PRIVACY POLICY

EnviroBusiness, Inc. d/b/a EBI Consulting (herein the “Company,” “us,” “we,” or “our”) is committed to protecting the privacy of consumers (“user,” “you,” or “your”). Our Privacy Policy is designed to assist you in understanding how we collect, use, maintain, disclose, and safeguard the information you provide to us and to assist you in making informed decisions when using our Site and our services. This Privacy Policy will be reassessed against new technologies, business practices, and our clients’ needs. This Privacy Policy applies to information we process:

• On this Site (https://www.ebiconsulting.com/), offline, or our business-to-business exchanges.
• In email, text, and other electronic messages between you and this Site.
• Through mobile and desktop applications you download from this Site, which provide dedicated non-browser-based interaction between you and this Site.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
• Through secure automated ordering and service delivery with participating clients.

This Privacy Policy:
• May be supplemented by Privacy Notices tailored to our specific relationships with you, including Privacy Notices that are sent to individuals as required under applicable laws and regulations.
• Does not apply to information that you provide to or is collected by any third party, including our business clients. Those third parties have their own privacy policies, which we encourage you to read before providing information on or through them. For example, at times, this Privacy Policy may explain how we collect, use, maintain, protect, and disclose personal information we may collect in our role as a service provider or processor for our business clients. However, when acting in this capacity, generally, our client’s privacy policy will apply. We will handle information, including personal information, that we receive, access, use, or maintain in this capacity based on the client’s direction. We encourage you to read the privacy policies of those businesses and exercise any personal information rights by contacting those businesses directly.

Please read this policy carefully in its entirety to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Site. By accessing or using this Site, you agree to this Privacy Policy. This policy may change from time to time (see 9. CHANGES TO OUR PRIVACY POLICY). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy page periodically for updates.

1. TYPES OF DATA COLLECTED

The types of information we collect depends on how we interact with you.

We collect information directly from you, including through your use of our Site. The following describes common types of information you may provide us. If you contact us, we may receive information such as your name, email address, and/or phone number. We also will receive the contents of any communications you have with us. This might include requests, questions, and/or issues regarding your current, past, or prospective orders, our Site, our services or other topics you might raise. California residents should refer to 5. YOUR STATE PRIVACY RIGHTS for additional information.

We automatically collect certain information about you as you navigate our Site.

As you navigate through and interact with our Site, 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 Site, including traffic data, session replay information, location data, logs, and other communication data and the resources that you access and use on the Site.
• Information about your device 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 may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

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

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 Site. 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 Site.
• Web Beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications, including advertisements, on the Site 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 web beacons or other tracking technologies to collect information about you when you use our Site. 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 interest-based (behavioral) advertising or other targeted content.

For example, we use analytics providers, such as Google Analytics or similar analytics services. For information on how Google processes and collects your information regarding Google Analytics and how you can opt-out, please see https://tools.google.com/dlpage/gaoptout.

We also use HubSpot in order to collect information voluntarily provided by our users, such as their name, contact information, and the company they work for. Submission of this information is entirely voluntary and may be used by us for the purposes of reporting and marketing. For more information on HubSpot’s own privacy policy, follow this link: https://legal.hubspot.com/privacy-policy.

We do not control how these third parties’ tracking technologies may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see 4. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION. Additionally, you may opt out of certain cookies via your browser settings or by visiting the Network Advertising Initiative opt-out page or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs. Please note that if you delete or choose not to accept cookies from us, certain features of our Site may not function as intended.

You may also opt out of Google’s use of cookies for advertising, including DoubleClick cookies, by visiting Google’s Ads Settings page.

2. USES OF PERSONAL INFORMATION

We use the information we collect from and about you for the following business and operational purposes:

• Provide, improve, enhance, and promote our Site
• Analyze use of our Site
• Communicate with you, including for marketing and promotional purposes. If you do not want us to use your information in this way, contact us at marketing@ebiconsulting.com
• Gain insights into prospective customers that might share an interest in our Site
• Perform services and maintain and service accounts
• Have our service providers or processors process payments and collections
• Provide customer support, including responding to questions, requests, and issues
• Find and prevent fraud
• Comply with laws, regulations, and other legal process and procedures
• Handle employment related matters

We may combine the information we collect through the Site with information we collect automatically or receive from other sources and use such combined information in accordance with this Privacy Policy.

3. PERSONAL INFORMATION DISCLOSURES

We disclose the information we collect from and about you for the following business and operational purposes:

• To contractors, service providers, and other third parties that perform services on our behalf, such as billing, payment processing, advertising, web and other analytics, data storage and processing, customer support, delivery services, security, fraud prevention, and other services. When necessary, we include data protection and privacy terms in our contracts.
• For legal reasons or the protection of Company and others, such as if required by law or legal process or if we believe in good faith that disclosure is reasonably necessary to: (i) enforce this Privacy Policy, or other terms, agreements, or contracts with you, including investigation of potential violations thereof, and/or for billing and collection purposes; (ii) respond to claims that any content violates the rights of third parties; and/or (iii) protect the rights, property or personal safety of Company, our Site users, and/or others. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, credit risk reduction, and similar purposes.
• In the event of sale (of some or all of our assets), transfer, merger, reorganization, dissolution, or similar event involving our business (including in contemplation of such transactions), your information may be among the shared or transferred business assets. If such transfer is subject to any mandatory restrictions under applicable laws, we will comply with those restrictions.
• To third parties to market their products or services to you if you have consented to or not opted out of these disclosures. For more information, see CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

4. CHOICES ABOUT  HOW WE USE AND DISCLOSE YOUR INFORMATION 

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. Please also note that your cookie settings may be browser or device dependent, and you may need to opt-out on each device from which you access.
• Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to marketing@ebiconsulting.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to certain operational emails from us.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending your request to ConsumerDataInquiry@ebiconsulting.com. For this opt-out to function, you must have your browser set to accept all browser cookies. For example, we may allow third-party advertising technologies (e.g., ad networks and ad servers such as Google’s ad services, and others) on our Site that use cookies and similar technologies to deliver relevant and targeted content and advertising to you on the Site and other websites you visit and applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you provide, your searches, demographic data, and other information we collect about you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests. Relevant opt-out links: https://tools.google.com/dlpage/gaoptout; Google’s Ads Settingspage; HubSpot’s privacy policy page; Network Advertising Initiative’s Consumer Opt-Out link; Digital Advertising Alliance’s Consumer Opt-Out link.

Please also note that the opt-outs described above apply per browser and per device, so you will have to opt out for each device—and each browser on each device—through which you access our Site.

Residents of certain states may have additional personal information rights and choices. Please see 5. YOUR STATE PRIVACY RIGHTS for more information.

Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that is available in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, which is why we describe a variety of opt-out mechanisms above. However, we do not currently recognize or respond to browser-initiated DNT signals.

5. YOUR STATE PRIVACY RIGHTS

States with consumer privacy laws may provide their residents with rights to request:

• To know or access what Personal Information we have collected or processed about you, including:
  • • the categories of Personal Information;
    • the categories of sources from which we collected it;
    • the business or commercial purpose for collecting, selling, or sharing Personal Information;
    • the categories of third parties to whom we sold, shared, or disclose Personal Information; and
• To access the specific pieces of Personal Information we have collected about you, also called the right to data portability, meaning you may have the right to download your Personal Information and transfer it to another business.
• To delete certain Personal Information that we have collected, subject to certain exceptions.
• To correct inaccurate Personal Information that we maintain about you, taking into account the nature of the information and the purpose for collection.
• To opt-out of sale or sharing, if we sell or share your Personal Information. This includes the right to opt out of Personal Information processing for targeted advertising, personal information sales, or advertising for cross-context behavioral advertising purposes. It also includes the right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. We only engage in cross-context behavioral or targeted advertising through cookies. We do not otherwise sell or share Personal Information for advertising purposes. To opt-out of sharing or these types of disclosures, we will rely on you to set your preferences regarding cookies and other tracking technology. To set your Cookie Preferences, click on the Cookie Preferences link in the footer of your browser. Please note that this will be browser- or device-specific.
• To limit the use or disclosure of Sensitive Personal Information if we use or disclose sensitive Personal Information for reasons other than those set forth under the law. We do not use or disclose Sensitive Personal Information for reasons other than the limited purposes allowed under the various comprehensive privacy laws.
• To non-discrimination. Unless permitted by law, we will not deny you goods or services; charge (or suggest you may receive) different prices for goods or services, including through granting discounts or other benefits, or imposing penalties; or provide (or suggest you may receive) a different level or quality of goods or services. In California, this includes the right not to receive discriminatory treatment by us for the exercise of privacy rights, including an employee’s, job applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their state law privacy rights. However, we may offer you certain financial incentives permitted by consumer privacy laws that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. Currently, we do not provide any financial incentives.

Some of these rights are only given to individuals when acting as “Consumers,” as that term is defined under the relevant law. Some of these rights do not extend to individuals who are acting in their business capacity or as an employee.

Exercising Your Rights

To exercise your access, modification, data portability, or deletion rights or to clarify any questions you may have about your Personal Information rights, please submit a request by clicking here or emailing us at ConsumerDataInquiry@ebiconsulting.com.

If you would like, in certain circumstances, you may designate an authorized agent to make a request on your behalf. We may deny requests from agents that do not submit proof of authorization from you. To verify that an authorized agent has authority to act for you, we may require a copy of a power of attorney or require that you provide the authorized agent with written permission and verify your own identity with us.

We will verify your identity. To do so, we may request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If it is necessary to collect additional information from your, EBI will use the information for verification purposes and will delete it as soon as practicable after complying with the request. For requests seeking particularly sensitive information, we may require additional proof of identification.

We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.

We will respond to your request within 45 days. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.

In certain cases, a request may be denied, for example, if we cannot verify your identity, the law requires that we maintain the information or if we need the information for internal purposes. If we deny your request, we will explain why we denied it. Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information.

You or your authorized agent may only submit a request to know twice within a 12-month period. Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. This request must be made by the originating email address associated with the account. In addition, the request must include, at a minimum, the phone number associated with the account.
• Have no pending activity on the account for requests to delete. In order to have the user account completely removed from the system, all pending activity (including pending statements) need to be cleared from the account. We will verify that no pending activity remains. In the event there is pending activity and a user deletion request has been made, an email will be sent to that user indicating that the pending activity will need to be removed or used prior to deleting the account. The user will then need to re-initialize the request after the pending activity has been removed or used.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale or sharing opt-out or opt-in rights, see 4. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact  ConsumerDataInquiry@ebiconsulting.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), 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.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. 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 and/or Sensitive Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

Appeal Process

If you would like to submit an appeal for any decision with regard to any consumer request, please contact ConsumerDataInquiry@ebiconsulting.com.

6. DATA RETENTION 

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means.

Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. Once you are no longer our employee, we will retain and securely destroy your Personal Information in accordance with our document retention policy and applicable laws and regulations.

7. HOW WE PROTECT YOUR INFORMATION 

When handling your personal data, we take appropriate measures reasonably designed to protect your information from unauthorized access, loss, misuse, disclosure, alteration or destruction. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site, or sites that we utilize; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorized access.

8. CHILD ONLINE PRIVACY PROTECTION ACT (COPPA) 

When it comes to the collection of personal information from children under the age of 16 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not intentionally collect any information from children under the age of 16 years old, and we do not specifically market to children under the age of 16 years old. If we learn that a child under the age of 16 submits personal information to us, we will delete the information as soon as possible. If you believe we have any personal information submitted by a child under 16, please contact us at ConsumerDataInquiry@ebiconsulting.com.

9. CHANGES TO OUR PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy at any time. If we make a change, we will make the revised Privacy Policy accessible through our Site. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Last Update” date at the top of this Privacy Policy. If we make a material change to this Privacy Policy, we will notify you through the Site, by email, and/or by other legally permissible communication. By continuing to use the Site, you are confirming that you have read and understood the latest version of this Privacy Policy.

10. CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy, or to exercise any of your rights described herein, you may call us at (781) 418 – 2325, email us at ConsumerDataInquiry@ebiconsulting.com using the phrase “CCPA Consumer Rights” in the subject line, or complete this web form here. 

Last Updated August 13, 2024