Hannon De Palma & Associates LLC and its affiliates (collectively, "Hannon De Palma," "our," "us," or "we") operate websites, provide products and services through mobile and other applications, and develop software. We refer to these as "site(s)," "service(s)," or "our sites and services."

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This privacy policy applies to our sites and services on which we display or post a direct link to this privacy policy. This privacy policy does not apply to those sites and services that do not display or link to this privacy policy, or that have their own privacy policies. However, we often acquire new companies to expand our business. Some acquired companies may operate under their own privacy policies until we integrate their privacy practices with ours.

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This privacy policy applies to all users of our sites and services and covers what information we collect and why we collect it, how we use the information we collect, and the choices you have to access and update that information. Please familiarize yourself with our practices and let us know if you have any questions. By using our sites and services, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this privacy policy. Each time you use our sites and services, the current version of this privacy policy will apply. If you do not agree to this privacy policy, please do not use our sites or services.

Data Controller and Contracting Parties

For the purposes of the General Data Protection Regulation 2016/679 (the “GDPR”), the Data Controller is Hannon De Palma & Associates, LLC. You can contact our Data Protection Officer by sending an email to admin@hannondepalma.com or by writing to:

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Hannon De Palma
445 Hamilton Ave., Suite 1102

White Plains, NY 11601

1. Personal Information that You Provide to Us

Personal information is information that can be used to identify, locate, or contact an individual, and includes other information that may be associated with personal information. When you interact with our sites and services, depending on the site or service, we may collect the following personal information directly from you

1. Account or Registration Information where needed to use our sites and services, and may include your name, address, email address, telephone number, birthday, user account name, and password;
2. Contact Information, which generally includes your name, addresses, email addresses, social media website user account names, and/or telephone numbers;
3. Payment Information where needed to process payments and generally includes your credit or debit card number, expiration date, and card verification number;
4. Personal Profile or Service Information, which may include areas of interest, information from social media interactions (such as Facebook, Twitter, or Google+), preferences, physical characteristics (such as height, weight), photographs and, biographical, health information and/or demographic information (such as gender);
5. Transaction Information, which may include information about how you interact with and use our sites and services, email, other communications, and applications, and how you interact with merchants, business partners, and service providers;
6. Geographic Location Information but only if your device transmits location data and/or your IP address and you have activated a location-enabled site or service;
7. Job-Search-Related Information where needed for recruitment purposes and may include educational and employment background, driver's license number, and social security number;
8. Survey Data where needed for the functionality of certain services and generally includes survey questions and responses, and may allow you to import email addresses and names in order to send surveys or to allow us to send surveys on your behalf;
9. Medical Information, where needed for the functionality of certain services, such as to connect you with your healthcare provider, and may include your medical history, present symptoms, future conditions or treatments, insurance carrier and plan, and any other medical and health information you or your healthcare provider choose to provide to us;
10. Appointment Information, where needed to schedule an appointment or consultation through our online appointment or consultation services and may include the requested appointment information, which may be linked with health or legal information that you choose to provide to us;
11. Access to Your Data, but only if you use certain services, interactive tools, or authorize us to retrieve information from another database, user, or other third party on your behalf, such as integrating a practice management system with your services;
12. Your Submissions, which generally includes information you voluntarily provide through free form text boxes, forums, document upload, or data retrieval or import;

In each of the above instances, you will know what personal information we collect through our sites and services because you voluntarily and directly provide it to us.

2. Other Information We Automatically Collect through Cookies and Other Technologies

We or our third-party service providers may collect and store certain technical information when you use our sites and services. For example, our servers receive and automatically collect information about your computer and browser, including, for instance, your IP address, browser type, domain name from which you accessed the site or service, device size and other software or hardware information. If you access our sites and services from a mobile or other device, we may collect a unique device identifier assigned to that device (UDID), type of device, general GPS location, or other transactional information for that device in order to serve content to it and to improve your experience in using the sites or services.

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In addition, we or our third-party service providers may collect information about how you use of our sites, including but not limited to, the date and time you visit the sites, the areas or pages of the sites that you visit, the amount of time you spend viewing the sites, the number of times you return to the sites, visits to sites outside our network, preferred language, and other click-stream data.

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2.1 Cookies and Other Tracking Technologies

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We or our third-party service providers may use cookies and other tracking technologies (including browser cookies, pixels, beacons, mobile application identifiers, and Adobe Flash technology) to help us recognize you across different sites and services, improve your experience, increase security, measure use and effectiveness of our services, and serve advertising. You can control cookies through your browser settings and other tools.

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By visiting our sites and services, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this privacy policy.

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To provide you with certain personalization and advertising services described herein, when you use our Sites, we may share information that we may collect from you, such as your email address (in hashed form), IP address or information about your browser or operating system, with our service provider, LiveRamp Inc. and its affiliates, which may in turn link demographic or interest-based information to your browser.

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2.2 Do Not Track

You can opt-out of being targeted by certain third-party advertising companies online by visiting the following third-party websites: Network Advertising Initiative, Omniture, PrivacyChoice, and/or Digital Advertising Alliance

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We currently do not respond to "Do Not Track" browser signals. Accordingly, your navigation on our sites and services may be tracked as part of our efforts to gather user information described above. If you arrive at our sites and services by way of a link from a third-party site that does respond to “Do Not Track” browser signals, such “Do Not Track” browser signal recognition will end as soon as you reach our sites and services.

3. Our Legal Bases for Processing

We will only collect and process personal information, including sharing it with third parties, where we have a legal basis for such collection and processing. We rely on a number of legal bases, including:

1. our legitimate interests in providing and improving our sites and services;
2. our legitimate interests in keeping our sites and services safe and secure;
3. our third party service providers’ legitimate interests as described in “Other Information We Automatically Collect Through Cookies and Other Technologies” above;
4. your consent to the processing of your personal information, which you can revoke at any time;
5. where the processing of personal information is necessary for the performance of a contract to which you are a party to, such as our Terms of Use, Service Agreement, and License Agreement;
6. where the processing of your personal information is required to protect your vital interests or those of another person, such as other users of our sites and services;
7. where the processing of personal information is necessary to comply with a legal obligation such as a law, regulation, search warrant, subpoena, or court order.

4. How We Use Personal Information

4.1 Personal Information that You Provide to Us

We may use the personal information that you provide in one or more of the following ways:

1. to carry out our obligations arising from your purchase of, or subscription to, our services or any other contract entered into between you and us;
2. to enable site features such as geographically specific pricing or logging, and retrieving and providing analysis of data;
3. to send you important notices, such as communications about changes to your account, and our sites' and services' terms, conditions, or policies;
4. to process payments and to send you emails, invoices, receipts, notices of delinquency, alerting you if we need different or updated payment card information or other communications in connection with processing and collecting payments;
5. to verify the information you provide through our sites and services, including income and employment information, in connection with a loan request sent through our sites and services;
6. to retain your loan request for the length of time determined by us or by applicable law;
7. to solicit input and feedback to improve our sites and services and customize your user experience;
8. to enable you to communicate with other site or service users via private messaging or other service specific communication channels;
9. to contact you via email, telephone, text or chat in a manner required by law;
10. to meet contractual obligations;
11. to send you reminders, technical notices, updates, security alerts, support and administrative messages, and service bulletins;
12. to inform you about new products or promotional offers, or other opportunities which we feel will be of interest to you, and to provide advertisements to you through our sites, email messages, text messages, applications, or other methods of communication;
13. to manage our sites' and services' administration, forum management, or fulfillment;
14. to provide customer service and technical support;
15. to administer surveys, sweepstakes, giveaways, contests, or similar promotions or events sponsored by us or our partners;
16. to prevent fraud or potentially illegal activities, or to comply with applicable law;
17. for internal purposes such as auditing, data analysis, and research to improve our products, services, and communications;
18. to allow you to apply for a job or sign-up for special offers from third parties through our sites and services;
19. to help you contact or schedule an appointment with a healthcare provider or a legal professional listed in one of our directories and to remind you of upcoming or follow-up appointments;
20. to perform services in conjunction with interactive tools, such as integrating practice management systems, making a referral, sending a prescription to a pharmacy, or sending a test to a clinical laboratory; and
21. to run (or authorize third parties to run) statistical research on individual or aggregate trends.

In addition to the uses described above, we may use personal information that we collect for other purposes that are disclosed to you at the time we collect the information, or with your consent.

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4.2 Other Information We Automatically Collect Through Cookies and Other Technologies

We may use information collected from you through cookies and other tracking technologies in one or more of the following ways:

1. to remember you when you return to our sites;
2. to understand and analyze trends, to monitor usage, and learn about user behavior;
3. to gather demographic information about our user base as a whole;
4. to customize ads, content, or offers on our sites and services; and
5. to conduct market research and measurement in order to improve our sites, content, and services and to make our sites, content, and services more useful for users.

5. Sharing Personal and Non-Personal Information

We may share your personal information with third parties in the following circumstances:

1. when we engage third parties to perform services on our behalf, such services include maintenance, hosting, data storage, security, analytics and data analysis, payment processing, marketing, email and text message distribution, customer service, and surveys and sweepstakes;
2. when you communicate with us by email, submit an online form through our sites and services, request a quote or information, request financing, purchase a product or service, or otherwise submit a request through our sites and services, the personal information you provide may be shared with third parties to process or respond to your request, provide you with the products or services you requested, or complete a transaction, including a third party broker, aggregator, or other referral service to share and/or sell your information to a lender, dealer, or other financial institution in connection with your online request.
3. when you schedule an appointment with a healthcare provider or legal professional, we may share your contact data, insurance data, and medical data with such healthcare provider or legal professional;
4. where necessary to operate our sites and services, your personal information and the contents of all of your online communications on or through our sites and services may be accessed and monitored:some text
   1. to satisfy any applicable laws or regulations,
   2. to defend ourselves in litigation or a regulatory action,
   3. in order to protect the rights or property of Hannon De Palma and our subsidiaries and corporate affiliates, including to enforce our sites' or services' Terms of Use.
   4. when we have a good faith belief that we are required to disclose the information in response to legal process (for example, a subpoena, court order, or search warrant),
   5. where we believe our sites and services are being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and risk management, and
   6. when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally;
5. in the event of a merger, acquisition, debt financing, restructure, sale of Internet Brands' assets by or with another company, or a similar corporate transaction, we may need to disclose and transfer all information about you, including personal information, to the successor company;
6. we may share information about you with Internet Brands' subsidiaries and affiliates and companies acquired by or merged with Internet Brands and its affiliates, including without limitation, to enable such acquired or merged companies to advertise to you products and services in which you may be interested.
7. when you register to use a service co-branded by Internet Brands and other companies with which we partner, we may share the personal information you provide with such companies; in this instance, both our privacy policy and the partner's privacy policy will apply;

We may share personal information about you for any other purpose(s) disclosed to you at the time we collect your information or with your consent.

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Non-personal information may be shared with our partners who referred you to our site(s) and who may use the data for their market research and measurement purpose. User information may also be shared with our partners who help us deliver ads to you on websites not controlled by us; for instance, when we put a pixel on a conversion page on our site and a marketing partner uses that pixel to optimize the traffic that they send to us.

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6. Storing Personal Information

We retain your personal information while your account is active or as needed to provide you services. Additionally, we may retain personal information even after your account has been closed if retention is reasonably necessary to comply with our legal or regulatory obligations, resolve disputes, prevent fraud and abuse, enforce our Terms of Use or any other contract entered into between you and us, or if it is not technically feasible to delete your personal information.

7. Email and Other Communications

Our sites and services may allow us or other users to communicate with you or other users through our in-product instant messaging services, service-branded emails, SMS, and other electronic communication channels.

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9.1 Text Messaging

We may make available text messaging services in which you can receive messages from us and send messages to us on your mobile phone.

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9.2 Opting Out of Requested Communications

Requested communications include, for instance, email newsletters and software updates that may be expressly requested by you or which you consented to receive. After you request such communications, you may "opt-out" of receiving them by using one of the following methods:

1. selecting the email "opt-out" or "unsubscribe" link, or following the opt-out instructions included in each email communication;
2. returning to the web page(s) where you originally registered your preferences and following the opt-out instructions; or
3. emailing admin@hanondepalma.com.

9.3 Opting Out of Transactional or Relationship Communications

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Communications that are sent by or on behalf of a user are indicated as being from that user. Communications that are sent by us are indicated as being from us or one of our account or support specialists. Either type of communication may be "real time" communications or communications triggered automatically upon the occurrence of certain events or dates, such as appointment reminders. Email communications received from users and our administrative announcements are often transactional or relationship messages, such as appointment requests, reminders, and cancellations. You may not be able to opt-out of receiving certain email messages, although our services may provide a means to modify the frequency of receiving them.

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9.4 Opting Out of General or Promotional Communications

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General communications provide information about products, services, and/or support and may include special offers, new product information, or invitations to participate in market research. You may opt-out of receiving these general communications by using one of the following methods:

1. selecting the email "opt-out" or "unsubscribe" link, or following the opt-out instructions included in each email communication; or
2. emailing admin@hannodepalma.com.