1. Introduction
Compare Nodes LLC, (hereafter “CompareNodes”, “the Company”, “We”, “Us”) takes privacy seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. By providing us with your personal information and using our services, you are accepting and consenting to the practices described in this policy. It also explains your rights in relation to your personal information and how to contact us or the supervisory authority in the event you have a complaint.
We collect, use and process certain personal information about you. There is no comprehensive national privacy law in the United States. However, there are many privacy laws at the state (and local) level, which may impact your rights. You are advised to stay current with these laws.
California Privacy Rights. If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act of 2020 (CPRA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California.
Interaction With Children Online
The Department is committed to the protection of children’s online privacy. The Children’s Online Privacy Protection Act (COPPA) governs information gathered online from or about children under the age of 13. Verifiable consent from a child’s parent or guardian is required before collecting, using, or disclosing personal information from a child under age 13. If this website intends to collect information about children under 13 years old, COPPA-required information and instructions will be provided by the specific web page that collects information about the child. The web page will specify exactly what the information will be used for, who will see it, and how long it will be kept.
2. Definitions
“Applicable Regulations” shall mean (a) rules of a relevant regulatory authority having powers over the Company; and (b) all other applicable laws, rules and regulations of JURSIDICTION and/or of another jurisdiction.
“Company” shall mean :Compare Nodes LLC. with a registered address at 192 Benmore Dr, Hayward CA 94542 and a registration number of 202355912489.
“Cookies" shall mean small text files created and stored on your hard drive by your internet browser software, which hold relevant information about the web page you are currently viewing.
“Data Protection Officer” (“DPO”) shall mean an officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy officer using the details set out below.
Simon Radovcicsimon@comparenodes.com
“Personal Identifiable Information” (PII) shall mean any information relating to an identified or identifiable individual.
“Sensitive Personal Information” (SPI) shall mean a special classification for PII and contains very sensitive information sets such as: Social Security Number; Driver’s license;
State identification card; Passport Number; Financial account information and log-in credentials; Debit Card or Credit Card number along with access codes; Precise geolocation data; Religious or philosophical beliefs; Ethnic origin; Contents of communication; Genetic data; Biometric information for identification; Health information; Information about sex or sexual orientation.
“Website” shall mean the Company’s website at https://www.comparenodes.com/ or such other website as the Company may maintain from time to time.
3. Information we collect about you
We will collect and process the following data about you:
■ Information you give us: This is information about you that you give us by filling out our user forms/agreements, or by corresponding with us by phone, email, in person, or otherwise. It includes information you provide when you choose to use our website or services, participate in any event, and when you send any information to us in any capacity. This information may include but is not necessarily limited to the stated areas,
■ Identity data such as name, address, date of birth, username or similar identifier, title, gender.
■ Identity verification data such as the images of your government issued ID, passport, national ID card, utility bill or driving license.
■ Contact data including your address, messenger or social media handles, email address and telephone numbers.
■ Financial data such as your financial position, status and history, and payment account details which can include bank, credit card, or other payment details.
■ Transaction data which includes details about payments to and from your accounts with us.
■ Technical data includes details about the devices you use to access our services including internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or services.
■ Social media data includes social media handles and other social media profile information that you make available to us or to the public.
■ Usage data which includes information about your use of our website, products, and services. We utilize Plausible.io as our analytics provider for this purpose. Please refer to the following link for details on the data they collect: https://plausible.io/privacy-focused-web-analytics
■ Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
■ Aggregated data includes statistical or demographic data for any purpose. This type of data can be created from personal data but legally is not considered personal data because it does not directly or indirectly reveal your identity. If this type of data is connected to your personal data so you are directly or indirectly identified, this will be handled under this privacy notice.
■ Information we collect/receive from other sources: This is the information we receive about you if you use any of the websites we operate or the services we provide and/or from other affiliates and/or professionals. We are working closely with third parties (including, for example, business partners, brokers, payment service providers, analytics providers, search information providers, credit reference agencies). We may notify you when we receive information about you from them and the purposes for which we intend to use that information.
■ Information you share while using the Node Comparison Tools: If you use our Node Comparison Tool, please refer to our separate privacy policy document for information about the data we collect and how we use it. By using the tool, you agree to the terms outlined in the Privacy Policy for Node Comparison Tool.
In certain cases we require personal data by law, or under the terms of the service we are providing to you. If that data is not provided, we may not be able to complete the provision of the service. If so, we will inform you if we have to cancel the service.
4. How we use your data
We use the information we collect about you in the following ways:
■ To carry out our services and obligations arising from your use of the website and any agreements and/or contracts including the Terms of Use between you and us and to provide you with the information, products and services that you request from us.
■ For our legitimate and permitted interests or those of a third party, for example, to prevent and detect fraud/unauthorized access to our systems that can be damaging to us and you and services or to study how customers use our products/services, to develop them, to grow our business,to inform our marketing strategy to develop new products/services and grow our business.
■ To comply with our legal and regulatory obligations, for example, conducting checks to identify our customers and verify their identity as required by relevant regulations to which we are subject.
■ To provide information to you with information about other services we offer that are similar to those that you have already used or enquired about or to notify you about changes to our services.
5. Disclosure of your information
You agree that we have the right to share your information with:
■ Any team member of our company for the purpose of ensuring we maintain a correct record, understanding and response regarding all of your communications, requests, responses and interests with us and only as appropriate to ensuring a helpful, constructive business relationship between you and our company, this may include anyone in our group of companies including subsidiaries or our holding company or any of our agents or partners;
■ Selected third parties we use to help deliver our products and/or services to you including: business partners, brokers, vendors, insurers, fraud prevention services, payment service providers for the performance of any contract we enter into with them or you; analytics and search engine providers that assist us in the improvement and optimization of our site.
■ For the purposes of complying with local and international regulations against money-laundering, fraud and the general prevention of crime and illegal activities, we maintain communications with law enforcement agencies and regulatory bodies of those jurisdictions relevant to your citizenship and our legal requirements for compliance with those regulations including for tax reasons. This may include as well for the pursuit of our own legal claims.
We will disclose your personal information to third parties:
■ In the event that this is necessary for the delivery of our products and/or services to you;
■ If Compare Nodes LLC, or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
■ If we are under a duty to disclose or share your personal data to comply with any legal and/or regulatory obligation, or to enforce or apply our terms and other agreements, or to protect the rights, property, or safety of Compare Nodes LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, anti-money laundering and credit risk reduction;
We only allow the third parties we work with to process your personal information if we are satisfied on how they take appropriate technical and organizational measures to protect your personal information. We also impose contractual obligations on our selected third parties to ensure they can only use your personal information to provide services to us and to you. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Cookies
We may use cookies and pixel tags to monitor and observe your use of our websites, compile aggregate data, and provide a more effective service including customization. Most internet browsers allow you to disable cookies, however this may reduce website function. “Pixel tags” are small blocks of code on a webpage. They can include information such as your IP address, the time you viewed the pixel and the type of browser being used.
6. Where we store your personal data
All information you provide to us is stored on secure servers. Where we may have given you (or where you have chosen) a password which enables you to access certain parts of our site and/or use any other of our services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
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 us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7. Duration your personal information will be kept
We will keep your personal information while you have an account with us or while we are providing services and/or products including use of our website to you or while we are in a contractual relationship with you. Thereafter, we will keep your personal information for as long as is necessary:
■ to respond to any questions, complaints or claims made by you or on your behalf;
■ to show that we treated you fairly;
■ to keep records required by law, regulations and regulatory authorities.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.
By law we are required to keep certain data for minimum periods, namely:
■ we must retain Transaction Data for a minimum of six years after the date of the transaction;
■ we must retain certain Account Information, for a minimum of six years after your agreement with us has ended.
The majority of personal data we hold will be deleted 10 years after the termination of any agreement you have with us unless it is needed for other necessary or legitimate purposes. In some circumstances you can ask us to delete your data: see request erasure below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your rights
You have the following rights, which you can exercise:
● Right to correction, meaning you can request to have PII and SPI corrected if they are inaccurate.
● Right to opt-out of automated decision making, so that users can say no to their PII and SPI being used to make automated inferences, e.g. in profiling for targeted, behavioral advertisement online.
● Right to know about automated decision making, meaning users can request access to and knowledge about how automated decision technologies work and what their probable outcomes are.
● Right to limit use of sensitive personal information, meaning users can make businesses restrict their use of this separate category of personal information, particularly around third-party sharing.
● Right to delete, meaning users can request deletion of PII and business now have to notify third parties to delete this as well.
● Right to know, meaning users can request access to PII collected on them. You may request, up to twice in a 12-month period, the following about the personal information collected on you in the past 12 months:
o the categories and specific pieces of personal information we have collected;
o the categories of sources from which we collected the personal information;
o the business or commercial purpose for which we collected it;
o the categories of third parties with whom we shared the personal information; and
o the categories of personal information about you that we disclosed for a business purpose.
6● Right to opt-out, where users can opt out of businesses sharing and selling their PII specifically for behavioral advertisement.
● Rights of minors, where minor users must opt-in for the sharing of PI for behavioral advertising.
● Right to data portability, users can request to have their PII transported to other businesses or organizations.
Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
We aim to comply with requests of data subjects as quickly as possible and will ensure that we comply with legislation, unless exceptions apply. In such cases, the reasons for any delay will be explained in writing to the data subject making the request.
In processing a request, the identity of the data subject needs to be verified before information will be released. No personal data will be disclosed to a third party without the written consent of the data subject.
We reserve the right to refuse repeated/vexatious requests.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless they are clearly repetitive or vexatious.
For further information on each of those rights, including the circumstances in which they apply, please contact our DPO.
9. Keeping your personal information secure
We have appropriate technical and organizational security measures to prevent personal information from being accidentally lost, used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breaches. We will notify you and the relevant supervisory authority of a suspected data security breach when we are legally required to do so.
10. Complaints procedure
Compare Nodes LLC has the highest standards to protect your privacy. However, if you are concerned about the way in which we are managing your personal data and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact our Data Protection Officer. We will deal with the matter as soon as we can, and keep you informed of the progress of our investigation.
You have the right to make a complaint at any time to any relevant Data Protection Office or Department including the California Privacy Protection Agency (CPPA). However, we would appreciate it if you could allow us the opportunity to address your concerns before you approach their office.
11. Changes and updates to your data and this privacy policy
This privacy policy was last updated at the date appearing at the top of this page. We are constantly reviewing how we process and protect data. Therefore, changes to our privacy policy may occur at any time and at our sole discretion. You are advised to check the website regularly for any amendments.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
12. How to contact us
Please contact our DPO by email if you have any questions about this privacy policy or the information we hold about you.
If your concern is related to California Privacy Rights, You may also contact us via postal mail, proper postage prepaid, at:
Compare Nodes LLC
Attn: Your California Privacy Rights
192 Benmore Dr, Hayward CA 94542
Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail). All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.