Privacy Policy
SUMMARY
This Privacy Policy applies only to the information collected through the website, systems and platforms located at www.prosper360.com and any other Prosper360, LLC (“P360”) websites where it is posted (collectively, the “Sites”). By visiting the Sites, you accept the practices described in this Privacy Policy for any information you provide and have provided in the past through the Sites, or those collected from your usage of the Sites.
P360 Understands the Importance of Privacy
We need to collect your personal information in order to administer and provide you with those of our services you subscribed to, to customize our services and contents to your interests, and otherwise conduct our business operations and activities, including improving and marketing our services, in accordance with this Privacy Policy. In that regard, we are committed to protecting your privacy and want to make sure that you understand how your personal information is used.
What Personal Information We Collect
When you subscribe to one of our services, we request the basic information to provide you with that service. When you apply for membership, we ask for basic information such as your name, contact information, email address, physical address (optional), birthdate and company information.
When you register with the Sites, we collect the necessary information to proceed with registration to the Sites, namely your name, email address, physical address, payment information, business scope and valuation, and other autobiographical information, and you can also provide additional information in your profile, such as your phone number, instant message identifier, birthday, marital status, professional experience, education background, family members’ names and similar autobiographical information, photos, hobbies, and other interests. When you visit the Sites, we receive data about your interaction with various functionalities on the Sites, such as when you join a group and share information with other members. We also receive information about you from other members, such as when they add you to a group or “tag’” you in a publication or other content on the Sites. As explained in the Questions and Answers below, we may ask for additional information in your visits to the Sites. We keep track of your participation in P360 activities and member services so we can understand our members’ interests and evaluate the effectiveness of our offerings. Where permitted by applicable law, we also collect demographic information from other sources to help us learn more about member characteristics and needs. All of this information helps us better serve our members and improve our programs.
Why and When we collect personal information
P360 collects your personal information in order to conduct its business operations and activities, market and sell our services and provide you with our services.
We collect your personal information when you visit and otherwise use the Sites (e.g. to publish content or information), when you register with the Sites, provide us with such information using electronic or paper form, buy our services, contact us by telephone, fax, email, post, the Sites or any other mean, contact our care service or provide feedback on our services.
Please note that by registering at the Sites, or by otherwise providing information on the Sites, you understand that the data that you provide to us will be transferred to and processed in the United States.
Information Sharing
We may share your personal information with companies we have selected to provide official P360 member services or support P360 operations. Our contracts with these companies require them to maintain an adequate level of protection of the personal data, and to keep the information confidential and secure, and allow them to use the information only under P360’s instructions and in order to offer the contracted services to P360 and P360 members. We may release personal information on the rare occasions when we are required to do so by law, or when necessary or appropriate to comply with legal process or to protect or defend P360 and its members in compliance with applicable law. We do not sell or rent personal information to telemarketers, mailing list brokers or any other companies except as specified explicitly in this Privacy Policy.
Information Retention
We store your personal information for as long as necessary to provide the services you have requested, or for other business purposes such as but not limited to: complying with our legal obligations, resolving disputes and enforcing the agreements to which P360 is a party. P360 is required by law to keep some types of information for certain periods of time (e.g. Federal Internal Revenue Service (IRS) requires a period of seven (7) years after a customer terminates their relationship.). If your personal information is no longer necessary with respect to purposes for which it is processed and P360 has no legal obligation to retain that personal information, we will anonymize the data by following P360’s data destruction process.
What Rights do I have with respect to my personal information?
Under applicable law, you may be entitled to access the personal information that we hold about you. If you request access to your personal information, in ordinary circumstances we will give you access to your personal information. However, there may be some legal or administrative reasons allowing us to deny such access. If we refuse your request to access your personal information, we will provide you with reasons for the refusal where we are required by law to give those reasons.
You can access and correct some of your personal information through the Sites by logging into your account and updating or editing your profile at any time. Alternatively, a request for access can be made by contacting us using the details provided below.
P360 uses its best efforts to ensure that any personal information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete. Please tell us if any change occurs regarding the personal information you provided us with, notably by updating or editing your profile or contacting us in any of the ways specified below if you believe that the personal information is inaccurate or incomplete, and we will correct the information.
If you reside within the European Union, you have the right to ask for a copy of your personal information and/or ask for it to be ported to another provider of your choice.
Please note that such a request may be limited to the sole personal information you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures.
If you are not satisfied with our answer or the way P360 processes your personal information pursuant to this Privacy Policy, you may also have the right to lodge a complaint with a data protection authority. If you reside within the European Union, a list of national data protection authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
Privacy Questions and Answers About the Sites
The following Questions and Answers address privacy issues about the Sites in more detail and form part of the P360 Privacy Policy. We want to make sure that you understand the types of information that are collected at P360 and through the Sites and the ways in which that information is used and protected. Specifically, this Privacy Policy answers the following frequently asked questions:
1. Do I have to submit any personal information in order to use the Sites?
2. Do the Sites collect non-personal information, using “cookies” or otherwise?
3. How is this information used, and can I control its use?
4. Is any information shared with other companies or organizations?
5. What privacy rules apply when I “click” over to other web sites?
6. How do the Sites protect security and confidentiality?
7. Will this privacy policy ever change?
8. Who can I contact with questions or comments about privacy issues?
1. Do I have to submit any personal information in order to use the Sites?
If you want to take advantage of being a member of P360 or use of the member services available on the Sites, we will sometimes request information that allows us to identify you. If you use the online form or paper application to join P360 or renew your membership, for example, we will ask for certain information to process your application (name, company information, phone number, mailing address, email address, family information, credit card number and other various pieces of information) in accordance with our Privacy Policy. You will receive email newsletters and we may also ask for personal information necessary when you participate in other activities or services on the Sites, such as surveys and event registration.
We also have relationships with certain contractors, providers and vendors that we have selected and approved to offer services and benefits, whether directly or on linked sites (together, “Approved Vendors”). On some of these linked sites, you may be asked to enter personal information in order to take advantage of their services or programs. If you decide to purchase services on the website of one of our member benefits Approved Vendors, the contracted member benefit Approved Vendor offering the services may ask for your name, member number, address, and email in order to contact you about the services, under its own privacy policy and privacy practices, save its contractual privacy and confidentiality obligations pursuant to the contract it entered with P360.
On the Sites, members may be able to create an autobiographical profile that will be visible to P360 members and their spouse or partner or other family members who have been granted access to members only portions of the Sites. The Sites also provide forums, applications, and functionalities that allow you to communicate and share information with other members, their spouses or partners, and other family members. The information that you share with others can then be copied or reshared by them. When you use these social networking tools, you control what information and how much information you share. You can also choose not to use these social networking tools. The information you choose to provide to P360 may reveal, or allow others to identify, your nationality, ethnic origin, gender, age, religion and other aspects of your life. Supplying information to P360, including any information deemed “sensitive” by applicable law, is entirely voluntary on your part and under your sole responsibility.
Again, regardless of whether you are visiting the Sites or an affiliated site, you do not have to disclose any personal information if you do not want to. We are only interested in offering you convenient services that match your interests and needs.
2. Do the Sites collect non-personal information using “cookies” or otherwise?
We also collect other types of information that do not allow us to identify your name, email address, or other personal characteristics. This “non-personal information” includes the number assigned to your computer whenever you access the Internet (“IP address”), and the type of browser you use. None of this non-personal information allows us to identify or contact you directly. We use this information to help us evaluate how the site is being used. By gathering this information, we can learn, among other things, how many people visit the site, which pages are the most and least popular, and which other web sites are the most frequent referral sources for P360.
COOKIES
Below are additional details about how P360 collects and processes information collected via the Sites using cookies, as well as additional details about the choices and rights you have regarding our collection and processing of such information.
p360 Use of Cookies
We use cookies and similar technologies on the Sites, which P360 or our partners or service providers may place on your device. A “cookie” is a small text-file stored on your device (desktop, laptop, smartphone) that allows us to recognize your computer each time you visit the Sites as well as to collect information in order to customize your experience on the Sites and for analytics purposes, e.g. how many people visit the site, and which pages are the most and least popular. We may receive reports based on the information collected using cookies from our partners or service providers on an aggregated level.
P360 also partners with third-party advertising networks providers to either display advertising on the Sites or manage and administer P360’s advertising on third-party websites. Our partners use cookies and other tracking technologies to collect information relating to your activities on the Sites for the purpose of providing you with advertising tailored to your centers of interest. You may refuse to have your information used for the purpose of serving you with advertising relevant to you and tailored to your interests using an opt-out tool, e.g. network advertising initiative online opt-out tool. Please note that you will still see advertising if you opt-out.
Google Analytics
We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- DoubleClick Platform integrations
- Google Analytics Demographics and Interest Reporting
By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Sites. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Sites, and match the right audience with the right advertising message.
You can opt-out of Google’s use of cookies by visiting Google’s ad settings and/or you may opt-out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.
As advertisers on Facebook and through our Facebook page, we, (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Privacy Policy. You consent to our collection of such information.
We abide by Facebook’s Data Use Restrictions.
- Any ad data collected, received or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
- We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
- We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
- We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.
You may adjust your web browser settings to limit or block all or certain types of cookies, if you do not wish the Sites to install cookies on your web browser for the purposes described above.
If you disable certain cookies, notably first party technical cookies, the Sites may not function as intended.
3. How is this information used?
Our primary purpose in collecting this information is to provide you with the services you request, provide you with customized content, allow you to interact with other members, and to evaluate and improve other services that we offer now and in the future, both on the Sites and offline. As explained above, for example, we ask for information so that we can process your membership application, send you the email newsletters, and allow your use of the functionality on the Sites. We may also use this information for other purposes. For example, we may review demographic information, survey results, and statistical analyses regarding the Sites usage in order to help us evaluate, modify, and develop services that are likely to be of interest to our members, pursuant to the principles described in our Privacy Policy.
On occasion, we will also use your membership information to send you information about special member benefits and offers, and new features and groups on the Sites. If you initiate communications with other members through the Sites, those communications will include your name, email address or other communication identifier, and, if applicable, group information.
4. Is any information shared with other companies or organizations?
P360 takes seriously its responsibility to keep your personal information confidential and private (see Question 6 below). We do not sell or rent any of your personal information to telemarketers, mailing list brokers, or any other companies that are not offering or otherwise providing on behalf of P360 P360-endorsed services or benefits. As explained above, we share member information with the limited number of Approved Vendors that we have selected to provide P360 member services. Like most organizations, we also hire companies to provide certain administrative services that require access to member information, such as processing address labels, managing databases, and sending mailings.
We require all of these P360 service providers and Approved Vendors to hold member information in confidence. These providers and Approved Vendors are contractually required to maintain the security and confidentiality of all member information using appropriate technical and organizational means to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and they are prohibited from using that information for any purpose other than providing the services specified in their contracts with P360 and following P360’s instructions.
We may, at our discretion, audit and monitor these companies and Approved Vendors to ensure that members’ personal information they hold is protected. We may also disclose personal information when required to do so by applicable law or when such action is necessary or appropriate to comply with legal process served on P360, to protect and defend the rights or property of P360, or to protect the personal safety of users on and off the Sites. We reserve the right to contact the appropriate authorities in our discretion when visitors’ activities appear to be illegal or inconsistent with our policies. Your personal information may also be transferred, stored, processed or used outside of the United States and/or outside of the European Union by us or by third party Approved Vendors for purposes described in this Privacy Policy. This may happen if our related entities or venture partners or Approved Vendors are overseas, if we outsource certain activities overseas or if transactions, information, services or products have an overseas connection (such as when you attend an activity or event outside of your country of residence).
In any event, should a transfer of your personal information occur that is not described in this Privacy Policy, you will be informed of the collection, use, storage and processing of your personal information in those countries and the other countries referred to in this section. Where required by applicable privacy and data protection laws, we take steps in order to ensure any overseas transfer of personal information is performed in compliance with the appropriate organizational and technical means (including e.g. EU Commission’s model clauses for data transfers or European Commission’s adequacy decision). Where such parties are located overseas, you may have rights to enforce such parties’ compliance with applicable data protection laws, but you may not have recourse against those parties under the privacy laws of your country of residence, in relation to how those parties treat your personal information.
5. What privacy rules apply when I “click” over to other web sites?
The Sites include links to other web sites, some of which are operated by P360 service providers or approved vendors, and some of which are not. Sites operated by P360 service providers and approved vendors may also collect personal information and sites operated by third parties not affiliated or related to P360 may have their own privacy policies that differ from, and are not covered by or governed by this Privacy Policy. It is important that you review any privacy policies on these sites carefully before you use any services or programs offered.
When you click to unaffiliated third-party sites, P360 is not responsible for, and has no control over, the information collection or privacy practices of that site. It is important that you review and understand the privacy policies posted on any linked third-party sites you visit before volunteering any of your personal information.
These sites may also collect cookies, or allow third-party advertisers on their sites to collect cookies. You can often find information regarding a site and its privacy policy on the site’s home page. If you cannot find or do not like a site’s privacy policy, you may prefer not to do business with, or offer information to, that site.
6. How do the Sites protect security and confidentiality?
In order to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, we use appropriate technologies and processes such as encryption, access control procedures, network firewalls, physical security and other measures. Only our authorized employees, agents or independent contractors carrying out permitted business functions are allowed to access personal information to which access is rendered necessary. Employees, agents and independent contractors who violate our privacy access policies may be subject to disciplinary actions, including termination when appropriate.
In order to provide you with some services, we may require you to use a confidential password to protect your membership account from unauthorized access by others. You are responsible for maintaining the secrecy of your confidential password and account information, and for controlling access to your communications on the Sites at all times. If you do allow others, including family or household members, to access P360 members-only services through your personal password or to use your membership account number, please understand that you are responsible for the actions of those individuals.
Please note that emails, instant messaging and similar means of communication with other members are not encrypted, and we advise you not to communicate any confidential information through these means.
7. Will this Privacy Policy ever change?
This Privacy Policy describes the types of information we currently collect, and the ways we use and protect that information. If you are uncomfortable with our policies and practices regarding personal information, please do not provide any personal information to us through the Sites. This Privacy Policy was last updated 1 December 2022.
From time to time, where permitted or required by applicable law, we may collect different types of information and use that information in different ways for example, when we add features or services to the Sites or to reflect a change in our legal obligations. In these cases, we will provide you with appropriate information, either via the Sites or our Privacy Policy.
Consequently, we may edit this Privacy Policy to explain our new practices or changes thereto. If we do make significant changes in our practices or to this Privacy Policy, we will include announcements on the Sites’ pages, so that you will know to review the revised Privacy Policy. If you object to any changes, you may delete your account by contacting us. By continuing to use the Sites thirty (30) days after notice of changes has been sent to you or published on the site, you will provide implied consent to the changes and agree to be bound by them.
8. Who can I contact with questions or comments about privacy issues?
If you have any questions or comments about your personal information or this Privacy Policy, please send an email to dataprivacy@prosper360.com. We will do our best to investigate any question you may have and respond promptly to your concerns. If you are not satisfied with our answer or the way P360 processes your personal information pursuant to this Privacy Policy, you may also have the right to lodge a complaint with a data protection authority. If you reside within the European Union, a list of national data protection authorities can be found here:
http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm.