Introduction
GP Enterprise Solutions, LLC (“GPES,” “we,” “us” or “our”) understands that when you interact with GPES, including through our website and by using our licensed software (together, our “Services”), you entrust us with your personal information. As a result, we have crafted this Privacy Policy (“Privacy Policy”) with you in mind, so that we can protect your personal information and inform you of your privacy rights. In this Privacy Policy, we explain our policies and procedures for data collection, use, maintenance, protection, and disclosure when you visit our website (the “Site”) and/or use our licensed software, or otherwise obtain our Services. This policy also governs and provides you with information concerning the data we collect from and concerning you when you interact with GPES other than through our Site or our licensed software. This policy is effective as of January 9, 2021.
We may update this policy from time to time, including as we adjust our procedures to protect your information. We will make updated Policy versions available to you, and will also inform you as to the effective date for the amended Privacy Policy. Once we alter the Policy, continued use of the Site, or continued interaction with GPES other than through the Site, including use of our licensed software, on or after the effective date will be considered consent to the amended Privacy Policy.
About Your Use of Our Site and Software
Automatically Collected Information
Automatic Information Collection
As is customary, the Site and our software will collect information, including technical and routing information about your computer, without you being prompted. This may include geolocation data and internet or other electronic network activity such as device identifiers and advertising identifiers. We use this information to optimize our Site and software for the users’ use.
Cookies & Web Analytics
Cookies are small text data files that are sent to and stored on your computer, smartphone or other device for accessing the internet whenever you visit a website. Cookies are useful because they allow a website to recognize a user’s device. At GPES, we use cookies from our website in two ways:
- To analyze how you use our website so we can make our website better and to determine your likes and dislikes to help us improve your experience when using our website.
- To enable our website to perform for you as you expect, such as to log on to a secure area of the website.
You can find out more about cookies on www.allaboutcookies.org
In addition to the general uses described above, we use cookies, as allowed by law, for purposes such as: account servicing; communicating with you; improving our website, products, or services; marketing or personalizing the presentation of our products and services to you; tracking website usage, such as number of hits, pages visited, page interactions, and the length of user sessions in order to evaluate the usefulness of our sites.
We do not share personal information about you with third parties other than as stated in our Policy. If we provide links to third party websites, remember that they have their own privacy and cookie policies that control the use of information you submit.
The browsers of most computers, smartphones and other internet access devices are set up to accept cookies. You may change your acceptance of cookies through your browser settings. Your browser’s “help” function will tell you how to do this.
We do not separately maintain a listing of Site visitors who do not wish to accept cookies. You, as a visitor to our Site, must set your browser to reject cookies to enable our Site not to track your use of our Site.
Please remember that if you choose to disable cookies, you will likely affect how our website works for you and you may no longer be able to access all or parts of the website.
Google Analytics
We may use Google Analytics to collect information about your use of the Services. Google Analytics collects certain information, such as how often you use the Services, the pages you visit, and the websites you used prior to using the Services. We may use the information received from Google Analytics to improve the Services. Google Analytics collects only the IP address assigned to you on the date you visit the website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with any other information collected from you. Although Google Analytics stores a permanent cookie on your machine to identify you as a unique user the next time you use the Services, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics is governed by the Google Analytics Terms of Use available at http://www.google.com/analytics/tos.html and the Google Privacy Policy available at http://www.google.com/intl/en/analytics/privacyoverview.html. You can prevent Google Analytics from recognizing you by disabling cookies on your browser.
Other Information We Collect
Use of our software may require the submission of personal data including name, address, social security number and other identifiers. You are in control of and responsible for the data submitted through the platforms, including personal information. By choosing to engage with our Services in this manner, you authorize us to obtain additional personal information from third parties.
Tracking Disclosure
We do not respond to web browser “do not track” signals or other similar mechanisms.
Children Under the Age of 13
We do not knowingly collect information from children under the age of 13. Our Services are not directed at persons under the age of 13 and should not be used by them. In no event should young persons provide any personal information to us. If you believe that we have inadvertently collected information from a child of that age, please contact us at compliance@gpportal.com. More information about the Children’s Privacy Protection Act (COPPA) and how it protects children who use the Internet may be found at www.ftc.gov.
Our Use of the Data We Collect
Use of Personally Identifiable Information
We may use (and, where specified, share) your personal information for the following purposes:
Providing Services
We may use personal information to provide you with Services that you have requested, including to make our software services available to you.
Communication
When you contact us, we may use personal information (like your e-mail address) to reply and provide you with the services or information you requested. We also may use your personal information to collect feedback on our Services.
Site Improvement
We reserve the right to use your personal information and browsing behavior to personalize the Site and improve the overall user experience. We also may use personal information to evaluate response rates or gauge the usability of the Site.
Protect Content
In order to stop malicious, deceptive, fraudulent or illegal activity from occurring on our website or software platform, we may use identifying information to monitor users’ behavior. Our attempts to prevent malicious, deceptive, fraudulent, or illegal Internet activity may cause some users to be suspended from certain or all features.
Data Rights
Subject to applicable law, you may have the right to request and obtain information about, or copies of, your personal information that we process, where we obtained your information, the business or commercial purpose for collecting your information, and the third parties with whom your information is shared. Lastly, you may have the right to ask for the deletion of personal information relating to you, depending on the situation and applicable laws. If you’d like to make a request in relation to these potential rights, please contact us at the email address listed below.
All of our data use is in support of our business. Where we use your data based upon your consent, we recognize that you may withdraw consent if you wish to do so, and that you retain a right to your own data.
The chart below summarizes our practices in relation to our use of personal information.
| Category of Information Collected | Source of Information | Purpose for Collection | Third Parties to whom Information is Disclosed |
| · Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, or other similar identifiers.
· Other identifiers, such as signature or telephone number · Internet or other electronic network activity information, including but not limited to, browsing and search history, and information relating to your interaction with our Site or software · Inferences we may draw from the above information reflecting your preferences |
You, GPES customers with which you have an investment relationship, and/or your use of our Services | To contact you; provide you with Services; or to make our products and Services better | We may, on a selective and confidential basis, share appropriate information with GPES customers with which you have an investment relationship and companies affiliated to GPES if such sharing is necessary for the performance of our Services. We may also share select information when you expressly request that we provide you with certain products and services that are available through one of our companies. We also disclose your information to service providers, such as cloud computing providers, to allow GPES to conduct its business. |
Information Disclosure
We may need to disclose your personal information occasionally. Most of our disclosures are necessary to complete a transaction or provide the information or service you have requested. In addition to this, we may disclose your information if needed to comply with a court order, law, legal proceeding, or request from the government. We also reserve the right to disclose your information if we have the reasonable belief that such disclosure is fundamental to the safety of individuals associated with GPES or others unaffiliated with the company, or to report or investigate fraud or a crime.
We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to require that the transferee use personal information in a manner that is consistent with this Privacy Policy.
Data Retention
We will retain personal information for as long as required to provide the Services and otherwise as required by law.
Security
GPES considers the protection of personal information a very high priority. To protect the confidentiality of your activities, we use technology to update and test our computer networks regularly. Our goal is to ensure we maintain commercially reasonable standards to secure your financial privacy, including but not limited to:
Virus Protection
We use computer anti-virus software that is designed to detect and prevent computer viruses from entering our computer network system.
Firewalls
We use a specially programmed computer system that “stands” between GPES and the Internet. It is a security measure used by many companies to prevent unauthorized access by individuals or computer networks.
Continual Monitoring
We continually monitor for attempts to bypass or penetrate beyond our security systems.
Secure Transmission
SSL encrypts all your data into a series of unrecognizable numbers to travel through the Internet and establishes a secure connection between you and us. GPES websites require all traffic to be secured via SSL and rely on this protocol to encrypt data in transit. Once a secure connection is established, our computer network turns these numbers into recognizable information for our use.
We also utilize website certificates obtained through reputable, third-party commercial authorities to prove the website’s identity to browsers.
Identifying Authorized Users
We have designed our systems to ensure that your password and other access credentials are private and confidential. For your protection, only you know your access credentials. Our employees do not have access to them, and they will not ask you to reveal them.
Contact Us
If you have any questions or concerns about these policies, or how GPES protects your personal data, please feel free to contact: compliance@gpportal.com.