction. Other information will be retained for no longer than is necessary for the purpose for which it was obtained by us or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes. In general, we (or our service providers on our behalf) will hold this information for a period of seven years, unless we are obliged to hold it for a longer period under law or applicable regulations. We will review your personal data regularly to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment exercise or defense of legal claims. When it is no longer necessary for us to hold your personal data, we will securely destroy it in accordance with applicable laws and regulations. International Data Transfers SoftLedger is located in the United States.  Our service providers and other third parties you may interact with in connection with our Services may be may be located in the United States and other countries around the world. As a result your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country.  Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information.  By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.  To the extent personal information is collected and subsequently transferred out of the European Economic Area, the transfer will take place consistent with the Standard Contractual Clauses. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below. Other Important Information The following additional information relates to our privacy practices:
  • Information for California Residents. California law indicates that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law).  You can find a list of the categories of information that we collect and share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the “Contact Information” section below.  We do not discriminate against California residents who exercise any of their rights described in this Privacy Notice.
  • Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.  While our Sites may contain links to and from the websites of our partner networks, advertisers, and affiliates, if you follow a link to any of these websites, please note that these websites have their own privacy policies. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
  • Conflict Between This Privacy Notice and our Terms of Service or Other Terms. Where there is a conflict between this Privacy Notice and an explicit provision of the Terms of Service or the Website Terms related to our Processing Services, this Privacy Notice will prevail over those other Terms.
  • Changes To This Privacy Notice. We may change our Privacy Notice and practices over time.  To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new Privacy Notice.  Our Privacy Notice 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 Privacy Notice was last substantively modified.
  • If you are visually impaired, you may access this notice through your browser’s audio reader.
  • SoftLedger does not knowingly collect personal data from children under the age of thirteen (13). If we learn that we have collected Personal Information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us Personal Information, please contact us at By using the Site, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services through the Site.
  • Phishing and False Emails. If you receive an unsolicited email that appears to be from us or one of our Partners or third parties that requests your personal information (such as personal identifiers, credit card number, SoftLedger login, or password), or that asks you to verify or confirm your account or other personal information by clicking on a link, that email was likely to have been sent by someone trying to unlawfully obtain your information. This is sometimes referred to as “phishing” or “spoofing.” We do not ask for this type of information in an email. Do not provide the information or click on the link. If you receive any suspected phishing or spoofing emails, please report it to
Contact Information.  If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below.  We will attempt to respond to your requests and to provide you with additional privacy-related information. Attn: Privacy Team Soft Ledger, Inc., 202 Bicknell Ave, Ground Floor Santa Monica, CA 90405 If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority. Jurisdiction Specific Provisions The following may apply to you depending on where you are located. EEA To exercise your rights, you may contact us as set forth in the Contact Us section of our Privacy Notice.  If you are a resident of the EEA or we have identified SoftLedger Holdings Limited as your data controller, and believe we process your information in scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Office of the Data Protection Commissioner. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. United States Nevada.  This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing customers, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by emailing us at or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email: Texas.  If you have a complaint, first contact SoftLedger, Inc., by visiting our website at If you still have an unresolved complaint regarding the company’s money transmission or currency exchange activity, please direct your complaint to the Texas Department of Banking: 2601 North Lamar Boulevard, Austin, TX 78705-4294; 1-877-276-5554 (toll free); Virginia. This Section is only applicable to you if you are a resident of the state of Virginia in the US (“Virginia Residents”).   If you have a complaint, first contact us by visiting our Site at or contacting as set out in our Contact Us section below. We will respond within 45 days of receipt of your request, and such time may be extended for an additional 45 days if it is reasonably necessary.  We will notify you of any extension within the initial 45-day period.  If you are not satisfied with our responses, you have the right to appeal.  We will respond within 60 days of receipt of your appeal.  If you still have an unresolved complaint, please direct your complaint to the Virginia Attorney General at or call (804)786-2071. Vermont. In accordance with Vermont law, we will not share information we collect about you with companies outside of SoftLedger except as required or permitted by law. For example, we may share information to service your accounts, complete requested transactions, or to provide rewards or benefits to which you are entitled. California – California Consumer Privacy Act (“CCPA”).  This Section is only applicable to you if you are a resident of the state of California in the US (“California Residents”) and only applies to personal information for which SoftLedger is a “Business” (as defined in the CCPA), but does not apply to personal information we collect from you in the course of our provision of services to you where you are an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency.  It applies to personal information we collect from California Residents on or through our Services and through other means (such as information collected offline or in person). With respect to personal information for which you are a “Business” and SoftLedger is a “Service Provider,” please see the applicable  Terms of Service. How We Collect, Use, and Disclose your Personal Information The Personal Data We Collect section describes the personal information we may have collected about you, including the categories of sources of that information. We collect this information for the purposes described in the Use and Processing of Your Information  hyperlink> section. We share this information as described in the Sharing of Your Information <hyperlink> section. Souses cookies, including advertising cookies, as described in our Cookie Policy <hyperlink>. You may have certain rights as described in the Your Choices <hyperlink> section. To exercise your data protection rights California residents contact us at <make hyperlink>. If you have questions, please contact us as described in the Contact Us section in our Privacy Notice. You may be required to provide additional information necessary to confirm your identity before we can respond to your request and we will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within 45 days of receipt of your request, but if we require more time (up to an additional 45 days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 days. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you. You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time. For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us. For requests for deletion of your information, please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if (1) the information is necessary for us to (a) complete a transaction for you or otherwise perform a contract; or (b) detect, protect against, or prosecute security incidents, fraud or illegal activity; (2) we use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and (3) we are required to retain the information to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well. We will not discriminate against you as a result of your exercise of any of these rights. Selling Information. We do not sell your information for monetary consideration and we do not disclose your information for other valuable consideration. If, in the future, we enter into arrangements that fall within the definition of a “sale” under the CCPA, we will update this Privacy Policy and our compliance with the CCPA. Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorized the person to make the request on your behalf, (4) you verify your own identity directly with us, and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf. During the past 12 months we have collected the following categories of information about California residents from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. This includes information about Website visitors, registered users, employees, vendors, suppliers and any other person interacting with us either online or offline. Not all information is collected about individuals. For instance, we may collect different information from applicants for employment than from customers.
Categories of Personal Information That We Collect To Whom We Disclose Personal Information for Business Purpose
Identifiers – this may include name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name, signature, social security number, driver’s license number, passport number, or other similar identifiers. ·         Advertising networks ·         Affiliates or subsidiaries ·         Business partners ·         Data analytics providers ·         Government entities ·         Internet service providers ·         Operating systems and platforms ·         Other Service Providers ·         Payment processors and banks ·         Product and service fulfillment companies ·         Social media platforms & networks
Financial information – this may include bank account number, credit or debit card number, or other financial information. ·         Government entities ·         Internet service providers ·         Operating systems and platforms ·         Other Service Providers (as defined ·         Payment processors and banks ·         Service fulfillment companies
Medical / health insurance information – this may include information from a healthcare provider regarding an individual’s medical history, mental or physical condition, or treatment;  an individual’s insurance policy number or subscriber identification number, any unique identifier used by a health insurer to identify the individual, or any information in the individual’s application and claims history.  ·         Affiliates or subsidiaries ·         Government entities ·         Operating systems and platforms ·         Other Service Providers
Protected characteristics – this may include race, gender, physical or mental disability, and religion. ·         Affiliates or subsidiaries ·         Government entities ·         Other Service Providers
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. ·         Advertising networks ·         Affiliates or subsidiaries ·         Business partners ·         Data analytics providers ·         Government entities ·         Internet service providers ·         Operating systems and platforms ·         Other Service Providers ·         Payment processors and banks ·         Product and service fulfillment companies ·         Social media platforms & networks
Network activity data– this may include internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. ·         Affiliates or subsidiaries ·         Data analytics providers ·         Government entities ·         Internet service providers ·         Operating systems and platforms ·         Other Service Providers ·         Social media platforms & networks
Geolocation data – this may include precise physical location. ·         Data analytics providers ·         Internet service providers ·         Other Service Providers
Electronic and sensory data – this may include audio, electronic, visual, thermal, olfactory, or similar information (e.g., pictures, a recording of a customer service call, security video surveillance footage). ·         Government entities ·         Other Service Providers
Professional/employment information – this may include occupation and professional references. ·         Government entities ·         Other Service Providers
Education information – such as information contained in education records. ·         Government entities ·         Other Service Providers
Make Hyperlink – in active on live page. We have prepared the stand alone Cookie Policy. Note, as a best practice (and as is recommended in some EU jurisdictions) this policy should be displayed at the point at which cookies attempt to deploy (e.g., a cookie banner).  Industry practice has become the creation of a cookie preference center that dynamically displays the “policy” by explaining which cookies the website would like to deploy.  Under EU law (and as a strategy under CCPA) non-essential / non-service provider cookies would not be deployed until opt-in consent is obtained. This is not an active hyperlink on the live version.

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