Privacy Policy

2021

INTRODUCTION

This Privacy Policy explains how Caleb Williams Holdings, inc. (“we”, “us”, or “our”) collects, uses, shares and processes information obtained through https://www.calebwilliams13.com our social media sites and other websites and applications that link to this Privacy Policy (which we call our “Site” or “Sites”). We encourage you to read this Policy before using the Site. By using the Site, you signify your agreement to the terms and conditions of this Policy. Please also see our separate Terms of Use and Cookies Policy, which also govern use of the Site along with this Policy. Should you have any questions about the Site, this Policy or our privacy practices and procedures, please contact us at the information below:

By email: info@calebwilliams13.com

By mail: Caleb Williams Holdings, inc

INFORMATION WE COLLECT ON OR THROUGH THE SITES

The type of personal information we collect depends on how you are interacting with our Sites. In this Policy, where we use the term “personal information,” we mean information that can be used to identify (directly or indirectly) or contact a specific individual, such as an individual’s name, email address, telephone number, or online identifier. The personal information we collect through the Site may include the following:

• Your Contact Information.  This includes information such as a name, alias, address, phone number, social media account user ID, email address, and similar contact data.
• Organizational Information. This includes your employer or organizations that you are a member of, information about your colleagues or those within your organization, your status with an organization, and similar data to the extent you share the same through social media.
• User Content.  This includes content, communications, suggestions, comments, questions, responses to questions, feedback and all other information that you send to us, that you provide to us when you contact us, or that you post on our Sites. This includes social media and other online content to the extent you interact with us on social media and other online services.
• Device Information.  This refers to device and browser information, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data as described in our Cookies Policy.
• Usage Data.  This refers to data collected automatically as a result of your use of the Site, whether generated by your use of the Site (for example, where you visit on the Site) or as a result of Site infrastructure itself (for example, the duration of a page visit). This includes usage metrics, content interactions (including searches, views, downloads, prints, shares, streams, and display or playback details), and user history (including clickstreams and page navigation), content viewed or searched for, page response times, page interaction information, advertising interactions and marketing preferences.
• Member Account Information.  This refers to security-related information (including user names and passwords), service-related information (including purchase history and account profiles), billing-related information (including payment, shipping, and billing information), and similar data that is associated with a Site account specific to you.
• Financial information.  Your billing address, credit card information, banking account information, and similar data to the extent you make a payment online.
• Location data. This refers to the location of your device when you access the Site and similar location data.
• Demographic information. Your country of residence, preferred language, age and date of birth, marriage status, gender, physical characteristics, personal or household/familial financial status, military status, and similar data may also be collected.
• Your Image may also be collected along with other aspects of your likeness such as still pictures of you, video, voice, and other data that shows or depicts you.
• Identity Information, such as government-issued identification information, tax identifiers, social security numbers, other government-issued identifiers, and similar data.
• Employment Information.  Career, education, and employment related information, such as job preferences or interests, work performance and history, salary history, status as a veteran, nationality status, professional licensure information and related compliance activities, accreditations and other professional accolades may also be collected.

HOW WE USE INFORMATION WE COLLECT ON OR THROUGH THE SITES

Our Processing

We process your personal information in connection with our Site and for other business purposes as follows:

• Fulfillment of your requests or in connection with the performance of a contract.
• Provide, deliver, analyze, and administer our Site and related services (including in connection with the performance of a contract).
• Comply with your instructions or to fulfill other, specified purposes for which you have given your consent.
• For that which you have given us consent to process your personal information for specified purposes, such as to provide our Sites and other services requested by you.
• Process transactions related to our Services and administer accounts or profiles related to you or your organization (including registrations, subscriptions, purchases, billing events, royalty calculations, and payments).
• For internal research and development purposes for new content, products, and services, and to improve, test, and enhance the features and functions of our Site.
• Personalize and make recommendations related to our Site and other offerings.
• Contact and communicate with you in connection with our Site or other notifications, programs, events, or updates that you may have registered for.
• Send you offers, advertising, and marketing materials, including to provide personalized advertising to you.
• Detect and prevent fraud and abuse, as well as to identify and authenticate your access to our Sites or to identify and authenticate you before we provide you with certain information.
• Exercise our rights and to protect our and others’ rights and/or property.
• Comply with the law and our legal obligations, including to respond to a request or order from a court, regulator, or authority, as well as to fulfill our contractual obligations with our customers when they arrange access to our Services for you.
• Effectuate the sale, merger, acquisition, or other disposition of our business (including in connection with any bankruptcy or similar proceedings).

 

Legal Notices

We may use your personal information to provide you with notice regarding a security incident or data breach, by: (i) sending a message to the email address you provide (as applicable); (ii) posting to a publicly facing page of our website; (iii) through major statewide media; and/or (iv) telephonic means, including calls and/or text messages, even if sent via automated means including automated dialers (standard text and data messaging rates may apply from your carrier). Notices sent by e-mail will be effective when we send the email, notices we provide by posting will be effective upon posting, and notices we provide through telephonic means will be effective when transmitted or dialed. You consent to receiving electronic communications from us relating to any security incident or data breach. It is your responsibility to keep your email address and any other contact information you provide to us current so that we may provide these communications to you.

Service and Marketing Messages

If you sign up for our newsletters and other marketing and informational messages, we may use your information to contact you about product and service offerings by email or otherwise. You have the right to opt-out of such messages. We may use your information to investigate, respond to and/or resolve legal, security or technical issues and complaints and as necessary for security purposes or to investigate possible fraud, violations of law or violations of this Policy or our Terms of Use. We may use your information to contact you about these security, legal and other service-related issues. Please be aware that you cannot opt-out of receiving such messages from us.

 

DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect or that you provide to fulfill our obligations to you (if any), the purpose for which you provide it (if any), for any other purpose for which we have your consent, or for legitimate business purposes which may include when required by law, subpoena, or other legal process or as necessary in the course of legal proceedings.

Internal Disclosure

We will share your personal data internally within Caleb Williams Holdings, inc. in order to determine whether we may provide services to you and, if an attorney/client relationship is created, facilitate our ability to provide services to you.

Disclosure to Our Service Providers

We may disclose personal information that we collect or you provide as described in this Privacy Policy to service providers and other third parties we use solely to support our business (such as the management of our data, maintenance, analysis, audit, fraud detection, communication and the like). They will have access to your information only as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

Disclosure for Legal Reasons

We may transfer your personal information to a third-party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control (such as the result of a bankruptcy proceeding). We may disclose your personal information to third parties if we reasonably believe that disclosure of such information is helpful or reasonably necessary to comply with any applicable law or regulation, to comply with or respond to a legal process or law enforcement or governmental request, to enforce our terms and conditions or other rights (including investigations of potential violations of our rights), to detect, prevent, or address fraud or security issues, or to protect against harm to the rights, property, or safety of our company, our users, or the public.

YOUR REQUESTS CONCERNING YOUR INFORMATION

For personal data that we have about you, you may make requests such as the following:

• Deletion:  You may ask us to erase or delete all or some of your personal data. Doing so may limit your ability to use certain functionality of the Site as well as our ability to process your requests and inquiries.
• Correction/Modification: You may ask us to change, update, or fix your data in certain cases, including if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You may ask us to stop using all or some of your personal data or to limit our use of it; however, doing so may limit your ability to use certain functionality of the Site as well as our ability to process your requests and inquiries.
• Right to Access Your Data: You can ask us for a copy of your personal data you have provided to us so long as we are able to verify your identity when you make such a request.

To make a request or inquiry concerning your personal information, contact us at the information above and include the phrase “[Your State] Privacy Request” in the subject line.  When you make a request, we ask that you help us by also identifying the following:

• Tell Us Your Specific Request: Please specify your specific request and the personal information to which your request relates. If you are acting on behalf of another individual, please clearly indicate this fact and your authority to act on such person’s behalf.
• Tell Us More about Your Relationship with Us: Please let us know how you are associated with us.
• Help Us Verify Your Identity: Provide us enough information to verify your identify. If we cannot initially verify your identity, we may request additional information to complete the verification process (such information may include your picture, a copy of your driver’s license or other government-issued ID and/or a recent utility or credit card bill). Please note that if we cannot verify your identity, we may not be able to fulfill your request. Any personal information you disclose to us for purposes of verifying your identity may be shared with our third-party service providers and/or third parties (like your phone carrier) or government agencies for the purpose of verification.
• Direct Our Response Delivery: Depending on your request, we will provide a response to you via email. If you prefer to receive our response in another way, then please let us know your preferred delivery mechanism to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).

We may decline to process requests if we cannot verify the requestor’s identity, if we believe the request will jeopardize the privacy of others, if we believe the change would violate any law or legal requirement or cause the information to be incorrect, or for a similar legitimate purpose. In any case, where we provide information access, deletion or correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information.  If we modify or delete some or all of your personal information, we will retain your personal data if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce obligations or fulfill any other requests from you (for example, to opt-out of further messages or for a copy of your data).

We will not discriminate against you for exercising any of your rights under applicable law. 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.

SECURITY AND PROTECTION

We implement industry standard security safeguards designed to protect your data. These include using encryption for your data while it is being transmitted between your device or browser and our servers. Nevertheless, given the nature of communications and information technology, and that the use of the internet has inherent risks, although we regularly monitor for possible vulnerabilities and attack, we cannot warrant or guarantee that information provided to us through the Site or stored in our systems or otherwise will be absolutely free from unauthorized intrusion by others. By using the Site, you agree that we are not responsible for: (i) any disclosure of your personal information made by you to a third party through your use of the Site; (ii) any disclosure of your personal information obtained illegally from us; or (iii) any accidental disclosure of your personal information made by us.

LAWFUL BASES OF DATA PROCESSING

We will only collect and process personal data about you where we have a lawful basis. Lawful bases include those uses and disclosures identified in this Policy, your consent, contract, and other legitimate interests. Such legitimate interests include protection to you, us and third parties, to comply with applicable law, to enable and administer our business, and to contact you concerning changes in law, invitation to our events and information about our services. We have analyzed the balance between our legitimate interests and your rights with the following considerations: (i) your personal data is collected and processed because you either use our services, have subscribed to our email contacts, or have inquired into our services; (ii) your contact information is limited to your business details unless you chose to provide private contact details; (iii) the content of our communications focuses on business relevant to legal matters; (iv) our intention is to only generate meaningful consent or to contact you concerning services you have requested from us; and (v) the marketing messages we send to you contain an option to unsubscribe.

RETENTION AND WITHDRAWAL

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. Where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at the information above. We retain personal information in accordance with our enterprise records retention schedule, which varies by service, business function, record classes, and record types. We calculate retention periods based upon and reserve the right to retain personal information for the periods that the personal information is needed to: (a) fulfill the purposes described in this Policy, (b) meet the timelines determined or recommended by regulators, professional bodies, or associations, (c) comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), and (d) comply with your requests.

THIRD PARTY COLLECTION

Please keep in mind that the Site may contain links to other websites or apps. Some content or applications on or in the Site may be served by third-parties, including content providers, application providers, analytics companies, your mobile device manufacturer, and your mobile service provider. These other sites and companies may place their own cookies or other files on your computer, collect data or solicit personal information from you. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services. They may use this information to provide you with interest-based (behavioral) targeted content.

We do not control these third parties’ privacy practices or tracking technologies. If you have any questions about targeted content, you should contact the responsible provider directly.  You are responsible for reviewing the privacy statements and policies of those other websites you choose to link to or from the Site, so that you can understand how those websites collect, use and store your information. We are not responsible for the privacy statements, policies or content of these other companies and websites or apps, including websites you link to or from the Site.

CHILDREN’S PRIVACY

Information concerning our policies and procedures when collecting information from children under the age of 16 may found in our Children’s Privacy Policy.

CHANGES

We may update our Privacy Policy from time to time to reflect changes in our practices. We will post any changes to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will provide a notice that the Privacy Policy has been updated. The date the Privacy Policy was last modified is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Policy to check for any changes.

Our Privacy Policy generally explains our collection, processing, and storage of the personal information we collect from you online. This Cookie Policy is intended to supplement that Policy and explain how Caleb Williams Holdings, inc. (“we”, “us”, or “our”) and https://www.calebwilliams13.com (the “Site”) deploys and uses cookies and similar technologies

What are Cookies?

Cookies are small data files stored on your computer or other device when websites are loaded in a browser. They are used to remember you and your preferences through either a single visit to a Site (a “session cookie”) or over the course of repeated visits (a “persistent cookie”). Cookies help to facilitate the best possible user experience of our Site as they allow us to recognize your preferences and information from session to session and generally improve website functionality.  Cookies may be set by the website you are visiting (a “first party cookies”), or by third parties who provide content or advertising or analytics services on that website (“third party cookies”).

Cookies are in addition to other tracking technologies known as “web beacons” or “pixels.” These are typically small transparent images that provide internet usage statistics and are often used in conjunction with cookies, although they are not stored on your computer in the same way as cookies. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.

Flash cookies are designed to support browser content supported by Adobe® Flash. They will store information on your device, some of which will be specific to the Flash-enabled content. Please refer to the following help page for information on how to manage your privacy settings and deletion of Flash cookies:

http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.

 

Although these types of tracking technologies are not all commonly referred to as “cookies,” we will refer to them as “cookies” throughout this Cookie Policy for ease of reference.

The Types of Cookies We Use

• Necessary. These cookies are essential for our Sites to perform basic functions. These include cookies that are required to allow users to authenticate and perform account related functions.

• Functionality. These cookies are used to store preferences set by users.

• Security. We use these cookies to help identify and prevent potential security risks.

• Performance. We use performance cookies to collect information on how users interact with our Site and the content utilized on our Site. We use these details to improve how our services and Sites.

• Advertising. These cookies are used to display relevant advertising to users of our Site, as well as to understand and report on the efficacy of ads served on our Site. These are set by us and trusted third party networks, and are generally persistent in nature.

Third Party Content

Some of our Sites are offered through third party platforms and applications that use their own cookies.  These include social media platforms such as Facebook and Twitter (through the use of sharing buttons). As a result, cookies may be set by these third parties, and used by them to track your online activity. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly.

What We Collect With Cookies

We use cookies to recognize you and/or your device(s) on, off, and across the different applications of the website and devices. We log usage data when you use the website, including when you view or click on content, browser type, browser language, perform a search or request, the date and time of your request or use one or more tools offered through the website.  We use log-ins, device information internet protocol (“IP”) addresses, and cookies to identify you and log your use.  When you access or leave our Sites, we receive the URL of both the site you came from and the one you go to next. We may also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. We do not collect information concerning your GPS location

How We Use Information We Collect With Cookies

We use cookies for several different purposes. We use cookies for technical reasons to enable the content being provided on the Sites as well as to provide you with a more personalized experience on our Sites.  We also use cookies to analyze Site usage and for advertising purposes.

Restricting and Controlling Cookies

Although most internet browsers accept cookies, you can control these types of technology through your browser settings and similar tools and agree to refuse cookies altogether. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the help option in your browser for more details:

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari weband iOS
• You can opt out of Google Analytics by installing Google’s opt-out browser add-on

If you refuse to accept cookies by activating the appropriate setting on your browser or smartphone, you prohibit us from delivering the full capability of the website and prevent the use of certain features and services that require these technologies.

Do Not Track Signals

We do not currently respond to, or take any action with respect to web browser “do not track”“ signals or similar mechanisms as there is no uniform implementation of the same. Our third-party service providers may honor Do Not Track signals.  For more information about “do not track” signals, please visit https://allaboutdnt.com/.

Consent for Cookies on Our Sites

By using our Site without changing your browser or device settings to disable cookies, you agree to this Cookies Policy and the use of cookies as described above.  You may see a “cookie banner” on our websites. If you are visiting one of our Site from certain jurisdictions, you may be asked to accept cookies in accordance with this policy.  When you consent to this banner, we will assume that you consent to our use of cookies as described above for all future visits unless you contact us and notify us otherwise.

How to Contact Us with Questions or Concerns

If you have any questions about our use of cookies, you can find the most recent contact details in our Privacy Policy.

Our Privacy Policy generally explains our collection, processing, and storage of the personal information we collect from you online. This notice is intended to supplement our Privacy Policy so as to explain rights that California consumers may have with respect to our Sites under the California Consumer Privacy Act of 2018 (“CCPA”).

Terms such as “personal information” and “processing” that are defined in the CCPA will have the same definitions in this Policy as we understand them to have under the CCPA. This includes exceptions to certain terms under the CCPA. For example, “personal information” under the CCPA does not include publicly available, de-identified, or aggregate consumer information.

Below is a table that provides categories of personal information we collect online, the sources of that information, purposes for why we collect it, who we share it with, and whether we sell that personal information.

If you are a resident of California, you may have the right to request what information we collect, use, and disclose. You may also have the right to request that we delete your information. California residents also have certain rights regarding the sale of personal information, however, we do not “sell” your personal information as that term is used and defined in the CCPA.

We ask that individuals making requests identify themselves and identify the information requested to be accessed, corrected or removed before we process any requests.  We may decline to process requests if we cannot verify the requestor’s identity, if we believe the request will jeopardize the privacy of others, if we believe the change would violate any law or legal requirement or cause the information to be incorrect, or for a similar legitimate purpose. We will use information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver’s license and/or a recent utility or credit card bill. In any case, where we provide information access, deletion or correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

We will deliver our written response by mail or electronically, at your option.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. If we modify or delete some or all of your personal information, we will retain your personal data if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce obligations or fulfill any other requests from you (for example, to opt-out of further messages or for a copy of your data).   We will not discriminate against you for exercising any of your rights under applicable law. 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.

To make a request, you can contact us at the information provided in our Privacy Policy.  You can designate an agent to make a request on your behalf by either: (1) having your agent send us a letter, signed by you, certifying that the agent is acting on your behalf and showing proof that they are registered with the California Secretary of State; or (2) by you and the agent executing and sending us a notarized power of attorney stating that the agent is authorized to act on your behalf.  Please note that we may still require you to verify your identity before we process a request submitted by your agent.

Our Privacy Policy generally explains our collection, processing, and storage of the personal information we collect from you online. This Policy is intended to supplement that Policy and explain how Caleb Williams Holdings, inc. (“we”, “us”, or “our”) and https://www.calebwilliams13.com (the “Site”) collect, use, share and process information we collect from users that are children under the age of 16.

Information We Collect from Children

Children can access many parts of our Site and use some of its features without providing us with personal information.  Other content and features are available only to registered users and subscribers. In addition, we use cookies and similar technologies to automatically collect information from our users (including children) when they visit or use the Site as described in our Cookies Policy. We may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online. We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.

Information We Collect Directly.

A child must provide us with the following information to register with this website: the child’s first name, birth date, and [OTHER REQUIRED INFORMATION].  In order to verify a parent or guardian’s consent to their child using the Site, and to keep parents and guardians informed of their child’s use of the Site, we also collect [the email address and credit number of a parent or legal guardian]. We also require the child to create a member name and password. We may request additional information from your child, but this information is optional. We specify whether information is required or optional when we request it.

We may enable registered users to communicate with others on or through the Site through chat, email, video, and posting to public and private areas of the Site (“social features”). The nature of these features allows children to disclose personal information about themselves. We do not monitor or review this content before it is posted, and we do not control the actions of third parties with whom your child shares his or her information. We encourage parents to educate their children about safe internet use and to monitor their children’s use of social features.

How We Use Your Child’s Information

We use the personal information we collect from your child to (i) register him or her with the Site; (ii) communicate with him or her about activities or features of the Site that may be of interest; (iii) track his or her performance in use of the Site; (iv) allow for use of certain functionality of the Site; and (v) provide maintenance and support of the Site.  We also use the information we collect to improve our Site and to deliver a better and more personalized experience by enabling us to: (vi) estimate our audience size and usage patterns; and (vii) store information about the child’s preferences, allowing us to customize the content according to individual interests.

Our Practices for Disclosing Children’s Information

We do not share, sell, rent, or transfer children’s personal information other than as described in this section. We may use or disclose aggregated information about many of our users, however, this information does not identify any individual [or device]. In addition, we may disclose children’s personal information to third parties we use to support the internal operations of our Site and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential, if we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request, if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ourselves, our customers or others, or to law enforcement agencies or for an investigation related to public safety.  In addition, if we are involved in a merger, , restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets,  we may transfer the personal information we have collected or maintain to our successor.

Accessing and Correcting Your Child’s Personal Information

At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information. You can review, change, or delete your child’s personal information by accessing your child’s account directly and changing preferences for that account. Or, you may contact us at [contact information].  To protect the privacy and security of you and your child, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.