Effective Date: January 1, 2020
Last Updated: January 1, 2020

Summit Resources LLC doing business as Client Command (referred to herein as “Client Command”, “we”, “our”, or “us”) and its affiliates recognizes the importance of protecting the personal information we may collect from customers, users and any other individual or entity (“Users”, “you”, or “your”). This Privacy Policy applies to data collection and privacy practices of Client Command and when we collect personal information through your use of the website, www.clientcommand.com, and other Client Command-related sites, software and applications accessible on or by any top-level Client Command domain owned by us (each, a “Site” and collectively the “Sites”), through our social media pages that we control, and through email messages that we may send to you, (collectively, the “Services”).  Please note that this Privacy Policy excludes services that state that they are offered under a different privacy policy.

Specifically, our Privacy Policy covers the following topics:

1. When This Privacy Policy
2. Information We Collect
3. Information Collected Related to California Residents
4. How We Use Personal Information We Collect
5. Sale of Personal Information
6. Our Legal Basis for Collecting Personal Information
7. Cookies and Similar Technologies
8. Your Failure to Provide Personal Information
9. Our Retention of Your Personal Information
10. Sharing Personal Information
11. International Transfer
12. Your Privacy Choices
    1. a. Privacy Rights Specific to Californians
13. Exercising Your Privacy Rights
14. Your Marketing Choices
15. Links to Other Websites
16. How We Protect Personal Information
17. Children’s Privacy
18. Direct Marketing and “Do Not Track” Signals
19. Privacy Policy Modifications
20. How to Contact Us

Please familiarize yourself with our privacy practices. As one of our visitors using the Sites or Services, you understand and agree that we collect, use and disclose your Personal Information in accordance with this Privacy Policy.

If you have any questions or comments about this Privacy Policy, please submit a request to privacy@ClientCommand.com.

When this Privacy Policy Applies

 Our Privacy Policy applies to all the services offered by Client Command and its affiliates and services offered on other sites but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads. 

Information We Collect

We collect information, including personal information, to provide better Services to all our customers and users. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, information about your device, and certain metadata.

The Personal Information which we collect includes, but is not limited to, the following circumstances and data elements:

• • If you express an interest in obtaining additional information about our Services, request customer support, use the “Contact Us” or similar features on our Site, register to use our Sites or Services, or download certain content, we may require that you provide to us your contact information, such as your name, billing address, shipping address, email, phone number, zip or postal code, and user name and password, by completing forms on our website;
  • To process payments, you may provide us with certain personal information such as the first and last name of the payment card owner, credit card billing address, payment card number, payment card expiration date, bank account information and routing numbers, phone numbers and email;
  • If you report a problem or have a question about our Services, you may provide us with contact information, such as a phone number or email address;
  • If you use and interact with our Sites or emails, we automatically collect information about your device and your usage of our websites or emails through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Information under applicable law;
  • If you voluntarily submit certain information to our Services, such as filling out a survey about your experience or entering a contest or promotion, we collect the information you have provided as part of that request; and
  • If you apply for employment with us, you will be required to pass a background check, which includes providing us with information about your past employment history, any professional disciplinary records, criminal records, academic background and submit to drug testing.

If you provide, us or our service providers, with any Personal Information relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Policy. If you believe that your Personal Information has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Information, please contact us by using the information set out in the “How to Contact Us” section below.

Information Collected Related to California Residents

During the last twelve (12) months, we have collected the following categories of personal information from consumers.

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

• • Directly from our customers or their agents. For example, from information that helps us monitor and communicate campaign performance.
  • Indirectly from our customers or their agents. For example, through information we collect from our clients in the course of providing Services to them.
  • Directly and indirectly from activity on our website (www.clientcommand.com). For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
  • From social media websites, such as Facebook, Twitter, LinkedIn, YouTube, Instagram, and Pinterest.
  • From third parties that assist us in providing certain transactions and services (e.g. payment processing, hosting), even though it appears that you may not have left our Site.

How We Use Personal Information We Collect

We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

• • To present, operate or improve the Site and Services, including analysis of Site activity;
  • To inform you about Services and products available from Client Command;
  • To authorize access to our Sites and Services;
  • To validate your identity or verify communications from you;
  • To offer and administer programs;
  • To customize or tailor your experience of the Services;
  • To manage, store and enhance customer data and preferences;
  • To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, prize draws and other offers or promotions, and to deliver pertinent emails;
  • To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Services;
  • For marketing purposes, including but not limited to, facilitating interest-based advertising, creating custom audiences to target online and mobile advertising, sending integrated marketing messages across channels and devices, personalizing email marketing that we send to you, sending you other promotional materials, and notifying you about special promotions, offers, events or opportunities that may be of interest to you;
  • To improve our customer service, conduct customer satisfaction, market research, and quality assurance reviews;
  • To respond to and support users regarding their use of the Sites and Services;
  • To process applications for employment that you submit through the Sites;
  • To administer general recordkeeping;
  • To comply with all applicable legal requirements;
  • To investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm our customers.
  • For any other purpose that is disclosed to you at the point of collection of the personal information, for any purpose for which you provide your prior consent, or for any other lawful purpose.

We and our service providers may use IP addresses to understand the locations from which our customers and users are accessing the Services.  Except where prohibited by applicable law or regulation, we may combine information collected through one source with information obtained through other resources. We also may supplement the information we collect with information obtained from third parties. We will treat any information that we combine with your personal information as Personal Information pursuant to this Privacy Policy.

We may use your Personal Information in furtherance of our legitimate interest to provide you with the Services offered by Client Command. We may also use your information to manage our contractual relationship with you or to comply with our legal obligations.

To the extent we rely on consent for the processing of your Personal Information, we will seek such consent at the time we collect your personal data. We may also use the Personal Information we obtain about you in other ways for which we provide specific notice at the time of collection.

Sale of Personal Information

In the preceding twelve (12) months, we have not sold any Personal Information.

Our Legal Basis for Collecting Personal Information

Whenever we collect Personal Information from you, we may do so on the following legal bases:

1. Your consent to such collection and use;
2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
   1. a. Intra-organization transfers for administrative purposes;
   2. b. Product development and enhancement, where the processing enables Client Command to enhance, modify, personalize, or otherwise improve our Services and communications for the benefit of our customers and to better understand how people interact with our Sites;
   3. c. Fraud detection and prevention;
   4. d. Enhancement of our cybersecurity, including improving the security of our network and information systems; and
   5. e. General business operations and diligence;

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are, or could be, put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit one of our Sites or Services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third-party advertising and analytics partners include Google, Facebook, LinkedIn and similar partners.

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

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 services. 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 services.

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

Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.

Your Failure to Provide Personal Information

Your provision of Personal Information is required in order to use certain Services and programs.  In some instances, if you fail to provide such Personal Information, you may not be able to access and use our Services, or parts of our Services.

Our Retention of Your Personal Information

We use and retain your Personal Information for as long as necessary to fulfill the purpose for which it is being processed, to carry out legitimate business interests, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.

Sharing Personal Information

Client Command may disclose your Personal Information to commercial providers for a business purpose, which include verifying your identity when making a payment. When we disclose Personal Information for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:

• • Identifiers;
  • California Customer Records Personal Information categories;
  • Protected classification characteristics under California or federal law;
  • Commercial information;
  • Internet or other network activity information;
  • Professional or employment-related information;
  • Inferences drawn from other personal information.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• • Our affiliates;
  • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the Services we provide to you.
  • Service providers and other third parties we use to support our business, including without limitation those performing core services (such as credit card processing, customer support services, customer relationship management, property management, accounting, auditing, processing insurance claims, administering sweepstakes, surveys, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services.
  • Commercial providers;
  • Enterprise accounts, such as your employer.

We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of Client Command if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• • Fulfill any purpose for which you provide it;
  • Meet any applicable law, regulation, legal process or enforceable governmental request;
  • Detect, prevent, or otherwise address fraud, security or technical issues;
  • Protect against harm to the rights, property, assets or safety of Client Command, our customers or the public, content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law;
  • Facilitate a business transfer, such as to a buyer or other successor in the event of merger, acquisition, consolidation, divestiture, change in control, dissolution or other sale or transfer of some or all of Client Command’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by Client Command about its customers and users will be among the assets to be transferred, and any such successor may use your information for the same purposes set forth in the Privacy Policy;
  • For any other purpose disclosed when you provide the information; and,
  • When we obtain your consent to do so.

We attempt to notify you about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

International Transfer

We have centralized some of our data processing activities in accordance with applicable laws, and as a result, we may, directly or indirectly through our organization and affiliates, and through third-party entities around the world, process, store, and transfer the information you provide, including your Personal Information, as described in this Privacy Policy. Specifically, the information and Personal Information that we collect may be transferred to, and stored at, a location outside of your jurisdiction. The jurisdiction where your Personal Information will be processed may or may not have laws that seek to preserve the privacy of Personal Information. Your Personal Information may also be processed by staff operating outside of your jurisdiction who work for us or for one of the organizations outlined in this Privacy Policy in connection with the activities outlined in this Privacy Policy. By submitting your Personal Information using the Sites, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We have put in place commercially reasonable technical and organizational procedures to safeguard the information and Personal Information we collect on the Sites.

Your Privacy Choices

You may have certain rights relating to your Personal Information, subject to local data protection law. We aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.

• • Privacy Rights Specific to California Residents

Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.

Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.

• • Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.
  • Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
  • Right to Delete Your Data. 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.
  • Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
• • Exercising Your Rights

If you are a California resident who chooses to exercise your rights, you can:

1. Submit a request via the online webform by clicking here. 
2. Or call 1-800-497-4531 to submit your request.

You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.

• • Our Response to Your Request

Upon receiving your request, we will confirm receipt of your request by sending you an email. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. 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;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
3. Debug products to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
6. 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;
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
8. Comply with a legal obligation; or
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Your Marketing Choices

You may have certain choices when it comes to how we use your data and we want to provide you with information to make the choices that are right for you.

• • Interest-Based Ads and Other Online Advertising.  Visit http://www.networkadvertising.org or http://www.aboutads.info to learn more about your options for opting out of interest-based advertising. For more information on various opt-out options, visit the “Interest-Based Advertising” section above.  We do not guarantee that all of the third parties we work with will honor the elections you make using those options.  Please also keep in mind that even if you opt-out of receiving ads tailored to your apparent interests, you will continue to see online ads, but the ads that you see therefore may be less relevant to your interests.
  • Mobile Devices.  Your mobile device may offer settings relating to cookies, pixel tags, Flash cookies, and other similar technologies.  We encourage to you to visit your device’s help menu to learn about your options to limit tracking when using your device. For some information on controlling your mobile choices, click here.
  • Social Media Platforms and Networks. We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about sharing information from those platforms and networks with us.
  • Email Marketing. You can opt-out of receiving marketing emails from us by sending us an email stating your request to privacy@clientcommand.com. If we or one of our service providers acting on our behalf have sent you a promotional email, you may use the “unsubscribe” link or send us a return email asking to be omitted from future email distributions. Please keep in mind that opting out of marketing emails may impact our ability to allow you access to certain offers, benefits and features. Please also note that even if you opt out of receiving certain marketing emails, that opt-out may not apply to other transactional or legal communications that you may continue to receive from us, such as customer service messages, messages about your account or transactions with us, notices about our policies and terms, and emails responding to your communications with us or requests for information that we receive from you.

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service related notices.

Links to Other Websites

The Sites may contain links to webpages operated by parties other than Client Command. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Client Command strongly recommends that each User review the third party’s terms and policies.

If you have any questions about the privacy practices of other websites, you should contact the relevant parties controlling these websites for more information.

How We Protect Personal Information

Client Command maintains administrative, technical and physical safeguards designed to protect the user’s Personal Information and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we and/or our service providers use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.

Although we take reasonable steps designed to protect your Personal Information, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks).  We cannot and do not guarantee or warrant the security of your Personal Information or any information you disclose or transmit to us.  We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Information that may affect you so that you can take the appropriate actions.

For your own privacy protection, we urge you to keep all passwords confidential.  We also recommend that you do not include sensitive information such as passwords, social security numbers or payment information, in any emails that you send to us. If you become aware of any breach of the terms of this Privacy Policy or of the security of the Services, please notify us by email at privacy@clientcommand.com.

Children’s Privacy

The Sites and Services are not designed or intended to be used by anyone under the age of 18. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our Sites or Services), do not use the Services, or make purchases via the Services, use any interactive features of the Services, or post any Personal Information to our Sites or submit any Personal Information via the Services. We do not knowingly or intentionally gather Personal information about children who are under the age of 16.  If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us privacy@clientcommand.com. If we learn that we have inadvertently collected the Personal Information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible and cease the use of that information in accordance with applicable law. 

Direct Marketing and “Do Not Track” Signals

Client Command does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes. To make such a request you should send (a) an email to privacy@clientcommand.com with the subject heading “California Privacy Rights,” or (b) a letter addressed to Client Command, Attention: Privacy Department, 410 Peachtree Pkwy, Suite 4240, Cumming, GA 30041.  In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response.  We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

Privacy Policy Modifications

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

How to Contact Us

If you have any questions, comments or concerns about this Privacy Policy, or if you would like to exercise the choices discussed above, please contact us:

Via e-mail: privacy@clientcommand.com

By writing to us:

Client Command
Attn: Privacy Policy Inquiry
410 Peachtree Pkwy, Suite 4240
Cumming, GA 30041