Privacy Policy

BUFFINI & COMPANY PRIVACY POLICY

Effective Date: 1 October 2022

INTRODUCTION

Buffini & Company knows that your privacy and the protection of your personal information is important. This Privacy Policy is intended to disclose how Buffini & Company (“Buffini & Company” “we” “our” or “us”) collects, uses, and strives to protect your personal information and to explain the rights and options you have regarding your personal information.

When you attend, purchase, or use our websites, memberships, products, services, programs, events, or contact us (collectively, “Offerings”), we may collect personal information from which it may be possible to identify you. This might include information about your identity and your contact information, as well as information concerning your business, your purchasing history with Buffini & Company or any other information you provide us in connection with your interaction with our Offerings. In general, we collect personal information to enable us to fulfill requests for Offerings, to enhance your experience with Buffini & Company, to track your performance for your use and to enable us to assess the efficacy of our programs, and to assist us in providing you with relevant information concerning your membership, our events, or our Offerings. We will not sell your personal information to anyone and will only intentionally disclose it as set forth in this policy. Furthermore, we will not share or disclose your personal information except as necessary to provide or enhance our Offerings or to collect aggregated information about our clients and their production.

By your interaction with our Offerings, you are agreeing to the terms of this Privacy Policy, which are incorporated herein by reference, to the extent applicable.

Policy Application

This policy is intended to apply to the following category of persons who provide information to us:

• Attendees. Attendees at live or online events featuring content providers representing our Offerings.
• Visitors. Persons who use our website to obtain information, to interact with us, or to purchase our Offerings.
• Customers. Persons who individually, or on behalf of a business or business team, purchase or use our Offerings.

Categories of Personal Information We Collect

Depending on how you interact with us, we may collect the following categories of personal information directly from you or indirectly through your device or browser when you visit our Offerings. If you choose to visit or interact with our Offerings, we may gather the following information about you:

How We Use the Information We Collect

We only process and use personal information in a way that is compatible with and relevant to the purpose for which it was collected or authorized. In general, we may use all categories of information described above, to the extent applicable, for the following purposes:

• To authenticate your identity across our Offerings;
• To provide, operate, maintain, improve and promote our Offerings;
• To enable you to access and use our Offerings;
• To process and complete transactions and related information, including purchase confirmations and invoices of our Offerings;
• To send transactional messages, including responses to your comments, questions and requests, provide customer service support and send you technical notices, updates, support and administrative messages, and provide you with product or service notifications from our Offerings;
• To send commercial advertising or marketing communications such as providing you with information about our Offerings, features, surveys, offers, promotions, and events;
• To monitor and assess the efficacy of our Offerings;
• To provide information about your existing or potential business transactions with our Offerings;
• To monitor and analyze trends, usage and activities in connection with our Offerings for business purposes;
• To allow you to give and receive business referrals on our Offerings;
• To provide you a personalized experience in your use of our Offerings;
• To fulfill any other purpose, we describe when you provide the information or any purpose for which you provide it; and
• For any other purpose with your consent.

Information Sharing of Personal Information

We sometimes use third-parties, whether contractors, service providers, affiliates, or any other third parties we partner with or use to support our business, who help us run our business and to assist us in our business operations, to analyze various aspects of our business and to provide or help provide our Offerings. These service providers provide services to help us deliver customer support, process credit card payments, receive and deliver communications, manage and contact our existing customers and otherwise operate and improve our Offerings. These service providers also provide us with specific kinds of services such as customized badge printing for our events, providing our Client Direct service, shipping our products, and backing up our customer data, analytics and credit card processing.

Our service providers may only process personal information pursuant to our instructions and in compliance with this Privacy Policy and other applicable laws. We do not authorize our service providers to sell any personal information we share with them or to use any personal information we share with them for their own marketing purposes or for any purpose other than the services they provide for us.

In addition to the foregoing, we may also share your personal information with others in the following circumstances:

• When we are required to disclose personal information in response to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims;
• Where we have a good faith belief that sharing is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, or situations involving threats to the property or physical safety of any person;
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding;
• To fulfill any other purpose we describe when you provide the information or any purpose for which you provide it; and
• For any other purpose with your consent

In addition, from time to time, we establish contractual relationships with real estate, mortgage, or real estate servicing companies that promote products or services that may be purchased by an individual client. Those companies may be related to individual clients as franchisors, licensors, independent contractors, or principals. We may share the personal information of a client with a related business of the client if Buffini & Company, in its sole and exclusive judgment and discretion, determines that there is a legitimate business purpose or need for the disclosure of such information.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties

We may also aggregate data we acquire about you. Non-personally identifiable aggregated data may be shared with third parties for any purpose we determine reasonable and necessary in our sole and exclusive judgment and discretion.

Your Rights Regarding Your Personal Information

Request for Disclosure

No more than twice in any twelve-month period, you may request that Buffini & Company disclose the following for the prior twelve months.

• The categories and specific items of personal information that we have collected concerning you for the prior twelve months;
• The sources from which each category of information was obtained;
• The business or commercial purpose that we have for collecting each category of personal information;
• The categories of third parties with whom we have shared personal information;
• The business or commercial reason for sharing the information with third parties.

Request for Copy of Personal Information

No more than twice in any twelve-month period, you may request that Buffini & Company provide you with a copy of your personal information. To the extent possible the information will be provided in a portable, readily usable fashion.

Request for Deletion of Personal Information

You may request that we delete your personal information from our system. If you make that request, we will also instruct any third parties to whom we have shared your personal information to delete your personal information from their system. If you exercise your right to request the deletion of your personal information, it may be impossible for Buffini & Company to provide Offerings to you. Once your personal information is deleted by Buffini & Company or our third-party service providers your deleted data cannot be recovered.

Notwithstanding a request for deletion, we will retain your personal information for the purposes of completing ongoing transactions or maintaining an ongoing business relationship, or to use the information internally in a lawful manner that is compatible for the context for which the information was provided. For example, we will retain copies of billing records reflecting the transactions in which you have engaged.

Methods of Exercising Your Rights

In order to make a request for the disclosure of your personal information, a copy of your personal information or to request the deletion of your personal information, please contact us through Customer Service at 1-800-945-3485 x 1. Alternatively, you may make your request through the following link: https://www.buffini.com/company/contact-us.aspx

Opting out of Marketing Communications

If you no longer want to receive marketing communications from us, you can unsubscribe by following instructions contained in the messages you receive, by changing your marketing preferences through your Profile, or by contacting us through Customer Service at 1-800-945-3485 x 1. We reserve the right to send you certain communications relating to the Offerings we provide, such as transaction or administrative messages, or the extent we are required to do so by applicable legal requirements. We do not offer you the ability to opt-out of receiving those communications.

Cookie Options

As you navigate through and interact with our Offerings, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Offerings, including traffic data, location data, logs, and other communication data, and the resources that you access and use on our Offerings.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and does not include personal information, we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It furthers our legitimate interest to improve our Offerings and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns with our Offerings.
• Store information about your preferences, allowing us to customize our Offerings according to your individual interests.
• Speed up your searches for our Offerings.
• Recognize you when you return to our Offerings.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Offerings. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Offerings.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources, or you provide to us.

Some content or applications, including advertisements, on our Offerings are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you use our Offering. 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 and other online services. They may use this information to provide you with advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

You may manage or change the cookies settings through your web browser to manage or to alert you before a cookie is placed on your browser. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences.

Please note that cookie-based opt-outs only apply to the specific browser on which the opt-out cookie is applied. If you accept a cookie, you can delete it at any time through your browser.

If you choose not to accept cookies by denying or blocking, you may not be able to use or benefit from all the Offerings available.

Personal Information Security Safeguards

Although no website, application, database, or system is completely technically, physically, or administratively secure, or “hack-proof,” we have safeguards in place to reasonably prevent and protect against unauthorized access and disclosures of the personal information we control, including technical, physical, and administrative safeguards and security measures. Despite these measures, however, we cannot guarantee that our information security safeguards will never be compromised.

Changes to Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will also revise the "Effective Date" listed at the beginning hereof. We will use reasonable efforts to provide you with notice of any such amendment or change by electronic communication (“Notice”). Your continued use of our Offerings will be subject to the terms of the current Privacy Policy.

Contact Us

For further information regarding this Privacy Policy or related Buffini & Company policies and procedures, please contact us through Customer Service at 1-800-945-3485 x 1.

Supplemental (CCPA) Notice to Residents of California

If you are a California resident, California law may apply to how we collect and use your personal information, and what rights you have in some circumstances. The following terms supplement our Privacy Notice and explain the rights of California residents.

For information about what categories of personal information we may collect from our customers, the sources of that information, the purposes for collecting and using that information, and what types of service providers we may share that information with, please see above.

California residents have the following rights:

• The right to request information about personal information that we have collected about that customer in the 12 months preceding the customer’s request;
• The right to receive requested information in a readily-usable format if provided electronically;
• The right to request that we delete any personal information about the consumer that we have collected (although we may be entitled to retain some information for certain purposes); and
• You have the right to be free from discrimination based on your exercise of your CCPA rights.

We will use reasonable efforts to supply, correct or delete personal information about you in our files to the extent you request it.

We do not sell personal information.

While we do not sell personal information for monetary value, we may share or disclose personal information to third parties in such a way that may be considered a “sale” of personal information. To direct us to stop the sale of your personal information, please contact us at the following link: https://www.buffini.com/company/contact-us.aspx

We cannot respond to your request to access or delete information unless we are able to both verify your identity or authority to make the request and confirm the personal information relates to you. If you have an account on any of our Offerings, we will verify your identity by having you log in to your account. If you do not have an account on our Offerings, we will attempt to verify your request by asking you to provide identifying information that we will match to information in our files. We will only use information you provide in your request for the purpose of verifying your identity or authority to make the request.

We may deny deletion requests in whole or in part in certain circumstances, including as permitted or required by applicable law. We do not charge a different price or rate or provide a different level or quality of goods or services based on your exercising your CCPA rights.

To exercise your rights under California law, please contact us at the following link:
www.buffini.com/company/contact

Supplemental (GDPR) Notice to Residents of the European Economic Area, Switzerland, and the United Kingdom

Controller of Personal Information

The data controller for personal information provided to us or in connection with our Offerings is Buffini & Company, located at 6349 Palomar Oaks Ct, Carlsbad, CA 92011, United States of America.

Legal Bases for How We Process Your Information

The legal bases for processing your information as set out in this Privacy Policy are as follows, as applicable:

• Where use of your information is necessary to perform our obligations under a contract with you;
• Where use of your information is necessary for our legitimate interests or the legitimate interests of others;
• Where we have your consent, in accordance with applicable legal requirements, to use your information for a particular purpose to the extent of that consent; or
• Where we use your information to comply with applicable legal or compliance obligation.

Integrity and Retention of Personal Information

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our Offerings specific terms. When assessing these periods, we carefully examine our need to collect personal information at all and if we establish a relevant need, we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

International Data Transfers

Our technology services are in the United States. If you choose to provide us with your information as described in this Privacy Policy, we may transfer your personal information cross-border to the United States.

Where we transfer data from the EU, we will implement appropriate safeguards to comply with applicable law.

By providing us with your information, you acknowledge such transfers. If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. If you would like further information about these transfer mechanisms, please feel free to contact us at the following link: https://www.buffini.com/company/contact-us.aspx

Your Legal Rights

Your local laws may permit you to request that we, subject to certain limitations:

• Tell you how we use your information and provide access to and/or a copy of certain information we hold about you;
• Update or rectify information that is out of date or incorrect;
• Delete certain information that we are holding about you;
• Transfer your information to a third-party provider of services;
• Erase, return, or limit processing of your information in certain circumstances, e.g., for direct marketing purposes;
• Revoke your consent for the processing of your information, to the extent we rely on consent as the legal basis to process your information; or
• Lodge a complaint with the supervisory authority responsible for data protection matters.

You may edit, cancel, or delete your Buffini & Company account information at any time by contacting us through Customer Service at 1-800-945-3485 x 1.

Information necessary for the purposes of maintaining business records regarding a deleted or canceled account, including records of credit transactions and account ownership, will be retained in accordance with applicable law. We may decline to process requests that are frivolous/vexatious, would jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud, security, and/or safety purposes.

Supplemental Notice to Residents of Nevada

Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties. This right applies even if their personal information is not currently being sold. If you are a Nevada consumer and wish to exercise this right, please contact us at the following link: https://www.buffini.com/company/contact-us.aspx

Supplemental Notice Concerning Children’s Online Privacy Protection Act (COPPA)

Our Offerings are not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our Offerings. We do not knowingly collect personal information from children under 13. If you are under 13, do not provide any information on this or any of our Offerings or on or through any of our Offerings, make any purchases through our Offerings, use any of the interactive or public comment features of our Offerings or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the following link: https://www.buffini.com/company/contact-us.aspx

Abandoned cart

Buffini & Company uses cookies to collect information around abandoned shopping carts. A cart is considered abandoned within one hour of inactivity/lack of purchase. Once the cart is considered abandoned, an SMS message will be sent as a reminder.