Last Updated: June 17, 2024
Protecting your private information is our priority. This Privacy Policy (the “Policy”) describes the types of information AbleNet, Inc. (“we,” “us,” or similar) collects from you through your access and use of our websites (including ablenetinc.com and quicktalkerfreestyle.com) (collectively referred to as the “Site”), when you interact with us, or communicate with us, and how we use and disclose the information, and certain rights and options you have regarding your information. and governs data collection and usage.
By providing us with personal information or using the Site, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use the Site or provide us with your information.
Patient Records
This Policy is in addition to, and does not replace, any Notice of Privacy Practices that you received from AbleNet, Inc., and that describes how we use and disclose patients’ protected health information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). To the extent of a conflict between the terms of this Policy and the Notice of Privacy Practices with respect to PHI, the Notice of Privacy Practices will control how we use and disclose your PHI. Please review our Notice of Privacy Practices for complete information on the use and release of PHI.
Important Information About This Policy
While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time, or to create additional policies, in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information.
To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates. We also ask that, where we have an ongoing relationship with you and any of the data you have provided becomes no longer accurate, you keep us informed of this so we can amend our records accordingly.
COLLECTION OF YOUR PERSONAL INFORMATION
- Information You Provide
For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual or household. The types of personal information we collect include the following categories:
- Contact information – first name, last name, email address (personal or business), mailing address (personal or business), billing address (personal or business), telephone number (personal or business), and employer and employment details.
- Account information – if you create an account to access or use our Site, your username, account password, account number, and other information that we may request or that you may provide relating to your account or profile.
- Transactional information – details about your, or your company’s, transactions with us, including method of payment, payments received, payment details, transaction history, and other information relating to the products purchased by you or your company.
- Financial information – if you are required to pay for any products, your payment card or wiring details, and billing information. Note, all payments made direct to AbleNet, Inc. are processed on our behalf by our third-party payment processor.
- Insurance information – if you are a caregiver/parent who is interested in obtaining a product that is billed to your medical insurance, we may collect your insurance information, including payee ID and number, plan number and details, and the primary insured’s date of birth.
- Marketing information – details regarding informational and promotional materials you may have requested or received from us, the products in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
- Customer support information – details of any communications or inquiries you submit to us, including technical or customer support requests, through email, calls, a chatbot or messaging or chat features on our Site, physical mail, or other means.
- Device and usage information – details regarding how and when you use our Site, including the device used to connect to our Site, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our Site, and information about your interaction with our Site.
We collect this information when you access, use, or navigate the Site, fill in forms when presented to you, request information via our Site, communicate with us or a salesperson or representative (including by phone, email, chat, or otherwise), interact with any chatbot or similar features available within our Site, participate in surveys or sponsored activities, access and use your account or profile, or otherwise provide us with personal information.
Please note that we may aggregate or anonymize the foregoing types of data such that they are no longer capable of identifying you, in which case they are no longer considered “personal information” for the purposes of this Policy.
- Automatically Collected Usage and Device Information
Like most website operators, we use various technologies to automatically collect information from you and about your interaction with our Site:
- Cookies: A “cookie” is a string of information which assigns you a unique identifier that we store on your device or browser. Your device or browser then provides that unique identifier to use each time you access the Site. We use cookies on the Site to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into the Site, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how the Site is being used and improve your user experience.
The following types of cookies may be used when you visit the Site:
- Advertising Cookies: Advertising cookies are placed on your device or browser by third-party advertisers and ad servers (including our own marketing and analytics vendors) in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Site and other websites, alternate the ads made available to you via your device or browser, and track how often an ad has been viewed and by whom.
- Analytics Cookies: Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved.
- Necessary Cookies: Some cookies are essential to the functionality of our Site and can be either permanent or temporary. These are necessary cookies, without which the Site won’t work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the Site. For example, we use security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.
- Personalization Cookies: Personalization cookies are used to recognize repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.
- Site Management Cookies: Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.
Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Site.
For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies.
In addition, you may opt-out of some third-party cookies through the Network Advertising Initiative’s Opt-Out Tool.
- Pixels, tags, and web beacons. Our Site may also use “pixels,” “tags,” “gifs,” or “web beacons.” These technologies are small pieces of code that run when a website/application page or email is loaded. They are used to monitor the behavior of the visitor or email recipient—such as what icons were clicked or whether links in an email were opened—and gather analytics. For example, when you open our Site homepage, a pixel may run and generate information based on the visit, and then this information is processed by us and/or our vendors. Pixels work in conjunction with cookies to let us know what portions of our Site are of interest to you and to help us provide you with tailored information from our Site.
IF YOU TURN OFF COOKIES, PIXELS, TAGS, AND WEB BEACONS MAY STILL DETECT CERTAIN INFORMATION ABOUT YOUR INTERACTION WITH OUR SITE AND DISREGARD ANY COOKIE-PROHIBITIVE MARKERS OR SIGNALS. Note, the social media, marketing, and analytics vendors we engage that supply us pixels, tags, web beacons, cookies, or similar tracking technologies collect your personal information instantaneously and simultaneous to our collection of such information.
- Log file information. Log file information is automatically collected from your browser or your device each time you access our Site. When you use our Site, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, device type, operating system type, IP address, mobile device identifier provided by your mobile device operating system, browser type, domain name, pages viewed, open and click engagement, as well as the language your system uses and the country and time zone where your device is located. Log file information is used for security purposes (i.e., to prevent fraud) and product improvement purposes.
- Analytics: We also use third-party analytics tools, such as Google Analytics, to do the above. You can find more information about how data is collected and processed in connection with the Google Analytics service at this link. You can also read Google’s privacy policy at this link.
- Information from Other Sources
We may obtain both personal and non-personal information about you from affiliates, vendors, suppliers, and other third parties and add it to other information we have collected. For example, we may collect information about you from our third-party distributors. We, and the third parties we engage, may combine information we collect from you over time, and across our services, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.
- Information from Social Media
If you interact with us on any social media platform: (a) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (b) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts. Social media platforms operate independently from us and we are not responsible for the personal information that you choose to submit or link on any social media platform. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.
HOW WE USE YOUR INFORMATION
We (or the service providers acting on our behalf) use the personal information identified above for the following purposes:
- Fulfilling purchases and transactions with our customers and organizational partners.
- Negotiating, entering into, and managing our relationship and agreements with our customers and organizational partners, including providing our products to and processing payments from our customers and organizational partners.
- Making our Site available to individual end users and our organizational partners.
- Providing and optimizing your experience on our Site and ensuring that our content is presented to you in the most effective manner.
- Communicating with you and responding to your inquiries and communicating regarding our products, our agreements with you or your company, and other issues.
- Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.
- Managing customer service issues, including issues relating to the performance of our products and customer feedback.
- Developing, updating, and improving our services, customer service, and customer experience, and otherwise improving our knowledge and insights regarding customers.
- Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the Site or the purchase or use of our products.
- Enforcing our agreements with you or our organizational partners, complying with our legal or regulatory obligations, and defending or advancing legal claims.
- Notifying you about changes to our products, our Terms of Use, or material changes to this Policy.
- Providing you with surveys or otherwise soliciting feedback from you.
- Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.
For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Collection and Use of Your Information” below.
OUR MARKETING EFFORTS
We may send you direct marketing communications from time to time including news, updates, offers, and other announcements relating to our services and business. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing communications from us, then you can always unsubscribe using the option provided in the communication you have received (e.g., in the footer of the email) or by contacting us using the information below.
AbleNet, Inc. uses SMS text messaging to communicate transactional and promotional information with you. By opting-in to SMS text messaging, you agree to receive SMS text messages from AbleNet, Inc. at the phone number you provide. Consent to receiving SMS text messages is not a condition of purchasing from AbleNet, Inc. Message and data rates apply. Message frequency varies. Reply STOP to any text you receive opt-out of SMS text messaging.
DISCLOSURE OF YOUR INFORMATION
When the information we collect is aggregated, anonymized, or otherwise does not identify you, it is no longer considered “personal information.” We may use such information for any purpose or disclose it to third parties, to the extent permitted by applicable law.
We may disclose your personal information to the following types of third parties:
- Service providers we use to facilitate our business operations and administer our Site. These third parties have access to your personal information only to perform specific tasks on our behalf. For example, our service providers include (i) IT and system administration providers, (ii) data storage providers, and (iii) vendors to facilitate payments and payment processing.
- Third-party vendors whose technologies we leverage to provide certain features on our Site, such as the vendor we use to provide any chat feature or functionality. Note, the technology vendors we use to make the Site available to you via the internet may collect your personal information, on our behalf, instantaneously and simultaneously with us collecting the same information.
- Marketing and advertising vendors that may assist with lead generation, hosting information relating to customers and business partners and potential customers or business partners, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
- Our distributors, some of whom operate internationally.
- Analytics vendors in order to understand our Services traffic and usage patterns, optimize our Services, and identify potential new customers or users.
- Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
- Our professional advisors, such as lawyers, accountants, and other similar advisors.
- Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
- Other parties for any purpose we disclose at the time you provide the information.
AbleNet, Inc. may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to:
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- conform to the edicts of the law or comply with legal process served on AbleNet, Inc. or the Site;
- protect and defend the rights or property of AbleNet, Inc.; and/or
- act under exigent circumstances to protect the personal safety of users of AbleNet, Inc., or the public.
PROTECTION OF PERSONAL INFORMATION
We use administrative, technical, and physical measures to protect your personal information from loss, theft, or unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.
YOUR CHOICES ABOUT COLLECTION AND USE OF YOUR INFORMATION
We respect your right to make choices about the ways we collect, use, and disclose your information, so we try to offer you meaningful choices regarding your personal information. Some choices you have regarding personal information include the following:
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- Cookies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Site.
- Declining to Provide Information – You can choose not to provide us with information we may request through our Site, but that may result in you being unable to use certain features of our Site, request information about our Site, or initiate other transactions with us.
- Marketing preferences – You can opt-out of receiving marketing communications by using the “unsubscribe” or similar link in the email you received, or by replying “STOP” to any text message. You can also contact us at the information below to indicate your marketing preferences.
- Jurisdictional Rights – Please review the “Rights Afforded to Certain Individuals” section below to learn more about the options you may have based on the place where you reside.
- Do Not Track Mechanisms – Please note that our Site does not honor “Do Not Track” signals, and such signals will not impact the operation of the website.
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In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.
RIGHTS AFFORDED TO CERTAIN INDIVIDUALS
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- California Residents
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- Nevada Residents
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Under Nevada law, Nevada residents who have purchased products from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. We do not engage in any activities that would be considered a “sale” under Nevada law. You can contact us at the information below to learn more or make a request under Nevada law.
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- Canadian Residents
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If you reside in Canada, various Canadian laws, including Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), may provide you certain rights with respect to your personal information, including the right to request information about the collection, use, or disclosure of your personal information, to request access to your personal information, and to challenge the accuracy and completeness of your personal information and have it amended as appropriate.
If you are a Canadian resident and would like to make a request regarding your personal information, please send a request to [email protected] with the subject line, “Canada Resident Request,” or otherwise contact us using the information in the “Contact Information” section below. We will attempt to respond to your request as quickly as possible but may ask you to provide additional information to enable us to locate the personal information or determine how it has been used or disclosed. We will provide you access, as appropriate, at minimal or no cost to you.
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- EU/UK Residents
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- Rights under GDPR
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The European Union’s General Data Protection Regulation, and the United Kingdom’s and Switzerland’s versions of the same (collectively, the “GDPR”) afford certain rights to individuals in the European Economic Area and Switzerland (collectively for this Policy, “EEA”). If you are in the EEA, you have the following rights. Note, however, that not all rights apply in all circumstances.
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- Right of access: subject to certain exceptions, you have the right of access to your personal information that we hold. If you are requesting access to your data in order to protect the rights of others, we may require you to validate your identity before we can release that information to you.
- Right to rectify your personal information: if you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e., corrected).
- Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. This right is not absolute, and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.
- Right to restriction of processing: in some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.
- Right to object to processing: you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
- Right to data portability: you have the right to receive, move, copy, or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.
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With regard to the personal information discussed in this Policy, we are typically the “data controller” for such information under the GDPR. As a result, if you wish to exercise one of the rights discussed above, you may do so by submitting a written request to [email protected] with the subject line, “GDPR Request.” This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond. Once we have received your request, we will review it and contact you within thirty (30) days of receipt of your request, will notify you of any delay in processing your request and, in any event, will respond to the request within three (3) months. Please note that we may need to request specific information from you to help us confirm your identity. If you have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in your jurisdiction of residence.
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- Lawful Basis under GDPR
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We will process different types of information under different lawful bases under the GDPR depending on the nature of the information and your relationship with us. The following table describes how we plan to use your personal information and our lawful basis for doing so. We may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information.
| Purpose/Activity | Type of Information | Basis of Processing |
To enter into and subsequently to manage our business relationship with you or your company, including:
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To administer and protect our business and website including:
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| To make decisions about how best to deliver relevant website content and advertisements to you, and otherwise market to you, and to better understand the effectiveness of our marketing efforts |
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Necessary for our legitimate interests (better understanding website functionality and how website users navigate and interact with the site) |
| To advance and promote our business interests including contacting you regarding products, services, or promotions that may be of interest to your company, conducting surveys or soliciting feedback on our services, and updating, developing, and improving our products/services, customer service, and marketing efforts |
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Necessary for our legitimate interests (to enhance our services, improve our marketing strategies and develop our business) |
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- Transfers from EEA, Switzerland, or UK
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If we transfer personal information from the EEA, Switzerland, or UK to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR’s requirements. For example, if the recipient country has not received an Adequacy Decision from the European Commission (such as the United States), we will rely on Standard Contractual Clauses (SCC) that have been approved by the European Commission (or other similar authorities) as the lawful mechanisms for such transfers. Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors that contain SCCs and define data protection standards to be employed by each (sub)processor.
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- Washington Residents
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The Washington My Health My Data Act (the “MHMDA”) regulates the collection of individuals’ “consumer health data” in Washington. In providing our services, we either (1) collect protected health information (as defined by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations), or (2) collect personal information from individuals (a) not acting in an individual or household context (e.g., school administrators or speech professionals), or (b) purchasing a product for someone else’s use (e.g., a parent purchasing a product for use in their household). As a result, we do not collect “consumer health data” and are not otherwise a “regulated entity” for the purposes of the MHMDA.
LINKS
This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
DATA RETENTION
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider any specific limitation periods under applicable law.
PROTECTION OF PERSONAL INFORMATION
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.
CHILDREN UNDER 13
AbleNet, Inc. does not knowingly collect personal information from or about children under the age of sixteen. If you are under the age of sixteen, you must ask your parent or guardian for permission to use this Site. Please contact us if you believe we have collected information from or about a child under sixteen.
INTERNATIONAL TRANSFERS
AbleNet, Inc. is headquartered in the United States and, as a result, the information you provide to us may reside on servers or workstations located the United States. You understand and consent that information you provide may be transferred to the United States. You also understand that the data protection laws in the United States may be different from those of the country where you reside. When we transfer personal information to the United States, we will implement appropriate and suitable safeguards to protect such information as may be required by applicable data protection laws.
CHANGES TO THIS POLICY
AbleNet, Inc. reserves the right to change this Privacy Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this Site after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.
CONTACT INFORMATION
AbleNet, Inc. welcomes your questions or comments regarding this Policy. Please contact AbleNet, Inc. at:
AbleNet, Inc.
2625 Patton Road
Roseville, MN 55113-1308
Toll Free: (800) 322-0956 (US & Canada)
Phone: (651) 294-2200
Email: [email protected]