Introduction

SG360° (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from or about you or that you may provide when you visit the website https://sg360.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
• From third party data brokers, which may include certain types of personal information, such as names and addresses, for purposes of helping our clients in their own marketing efforts.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at:

1351 South Wheeling Road
Wheeling, IL 60090

dataprivacy@sg360.com
847-541-1080

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information, including from third party data brokers, about users of our Website, and consumers in general, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information“);
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.
• From third party data brokers.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

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

• Cookies (or browser cookies). Cookies are small text files placed on your device to store data that can be recalled by a web server in the same domain that placed the cookie. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well. The User’s web browser places cookies on their browser to track overall usage, determine the User’s browsing preferences and improve and customize their browsing experience. Most web browsers are set to accept cookies by default. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To improve customer service: Information you provide helps us respond to your customer service requests and support needs more efficiently.
• To improve our Site: We may use feedback you provide to improve our products and services.
• To run a promotion, contest, survey or other Site feature.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To send periodic emails: We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SG360°’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SG360° about our Website users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• Other agreements, including for billing and collection purposes.
• If disclosure is necessary or appropriate to protect the rights, property, or safety of SG360°, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by sending us an email stating your request to dataprivacy@sg360.com.
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt out by sending us an email stating your request to dataprivacy@sg360.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ and customers’ target-audience preferences, you can opt out by sending us an email stating your request to dataprivacy@sg360.com or by visiting SG360°’s “Do Not Sell My Information” page.

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. These rights include:

Right to Know About Personal Information Collected, Disclosed, Or Sold (“Right to Know”)

You have the right to request to know what personal information we have collected about you, including:

• The categories of personal information collected
• The categories of sources from which the personal information is collected
• The business or commercial purpose for collecting or selling personal information
• The categories of third parties to whom the personal information is shared, as defined above
• The specific pieces of personal information collected about you that is permitted by law

Right To Request Deletion of Personal Information (“Right to Delete”)

You have the right to request that we delete any of your personal information that we collect, subject to certain exceptions. Most of the information we maintain is used in connection with making and servicing your loan or other Navient products and is therefore exempt from the CCPA.

Right to Correct Inaccurate Personal Information (“Right to Correct”)

You have the right to request correction of inaccurate personal information that we maintain about you or update the information we have on file.

Right to Opt-Out of Sale or Sharing Your Personal Information

The CCPA provides consumers with the right to opt out of the sale or sharing of their personal information. We do not sell or share personal information as defined under the CCPA, including personal information of minors under the age of 16. Because we do not sell or share personal information, we also do not treat opt-out preference signals as opt-out requests.

Right to Non-Discrimination For The Exercise Of Your Privacy Rights

You have the right to be protected from discrimination for exercising your CCPA rights. We will not discriminate against you for exercising your rights under the CCPA.

Right to Limit the Use of Sensitive Personal Information

The CCPA permits consumers to limit the use of sensitive personal information if it is used for purposes other than exceptions stated in the regulations, including the servicing of accounts, processing payments, detecting security incidents that could compromise the confidentiality of personal information, and short-term, transient use, such as for nonpersonalized advertising as part of a consumer’s current interaction with the website. We do not use sensitive personal information in any manner that requires offering a right to limit its use.

The following is a list of categories of Personal Information which may have been collected from consumers or users of our website within the last twelve (12) months. The categories and examples provided in the chart below are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact collected but reflects our good faith belief to the best of our knowledge that some of that information may have been collected about consumers. We will update this disclosure from time to time as appropriate.

To learn more about your California privacy rights, visit the California Attorney General website.

Data Security

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. Sensitive and private data exchange between the Site and its Users happens over an SSL secured communication channel and is encrypted and protected with digital signatures.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

SG360°
Attn: Compliance Department
1351 South Wheeling Road
Wheeling, IL 60090

or via our toll-free number:
847-541-1080

or via email:
dataprivacy@sg360.com