Last Updated: January 22, 2025
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We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://slpnow.com/terms-of-purchase/.
We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union, and also subject to the UK General Data Protection Regulation (UK GDPR), which applies across the United Kingdom. We are responsible as a “controller” of that personal information for the purposes of the GDPR.
We strive to educate parents and kids about how to appropriately safeguard their privacy when using our Services. We are committed to complying with the Children's Online Privacy Protection Act of 1998 ("COPPA"), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children under the age of 13 to access and/or use our Services. We urge kids to check with their parents before entering information through our Site and/or Services, and we recommend that parents discuss with their kids restrictions regarding the online release of Personal Information (as defined below) to anyone they don't know.
By visiting our Site and/or using our Services, or by permitting your child to use our Services, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. Capitalized terms not defined in this Privacy Policy shall have the meaning stated in our Terms of Use.
1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | SLP Now LLC |
| Data protection officer contact information | security@slpnow.com |
| Personal information | Any information relating to an identified or identifiable individual. |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation. |
| Sensitive Personal Information | Personal information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status. |
| Biometric Information | An individual’s physiological, biological, or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. |
2. Personal Information We Collect About You. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
| Categories | Examples | Collected in Last 12 Months? |
| 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.
|
Yes |
| Personal information
|
A 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.
|
Yes |
| Characteristics of protected classifications under 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).
|
Yes |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|
No |
| Biometric information | Physiological, biological, or behavioral characteristics, DNA information. Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, or voice recordings. Keystroke patterns or rhythms, gait patterns or rhythms, or sleep, health, or exercise data.
|
No |
| Internet and network activity | Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
|
Yes |
| Geolocation data
|
Information about physical locations or movements. | No |
| Sensory information
|
Audio, electronic, visual, thermal, olfactory, or similar information. | No |
| Professional or employment-related information
|
Current or past job history or performance evaluations.
|
No |
| Non-public education information (per the Family Educational Rights and Privacy Act)
|
Non-public education records that are directly related to a student which are maintained by an educational agency or institution or by a party acting on its behalf (for example, grades, transcripts, class lists, student schedules, identification codes, financial information, and disciplinary records).
|
No |
| Inferences drawn from other Personal Data
|
Information used to create a user profile which reflects the users’ preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
|
No |
If you do not provide personal information required to provide services to you, it may delay or prevent us from providing services to you.
3. How Your Personal Information is Collected. We collect personal information from the following categories of sources:
- You, directly in person, by telephone, text, or email and/or via our website and apps
- Third party with your consent (e.g., your bank)
- Advertising networks
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platforms
- Social networks
- Data brokers
- Publicly accessible sources (e.g., property records)
- Cookies on our website
- Our IT and security systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems.
4. How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:
- To comply with our legal and regulatory obligations
- For the performance of our contract with you or to take steps at your request before entering into a contract
- For our legitimate interests or those of a third party –or–
- Where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
We collect the categories of Personal Data listed above for the following business purposes:
- To take steps at your request before entering into a contract for services
- To provide the Services to you for their intended purposes, as well as to customize and/or enhance your use of the Services.
- For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.
- To send communications to you, including marketing communications (unless you opt-out).
- To accomplish the purposes outlined in our Terms of Service.
- To process your payments if you make a purchase through the Services, including sharing your payment information with third party payment processors. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
- To comply with our legal and regulatory obligations.
5. EEA Data Subjects: Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our services, including exclusive offers, promotions or new products or services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it with other organizations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- Contacting us at security@slpnow.com
- Using the “unsubscribe” link in emails or “STOP” number in texts or
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
6. Who We Share Your Personal Information With. We routinely share personal information with:
- Service providers we use to help deliver our products and/or services to you, such as payment and other service providers
- Other third parties we use to help us run our business, such as marketing agencies or website hosts
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
Click here to view our list of sub-processors.
We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
7. Personal Information We Sold or Shared.
| Categories | Shared in the last 12 months? | Recipients: |
| Identifiers
|
Yes | ☒Affiliates
☒Service Providers ☐Other Recipients
|
| Personal information
|
Yes | ☒Affiliates
☒Service Providers ☐Other Recipients
|
| Characteristics of protected classifications under federal law
|
N/A | N/A |
| Commercial information
|
N/A | N/A |
| Biometric information
|
N/A | N/A |
| Internet and network activity
|
Yes | ☒Affiliates
☒Service Providers ☐Other Recipients
|
| Geolocation data
|
N/A | N/A |
| Sensory information
|
N/A | N/A |
| Professional or employment-related information
|
N/A | N/A |
| Non-public education information (per the Family Educational Rights and Privacy Act)
|
N/A | N/A |
| Inferences drawn from other Personal Data
|
N/A | N/A |
8. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
- Identifiers (e.g., 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)
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
9. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and/or services to 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 –or–
- To keep records required by law
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.
10. International Data Transfer and Regulatory Compliance. SLP Now LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. SLP Now LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit Data privacy framework website. Being self-certified, SLP Now LLC is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Click here to view the list of participants in the Data Privacy Framework.
To maintain our status under the Data Privacy Framework, we will conduct an annual review and certification to verify our adherence to the principles outlined above. This process ensures continuous compliance and addresses any changes in data protection laws or our business practices.
We commit to cooperate with the relevant data protection authorities and participate in the dispute resolution procedures provided under the Framework and have established an independent recourse mechanism via the International Centre for Dispute Resolution-American Arbitration Association (ICDR-AAA). Individuals may visit https://apps.adr.org/SimpleFile/faces/SimpleFile.jsf for complaint submission and https://www.adr.org/Rules for related forms.
We pledge to cooperate with the FTC and European Data Protection Authorities (DPAs) regarding our data transfers and processing activities. This includes disclosing information about our data practices and compliance with the Privacy Framework as required by law or regulatory inquiry.
11. Binding Arbitration.
If you have any unresolved concerns or complaints regarding your privacy or the use of your personal data as outlined in this Privacy Policy, we first encourage you to contact us directly to seek resolution. If we cannot resolve your concern to your satisfaction, you may have the right, under certain conditions, to invoke binding arbitration as a final recourse.
Before invoking binding arbitration, you must:
- Notify us of your complaint, providing us with an opportunity to resolve it directly;
- Seek assistance from an appropriate data protection authority and follow the procedures outlined by such authority; and
- Engage in any other preliminary dispute resolution mechanisms as required by applicable laws or as detailed in this Privacy Policy.
After fulfilling the above preconditions, if your dispute has not been satisfactorily resolved, you may commence binding arbitration by submitting a request to a recognized arbitration institution agreed upon by both parties. The arbitration will be conducted in accordance with the rules of the chosen institution, subject to the terms outlined in this Privacy Policy.
The arbitration will be conducted by a single arbitrator, jointly selected by you and us, who has expertise in data protection law and privacy matters. The arbitration proceedings will be conducted in the language and jurisdiction specified in this Privacy Policy, unless both parties agree otherwise. The arbitrator's decision will be final, binding, and enforceable in any court of competent jurisdiction.
The costs of arbitration, including administrative fees, arbitrator fees, and reasonable attorney's fees, will be shared as determined by the arbitrator, unless otherwise provided by applicable law. Binding arbitration under this provision shall be limited to disputes arising out of or related to the use of your personal data and the terms of this Privacy Policy. It does not apply to disputes related to intellectual property rights, fraud, or other matters not encompassed by this Privacy Policy.
12. EEA Data Subjects: Your Rights Under the EU GDPR.
| Right to Be Informed | The right to know or be notified about the collection and use of your personal information. |
| Right to Access | The right to be provided with a copy of your personal information (the right of access) |
| Right to Rectification | The right to require us to correct any mistakes in your personal information |
| Right to be Forgotten | The right to require us to delete your personal information—in certain situations |
| Right to Restriction of Processing | The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data |
| Right to Data Portability | The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations |
| Right to Object | The right to object:
· At any time to your personal information being processed for direct marketing (including profiling) · In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests |
| Right Not to be Subject to Automated Individual Decision-Making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the EU General Data Protection Regulation.
13. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can email us at security@slpnow.com.
- If you choose to contact us directly by email, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address and customer or matter reference number)
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–
- A description of what right you want to exercise and the information to which your request relates.
- We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.
- Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
14. EEA Data Subjects: Where Your Personal Information is Held. If you are located outside United States and choose to provide information to us, please note that we collect and store the data, including Personal Data, in the United States and process it there. Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
Some of these third parties are based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”
15. EEA Data Subjects: Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- With our offices outside the EEA
- With your and our service providers located outside the EEA
- If you are based outside the EEA –or–
- Where there is an international dimension to the services we are providing to you
These transfers are subject to special rules under European and UK data protection law.
The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: United States of America.
US-EU Adequacy Decision: https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en
If you would like further information, please contact us (see “How To Contact Us” below). Your consent to this Privacy Policy followed by your submission of any personal information to us represents your agreement to that transfer.
16. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. 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 continually test our systems and are ISO 27001 and ISO 27701 certified, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
17. EEA Data Subjects: How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. The supervisory authority in the Member State where you live may be contacted through the European Data Protection Board, where you may find the contact information for the applicable supervisory authority.
18. “Do Not Track” Signals. We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
19. Links To Other Sites. Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
20. Changes to This Privacy Notice. This privacy notice was published on January 22, 2025 and last updated on January 20, 2025.
We may change this privacy notice from time to time–when we do, your continued use of the Services after the amended Privacy Policy is posted on the Services will constitute your acknowledgment and agreement to the amended Privacy Policy. However, to the extent the amended Privacy Policy materially alters your rights or obligations in this Privacy Policy, the amended Privacy Policy will become effective upon the earlier of (a) your continued use of the Services with actual knowledge of the amended Privacy Policy, or (b) 30 days after the amended Privacy Policy is posted on the Services.
21. How to Contact Us. If you have any questions comments, or complaints about this Privacy Policy, how we collect and use your information, or your choices and rights regarding the same, then you may contact us at the contact information below. If you are contacting us as an authorized agent for another person or business, please also provide sufficient information in your request so that we can verify that you are authorized to communicate with us as that person’s or business’ authorized agent.
Phone: (480) 808-0757
Email: security@slpnow.com
Address: 221 E Indianola Ave Phoenix, Arizona, 85012, United States of America
22. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to Contact Us” above).