Privacy Statement

Effective Date: November 16, 2020

This GreenPath Privacy Policy explains our practices, defines our users’ (“you” or “your”) privacy options, and describes how your information is collected and used by GreenPath (“we,” “us,” “our” or “GreenPath”).

 

This Privacy Policy, along with our Terms of Use governs your use of the GreenPath website at www.greenpath.com and the GreenPath Portal (“Site”), and any information we may access through social media platforms such as Facebook, Instagram, LinkedIn, or Twitter.  For purposes of this Privacy Policy, we will refer to all of these access points as the GreenPath system (“System”).

 

By using the GreenPath System or any of our products, services, features, tools, or resources, you agree to the terms of this Privacy Policy and our Terms of Use.

Revisions to the Privacy Policy

We reserve the right to modify this policy from time to time and will mark new versions with a corresponding effective date.  We recommend you visit the Site to review any changes in our practices.  Your continued use of the System constitutes your agreement to our then-current Privacy Policy.

What Information Do We Gather?

When you visit our Site, we may gather the information necessary to identify your needs and to provide you with better service.  Through your use of the site or registration as a new user, we may request personal information including, but not limited to:

  • Name
  • Contact information including email address, mailing address, and cell phone number
  • Demographic information including postal code, product preferences and interests
  • Internet Protocol (“IP”) Address and other persistent identifiers
  • Other information relevant to our services including personal and financial data
  • If you become a registered user or if you conduct transactions through this website, we will collect information about the transactions you engage in while on the website and your other activity on the site. This information may include, without limitation, areas of the website that you visit, transaction type, content that you view, download or submit, transaction amount, payment, and billing information as well as the nature, quantity and price of the goods or services you exchange and the individuals or entities with whom you communicate or transact business.

Some of this information, including name and contact information, will only be collected if you voluntarily provide it to request information or during the user registration process.  We may also track information such as the domain name and the name of the web page from which you entered our Site, and how much time you spend on each of our pages.  Our lawful basis for collection of this data is our legitimate interest in completing your requests and maintaining a functional System.

We collect information that is combined with other web visitors’ information, such as how many times visitors click on each web page and the methods by which our Site was found.  We may collect IP addresses and website usage information from you when you visit our Site via the use of “cookies.”

An IP address is a number that is assigned to your computer when you are using your browser on the Internet.  Cookies are small data files that help us keep track of your usage of the System. Many of the cookies we use enable the System to function as you would expect it to. Cookies enable the System to remember things like your login information so you do not have to re-enter it, items in your shopping cart when you navigate away from the page, user preferences, and other personalized settings. Cookies also enable us to track and analyze user behavior in order to improve our System. Most web browsers automatically accept cookies but you can choose to accept or decline certain types of cookies if you prefer. However, declining cookies may impact the functionality of the System and in some cases, you may not be able to access the functions of the System. We use the following categories of cookies on the System:

  • Session cookies

Session cookies are stored on the user’s hard drive temporarily and are deleted when the user ends the browsing session. Session cookies are useful for things like keepings item in a shopping cart while the user continues to browse.

  • Persistent cookies

Persistent cookies stay on the user’s hard drive until they expire, even after the browser is closed. Persistent cookies are useful for remembering things like login information, so users do not have to enter their password every time they visit the System.

  • Third-party cookies

Third-party cookies are not installed directly by our System, but by third parties such as advertisers. Third-party cookies are used to track advertising preferences from site to site, and to gather data about users’ browsing habits in order to improve the user experience.

What Do We Do With Personal Information We Collect?

We collect information about you in order to provide you with services and products, and to make the System work properly.  You will be asked to provide personal information in certain fields on this Site that allow you to be able to use our Services.  The personal information we collect is used only for the purpose we state at the time of collection or for purposes contained below.  For example, our uses may include, but are not limited to, the following:

  • We may use your email address or text message you to contact you about new features on the Site, or to provide you with other information that is relevant to your use of the Site.
  • We may use your information for internal record keeping purposes related to purchases and transactions.
  • We may periodically send you promotional emails or text messages about new services, special offers or other information which we believe may be of interest using the email address provided.
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.
  • We may use your information to promote completion of services that you request. We may contact you by email, phone, text message, fax or mail.
  • We may use your information to customize the website according to your interests.
  • We may disclose your information to implement and enforce our Terms of Use.
  • We may disclose your information to respond to subpoenas, judicial processes, or government requests or investigations.
  • We may use your information to protect the security of our Services, servers, network systems and databases or to protect our users and affiliates against liability or harm or for other purposes as necessary to carry out our obligations under this Privacy Policy or our Terms of Use.

To the extent that we collect certain demographic information about you, we may use this information in our market research, but we will do so only after we “anonymize” the data, i.e., remove information that would confirm your identity.  We will not use your personally identifiable information.

This Site does not collect personally identifiable information when you browse the Site and request pages from our servers unless you voluntarily and knowingly provide such information to us.  This means that we will not know your name, your email address, or any other personally identifiable information just because you browse the Site unless you:

  • access the Site from a link in an email that we have sent to you;
  • have created a profile and you either log-in to your account or choose to be remembered via your cookie or your web-enabled mobile device.

In these cases we will know who you are based on the information you previously supplied to us.  When you request a page from our Site, our servers log the information provided in the HTTP request header including the IP number, the time of the request, the URL of your request and other information that is provided in the HTTP header.  We collect the HTTP request header information in order to make our Site function correctly and provide you the functionality that you expect to see.  We also use this information to personalize content presented to you, better understand how visitors use our Site and how we can better tune it, its contents, and functionality to meet your needs.  We only use your personally identifiable information for those activities listed at the time you submit your information to us.  For example, if you provide us with an email to inform you of special events, then that is what we will use your email address to do.  If we would like to use your personally identifiable information for an unrelated activity, we will first request your consent to do so.

Who Can Use The Information We Collect and How?

We may provide your information to third parties, or third parties may collect information from you on our behalf if we have contracted with that third party to provide some part of the information or service that you have requested.  Other than those who act on our behalf and except as explained in this Privacy Policy, information you provide at this Site will not be transferred to unrelated third parties, unless we have your permission to do so.  However, please note that personal information provided to this Site is subject to disclosure pursuant to law enforcement requests or in response to investigations, subpoenas, court orders, or other legal processes to establish or exercise our legal rights or defend against legal claims, or as otherwise required by law.  In these instances, our lawful basis for disclosing your information is our legal obligation.

How Do We Protect The Information We Collect?

Your privacy and the security of your personal information are important to us.  We maintain and protect the security of our servers and your personal information.  To secure the information we collect online, prevent unauthorized access, maintain data accuracy and ensure only appropriate use of information, we have established appropriate physical, electronic and management safeguards. We require user names and passwords to access sensitive data.  Unless you authorize unencrypted transmission, we will use industry standard encryption methods to protect your data transmission.

Third-Party Websites and Links

Our System may contain links to other websites.  These websites may have privacy policies different from our Privacy Policy.  The System may also contain certain social media icons or widgets.  Although you can view the material we have linked to, you may have to create an individual account or register to use these third-party social media sites to use interactive features.  Any interaction on social media or other third-party websites is governed not by this Privacy Policy but by the terms of use and privacy policy of the particular platform.

How Do You Opt-out of Personal Information Sharing with Our Business Partners?

We may use third-party analytics vendors to evaluate and provide us with information about the use of our Services and viewing of our content.  Some of the information you see on our Site may be customized based on automated predictions about your interests, which predictions are generated from your visits over time and across different websites, using tools such as Google Analytics.  This information allows us to create content of greater interest to you and can also be used to serve ads based on your past visits to our Site.  Any information that these third parties collect via cookies is not linked to any personally identifiable information (name, address, email address, or phone number) we collect or you provide on the Site.  Note that you can opt-out of a third-party vendor’s use of cookies, including use by Google, by visiting the Network Advertising Initiative opt-out page.

For more information about how targeted Network Advertising works, please visit: http://www.youradchoices.com/ or http://www.networkadvertising.org/understanding-online-advertising.

 

You may opt-out of third party targeted advertising or analytics in two ways: 1) By directly notifying a Network Advertising service provider via its opt-out tools (Please see above) or 2) using your browser’s Do Not Track (DNT) settings to indicate that you do not wish to receive targeted advertising based on your overall internet usage. For more information about DNT and how it works, please visit the Future of Privacy Forum’s website.

We will make a good faith reasonable effort to honor your DNT browser settings for opting out of receiving targeted third-party advertising based on your overall Internet usage. Please note that various browsers frequently update technology or change their settings and business practices without advance notice, and we may not have the latest information on how to honor your preferences. If you exercise either opt-out option – the cookie opt-out or the browser opt-out – you will continue to receive advertising, but such advertising may not relate to your specific interests, previous purchases or search history.

However, you cannot opt-out of our contextual analytics and advertising, which is based on your usage of only our Services. We will continue to serve you contextual advertising. We will also continue to monitor your usage and search or transaction history to provide us with analytics on how well our Services, features and activities are functioning and used. We will also share this information in an aggregated form (meaning that no one individual person can be identified) within our company.

How Do You Correct and Update Your Personal Information?

You can change or correct your account information at any time.  Please use the Contact Us option on our Site or call us at the telephone number listed on your account statements or other account records.

What is Our Privacy Policy If You Are Under 13 Years of Age?

We understand the importance of protecting the privacy of all individuals, especially the very young.  Our services are intended exclusively for United States citizens over the age of 18.  We neither target nor sell our products or services to children under the age of 13, and we do not knowingly collect personal information from them.  Subscribing to our online service is restricted to adults who are either 18 years of age or older or as otherwise legally defined.

What Happens If We Sell Our Business?

While we do not anticipate it, every business nowadays should plan for the possibility that it might sell certain or all of its assets to another company or individual, or that it might buy certain assets of another company or individual.  If all or part of the company is sold, merged or otherwise transferred to another entity, the personal information you have provided to us may be transferred as part of that transaction.  However, we will take steps to ensure that your personal information is used in a manner consistent with the provisions of our Privacy Policy.

Your California Privacy Rights

California Civil Code § 1798.83 permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.  If you are a California resident and have an established business relationship with us and want to receive information about how to exercise your third party disclosure choices, you must send a request to the following address with a preference on how our response to your request should be sent (email or postal mail).  You may contact us in two ways. Send email to compliance@greenpath.com.

Alternatively, you may contact us at:

 

GreenPath, Inc.

36500 Corporate Drive

Farmington Hills, MI 48331

Attn:   Your California Privacy Rights

c/o Privacy Administrator/Compliance Department

 

For requests sent via email, you must put the statement “Your California Privacy Rights” in the subject field of your email.  All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or post card and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code. (Your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping.) We will not accept requests via the telephone or by facsimile. We are not responsible for responding to notices that are not labeled or not sent properly, or do not have complete information.

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code § 22581 permits you request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to compliance@greenpath.com.  Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

What If You Have Questions?

If you have questions or concerns regarding this Privacy Policy, you should first contact us via email at compliance@greenpath.com.