This Privacy Policy (the “Privacy Policy”) governs your access to and use of all websites and mobile applications (collectively, the “Sites”) that link to or reference this Privacy Policy. By accessing or using any of the Sites, you are agreeing to this Privacy Policy and entering into a legally binding contract with Foundation Partners Group (“FPG”) or an FPG subsidiary or affiliated entity (collectively, “Company”) under which you consent to the processing of information according to this Privacy Policy. If you are unwilling or unable to be bound by the Privacy Policy, do not access or use the Site. For information on how Company administers the Site, please see the Company Terms of Use.

Information We Collect

Through the Site, you can engage in various activities. In doing so, you will provide certain information to us. For example, when you register with the Company, we will collect your name, email address, and other information you provide to us. Your credit/debit card information will be processed by a third-party processor, and we will not collect your credit/debit card information directly. When you provide such information, you will be doing so directly to our third-party payment processor. When you register for a newsletter or alert available through the Site, we will collect your name and email address. We may also offer sweepstakes and contests through the Site, and, if so, we will collect the information you provide us in connection with the promotion. If you provide information regarding other people to us, you represent that you have permission from those people to do so. We also integrate with a third-party service that allows content sharing via Facebook, Google, Twitter, and other social media. When you share content via that service, you are sharing information with the service, not with the Site.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we have collected the following categories of Personal Information from consumers within the last 12 months or may collect such information in the future: A. Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. C. Protected classification characteristics under California or federal law: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). D. Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. E. Biometric information: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. F. Internet or other similar network activity: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. G. Geolocation data: Physical location or movements. H. Sensory data: Audio, electronic, visual, thermal, olfactory, or similar information. I. Professional or employment-related information: Current or past job history or performance evaluations. J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. K. Inferences drawn from other personal information: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you or your agent. For example, from documents that you provide to us related to the services for which you engage us.
• Indirectly from you or your agent. For example, through information we collect from you in the course of providing services to you.
• Directly and indirectly from activity on the Site. For example, from submissions through our website portal or website usage details collected automatically.
• From third parties that interact with us in connection with the services we perform. For example, from government agencies in connection with services we provide to them.

We also may collect the following information: your session history; your usage patterns (traffic data, location, data, server logs, and other communication data); information about your online activities on the Site and third-party sites, including the sites you visited before and after visiting the Site; information about your computer such as device type, screen size, browser type, operating system, memory, language and other settings, plug-ins, TCP configuration, carrier code, and information regarding software on your device; your internet connection information, such as IP address, which can be used to identify your geographic area; your interactions with email messages we send you (such as whether you opened an email and, if so, when, whether you forwarded the email, and the device you used to open the email); search terms you use on the Site and any site that referred you to the Site; and unique identifiers, such as mobile device identification numbers. We may collect this information through the cookies and other tracking technologies described below.

Cookies and Other Tracking Technologies

When you use the Site, we may use a variety of technologies to collect certain information. Although this information does not specifically identify you, it can be used to assign a unique number to you. It can then be used to connect your use of the Site to other information about you, including your Personal Information.

We and our service providers may use “cookies” to customize your experience on the Site. “Cookies” are small computer files that are transferred to your computer’s hard drive and contain information such as your preferences and the pages you have visited and the activities you have performed while using the Site. You may block cookies in your browser and/or delete cookies from your hard drive. By disabling cookies, however, you may not be able to access all of the features of the Site.

We and our service providers may use small pieces of code on the Site called “web beacons,” also known as “pixel tags” or “clear gifs.” Web beacons collect anonymous and aggregate advertising data. Web beacons recognize certain types of information such as a user’s cookie number, date and time of page view, and description of the page where the web beacon is placed. You may block web beacons by blocking cookies in your browser and/or deleting cookies from your hard drive.

We and our service providers may use local shared objects, which are also called “flash cookies,” and local storage objects such as HTML5. These technologies are stored on your device and can be used to store certain information about your activities and preferences. You may not be able to control flash cookies using standard browser tools and settings. For information about how to delete Flash cookies, please visit the Adobe website here.

We and our service providers may use device fingerprinting, which is a way of identifying a device based on its unique configuration.

How We Use the Information

We may use information that we collect about you or that you provide to us, including any Personal Information in the following ways:

• To provide the services you request such as email alerts and newsletters;
• To provide you with information and services you request from us;
• To contact you;
• To deliver targeted advertising and to understand how you interact with and use the advertisements and content on the Site;
• To administer sweepstakes and contests if we ever run such promotions;
• To allow you to use interactive features on the Site, to the extent such features are available;
• To contact you about our own and other parties’ goods and services in which you may be interested;
• To better understand those who use the Site;
• To manage and improve the Site, including performing analytics on the Site;
• To notify you about changes to the Site and about your registration;
• To enforce the legal terms that govern your use of the Site;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• To evaluate or conduct 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 a bankruptcy, liquidation, or similar proceeding, in which Personal Information the Company holds is among the assets transferred; and
• In other ways we describe when you provide the information.

Sharing of Information

We may share, sell, or rent your information in aggregate or on an individual basis to Company affiliates and other parties with which the Company has a business relationship. We may sell, divest, transfer, assign, or otherwise engage in a transaction that involves some or all of our assets in the course of a corporate divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any similar transaction or proceeding. Your information may be transferred in the context of such a transaction.

In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose: Internet Protocol Addresses.

In the preceding 12 months, we have sold the following categories of Personal Information: Internet Protocol Addresses.

We may share your information with service providers providing services to the Company, such as email and text message distribution, data processing, mobile and website analytics, website hosting, advertising services, and list management. We may also share aggregated information collected through surveys with advertisers.

We may disclose your information if we are required to do so by law, for example in response to a court order or subpoena, or in response to a legal agency’s request. We may also disclose your information to protect against misuse or unauthorized use of the Site or to protect the personal safety of our users or the public.

Third Party Data Collection

We may allow third-party companies to collect certain information when you visit our Site. These companies may use cookies, flash cookies, web beacons, device fingerprinting, or other technologies to collect and use non-personally identifiable information (e.g., hashed data, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this Site and other web sites in order to provide advertisements about goods and services likely to be of greater interest to you and to follow activities related to their advertisements placed on the Site. We have no control over, do not review, and are not responsible for such third-party websites. This Privacy Policy does not apply to third-party websites. We recommend that you learn about the privacy policy and security practices of such third-party websites before providing them with any Personal Information.

Some of our advertisers, ad servers, and third-party providers also use cookies to provide us with anonymous data and information regarding your use of the Site. We do not have access or control over such parties’ cookies. Our Privacy Policy does not cover the use of cookies by third parties.

This site is being monitored by one or more third-party monitoring software(s), and may capture information about your visit that will help us improve the quality of our service. You may opt-out from the data that https://doublesmart.digital is collecting on your visit through a universal consumer options page located at https://doublesmart.digital/Unsub/unsub.html. We may also use the data collected to send you direct marketing messages in the future. 

Data Security

We have implemented security procedures to help protect the Personal Information on the Site. However, no method of transmitting or storing electronic data is ever completely secure, and we cannot guarantee that such information will never be accessed, used, or released in a manner that is inconsistent with this Privacy Policy. We recommend that you use complex passwords for any accounts you have with us, and, if you believe your interaction with us is no longer secure, please notify us by email at privacy@foundationpartners.com.

International Transfers

The Site is headquartered in the United States. Information you provide to us or that we obtain through your use of the Site may be collected in your country and then transferred to the United States or to another country in accordance with applicable law. You consent to the collection, international transfer, storage, and processing of your information when you use the Site.

Your Opt-Out Choices

If you want to opt out from a Company email newsletter or commercial email list, use the unsubscribe link at the bottom of each message or send us an email at privacy@foundationpartners.com with the email address at which you no longer wish to receive newsletters or commercial emails. If you requested third-party email through our Site and no longer wish to receive the email, simply follow the advertiser’s unsubscribe link or opt-out instructions that should be included in the commercial message you received. If you want to disable web beacons in our email messages, turn images “off” in your email system (e.g., Outlook or Outlook Express). Check the settings or options menu in your email system for more information.

To remove your name and postal address from lists that we sell or rent to third parties for the purpose of marketing goods and services, please send your request to us in a letter addressed as follows:

Foundation Partners Group, Postal Opt-Out

Attn: Legal Department

4901 Vineland Road, Suite 300

Orlando, FL 32811

Or by email to: Legal@FoundationPartners.com

The Company, our authorized service providers, and/or other third parties involved in the delivery of advertising you receive through our mobile applications may collect information about your mobile device, including unique anonymous advertising identifiers and the names and IDs of apps you have installed, as well as information about how you use our mobile applications and other unaffiliated applications. This information is used in connection with interest-based advertising you receive through our Site and within third-party apps and other marketing channels. Depending on your device and operating system, you may be able to reset your mobile device’s advertising identifier to limit this data collection or prevent the collection of usage data across unaffiliated applications for interest-based advertising purposes by accessing the privacy settings on your mobile device. Each operating system, iOS for Apple devices and Android for Android devices, provides its own instructions on how to turn off tailored in-app advertising. Access the privacy settings for your mobile device or contact your platform operator for more information. To exercise choice over the companies participating in the DAA’s separate choice tool for the collection of cross-app data on a mobile device, download the DAA’s AppChoices app available here.

If you agreed to allow the Company and/or our service providers to collect and/or share information about the precise location of your device by tracking a mobile application, you can withdraw your permission by accessing and changing your device’s location privacy settings. This will prevent further collection of your precise device location information. Each operating system, iOS for Apple devices and Android for Android devices, provides its own instructions on how to turn off precise location sharing. Access the privacy settings for your mobile device or contact your platform operator for more information.

Children Under 13

The Site is not intended for children under 13 years of age, and the Company does not knowingly collect information from children under 13. If you are under the age of 13, do not: use, or provide any information on, the Site; make any purchases through the Site; use any of the interactive or public comment features of the Site; or otherwise provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name 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 personal information from or about a child under 13, please contact us privacy@foundationpartners.com.

Your California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once a calendar year, information about the customer information we shared, if any, with other businesses for their direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2021 will receive information regarding 2020 sharing activities). To obtain this information, please send an email message privacy@foundationpartners.com with “Request for California Privacy Information” in the subject line. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in our response.

California residents who are registered users of the Site and are under the age of 18 are entitled, in accordance with California law, to request and obtain removal of content and information that they themselves post on the Site. You may request such removal by emailing us at privacy@foundationpartners.com. In your request, please provide a description of the material that you want removed and information reasonably sufficient to permit us to locate the material and the subject line “California Removal Request” so that we can process your request.

Company does not currently recognize or respond to browser do-not-track signals. Instead, we adhere to the standards set out in this Privacy Policy and offer the opt-out choices described above.

Data Access and Portability

If you are a California resident, you have the right to request that we disclose certain information about our collection and use of your Personal Information during the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we collected about you;
• The specific items of Personal Information we collected about you;
• The categories of sources of Personal Information we collected about you;
• Our business purpose for collecting or selling that Personal Information;
• The categories of third parties with which we share Personal Information; and
• If we sold or disclosed your Personal Information for a business purpose, we will provide a list of the sales with the categories of Personal Information that the recipients purchased and, for disclosures, we will provide a list of the sales with the categories of Personal Information that the recipients received.

Deletion Request Rights

If you are a California resident, you have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

If you are a California resident and you wish to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by calling us at 888-788-7526 or by emailing privacy@foundationpartners.com. Only you, or a person registered with the California Secretary of State whom you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You also may make a verifiable consumer request on behalf of your minor child.

• You may make a verifiable consumer request for access or data portability only twice within a 12-month period. A verifiable consumer 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.
• 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 use Personal Information provided in a verifiable consumer request only to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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 cover only the 12-month period preceding the verifiable consumer request’s receipt. 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 from one entity to another entity without hindrance, specifically by electronic mail communication.

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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

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

Your Nevada Privacy Rights

If you are a Nevada resident and you wish to instruct Company not to sell your personally identifiable information (as that term is defined in Nevada law), please send a request that we can, if necessary, verify through commercially reasonable means to privacy@foundationpartners.com or call 888-788-7526.

Changes to our Privacy Policy

We may amend this Privacy Policy at any time in our sole discretion. We encourage you to review this Privacy Policy whenever you visit the Site to see if it has been updated since your last visit.

Questions about our Privacy Policy

If you have questions about our Privacy Policy or regarding exercising your rights under California law or other applicable laws, please do not hesitate to contact us at 888-788-7526, or by email at privacy@foundationpartners.com, or by mail at Foundation Partners Group, Attn: Legal Department, 4901 Vineland Road, Suite 300, Orlando, FL 32811.