Privacy Notice – A Paper Trail

Effective Date: March 15, 2020
Notice Version: 1.0

Data Controller Contact Information:
A Paper Trail, LLC
5580 Paredes Line Rd.
Brownsville, TX 78526
info@apapertrail.com

This document governs the privacy notice of our website www.apapertrail.com. Our privacy notice tells you what personal data and nonpersonal data we may collect from you, how we collect them, how we protect them, how we share them, how you can access and change them, and how you can limit our sharing of them. Our privacy notice also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our website.

Definitions
‘NONPERSONAL DATA’ (NPD) is information that is in no way personally identifiable.

‘PERSONAL DATA’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.

Topics Covered in Our Privacy Notice
YOUR RIGHTS
INFORMATION WE COLLECT AND HOW WE COLLECT IT
HOW YOUR INFORMATION IS USED AND SHARED RETAINING AND DESTROYING YOUR PD UPDATING YOUR PD
REVOKING YOUR CONSENT FOR USING YOUR PD
PROTECTING THE PRIVACY RIGHTS OF THIRD PARTIES
DO NOT TRACK SETTINGS
LINKS TO OTHER WEBSITES
OUR EMAIL POLICY
OUR SECURITY POLICY
CHANGES TO OUR PRIVACY NOTICE

YOUR RIGHTS
Contact us using the information at the top of this privacy notice to exercise any of your legal rights contained within this privacy notice.

You Have the Right Not to Have Your Personal Information Sold
You have the right to request that we do not sell any of your personal information.
Personal information for this section means a natural person’s first name or first initial and last name in combination with any one or more of the following data elements when the name and data elements are not encrypted: social security number, driver’s license number, driver authorization card number, or identification card number. Account number, credit card number, or debit card number, in combination with any required security code, access code, or password that would permit access to the person’s financial account. A medical identification number or a health insurance identification number. A username, unique identifier, or electronic mail address in combination with a password, access code, or security question and answer that would permit access to an online account.

If you wish to make this request, please email us at: info@apapertrail.com telling us that you do not want to have any of your personal information sold. Please include enough personal information so that we can reasonably verify your identification. We will respond to your request within 60 days after receiving it.

INFORMATION WE COLLECT AND HOW WE COLLECT IT
Generally, you control the amount and type of information that you provide to us when using our website.

Automatic Information
We automatically receive information from your web browser or mobile device. This information may include the name of the website from which you entered our website, if any, as well as the name of the website you’ll visit when you leave our website. This information may also include the IP address of your computer/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our website. We use all this information to analyze trends among our users to help improve our website.

When Entering and Using Our Website
When you enter and use our website and agree to accept cookies, some of these cookies may contain your PD.

Our Use of Cookies
Our website uses cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well.

By agreeing to accept our use of cookies you are giving us and the third parties with which we partner permission to place, store, and access some or all the cookies described below on your computer.

Strictly Necessary Cookies - These cookies are necessary for proper functioning of the website, such as displaying content, logging in, validating your session, responding to your request for services, and other functions. Most web browsers can be set to disable the use of cookies. If you disable these cookies, you may not be able to access features on our website correctly or at all.
Performance Cookies - These cookies collect information about the use of the website, such as pages visited, traffic sources, users’ interests, content management, and other website measurements.
Functional Cookies - These cookies enable the website to remember users’ choices, such as their language, usernames, and other choices while using the website. They can also be used to deliver services, such as letting a user create a blog post, listen to audios, or watch videos on the website.
Media Cookies - These cookies can be used to improve a website’s performance and provide special features and content. They can be placed by us or third parties who provide services to us.
Advertising or Targeting Cookies - These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.
Session Cookies - These cookies allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they browse a website. Session cookies also permit users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; they are not stored long term.
Persistent Cookies - These cookies are stored on a user’s device between browser sessions, which allows the user’s preferences or actions across a website or across different websites to be remembered. Persistent cookies may be used for several purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.
We may also use cookies for:
- identifying the areas of our website that you have visited
- personalizing content that you see on our website
- our website analytics
- remarketing our products or services to you
- remembering your preferences, settings, and login details
- targeted advertising and serving ads relevant to your interests
- affiliate marketing
- allowing you to post comments
- allowing you to share content with social networks.

Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access features on our website correctly or at all.

Web Beacons
We may also use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers and users.

At User Registration
When you register as a user, we collect your name and email address and/or phone number.

Contact Forms
Our website contains a contact us page that enable visitors to communicate with us offline. In some cases visitors can communicate with us without buying our products and services. When you use our contact form, we may collect some or all the following information: your email address, first name, last name, and any other information you willingly choose to give us.

Due to the sensitive nature of our services, we strongly discourage you from providing any information to us via email or through the web site other than your name and contact information. The contact information you provide us will be strictly used to make an initial contact with you, using the contact method and information identified by you. (phone, email or postal mail). It is only through our initial contact with you via phone, email or postal mail should any information be discussed beyond your contact information. Once initial contact has been successfully made with you, any contact information provided is moved into our firms file retention system or discarded, depending on the outcome of our initial contact. The firm does not maintain a database or any other storage of information provided by you via this web site, and you should expect no solicitation from this firm using your information provided through this website.

At Service Contract
If retained for service under an agreement, additional information will be collected. This includes but not limited to banking statements, cancelled check images, deposit details, paid invoice, credit card statements, payroll records, payroll filings, timecards, accounting system either manual or electronic including name, version and passwords, and other supporting documents/records pertaining to the project. If the agreement is with an attorney, work performed by us will be confidential, constituting a portion of your work product, and is to be regarded by us as being covered by the attorney-client and attorney work-product privileges. All work papers or other documents used by us during the course of this engagement will be maintained in segregated files.

Google Analytics
Our website uses Google Analytics to collect information about the use of our website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our website, what pages they visit, and what other websites they have used before coming to our website. We use the information we get from Google Analytics to analyze traffic, improve our marketing, advertising, and website. Google Analytics collects only the IP address assigned to you on the date you visit our website, not your name or other identifying information. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our website, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our website.

For more information on how Google collects and processes your data visit: https://www.google.com/policies/privacy/partners/
You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout

What Happens If You Don’t Give Us Your PD
If you do not provide us with enough PD, we may not be able to provide you all our products and services. However, you can access and use some parts of our website without giving us your PD.

HOW YOUR INFORMATION IS USED AND SHARED
We use the information we receive from you to:

provide our products and services you have requested or purchased from us
personalize and customize our content
make improvements to our website
contact you with updates to our website, products, and services
resolve problems and disputes
contact you with marketing and advertising that we believe may be of interest to you.

Communications and Emails
When we communicate with you about our website, we will use the email address you provided when you registered as a user or customer. We may also send you emails with promotional information about our website or offers from us unless you have opted out of receiving such information. You can change your contact preferences at any time through your account or by contacting us using the contact information at the top of this privacy notice.

Sharing Information with Affiliates and Other Third Parties
We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your NPD, which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. We may give your PD to third-party service providers whom we hire to provide services to us. These third-party service providers may include but are not limited to payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.

Sharing Information With Business Partners
We may share your PD with our business partners. The business partners include general business partners, affiliates, and joint venture partners. We share this information with them so that they can send you information about our products and services as well as their products and services. When you choose to take part in our services and/or offerings, you are authorizing us to provide your email address and other PD to our business partners. Please understand that when we share your PD with our business partners, your PD becomes subject to our business partners’ as well as our privacy notice.

Legally Required Releases of Information
We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or governmental enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our terms and conditions; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.

Disclosures to Successors
If our business is sold or merges in whole or in part with another business that would become responsible for providing the website to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.

RETAINING AND DESTROYING YOUR PD
We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. Your information may be retained in electronic, paper, or a combination of both forms. When your information is no longer needed, we will destroy, delete, or erase it.

Our policy is to contact you at the conclusion of this matter regarding all physical records obtained by us during this matter. Our policy is to return any and all collected records to you. In the event you desire us to retain and archive the records, we will maintain the records for a period of three years after the conclusion of this matter. At the end of three years we will schedule the records to be destroyed. With regards to any electronic records obtained, generated and/or maintained relating to this matter, we will maintain any electronic records for a period of four years after the conclusion of this matter. At the end of four years, all electronic records will be permanently erased from our systems.

UPDATING YOUR PD
You can update your PD using services found on our website. If no such services exist, you can contact us using the contact information found at the top of this privacy notice and we will help you. However, we may keep your PD as needed to enforce our agreements and to comply with any legal obligations.

REVOKING YOUR CONSENT FOR USING YOUR PD
You have the right to revoke your consent for us to use your PD at any time. Such optout will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to affiliates and business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or third-party offers you may choose to accept.

PROTECTING THE PRIVACY RIGHTS OF THIRD PARTIES
If any postings you make on our website contain information about third parties, you agree to make sure that you have permission to include that information. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified, if such postings violate the privacy rights of others.

DO NOT TRACK SETTINGS
Some web browsers have settings that enable you to request that our website not track your movement within our website. Our website does not obey such settings when transmitted to and detected by our website. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.

LINKS TO OTHER WEBSITES
Our website may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. These websites will likely have their own privacy notices. We have no responsibility for these websites and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy notices of these websites to see how they treat your PD.

OUR EMAIL POLICY
You can always opt out of receiving email correspondence from us or our affiliates. We will not sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business, or if our company files for bankruptcy.

OUR SECURITY POLICY
We have built our website using industry-standard security measures and authentication tools to protect the security of your PD. We and the third parties who provide services to us also maintain technical and physical safeguards to protect your PD. Unfortunately we cannot guarantee prevention of loss or misuse of your PD or secure data transmission over the Internet because of its nature.

CHANGES TO OUR PRIVACY NOTICE
We reserve the right to change this privacy notice at any time. If our company decides to change this privacy notice, we will post those changes on our website so that our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email sent to the email address on file in your account. Otherwise we will use and disclose our users’ and customers’ PD in agreement with the privacy notice in effect when the information was collected. In all cases your continued use of our website, services, and products after any change to this privacy notice will constitute your acceptance of such change. If you have questions about our privacy notice, please contact us through the information at the top of this privacy notice.