Firewood Marketing Privacy Policy

March 20, 2020

We at Firewood Marketing, Inc. are committed to protecting your privacy. This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use our Website.  

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification.  

While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at info@firewoodmarketing.com  or by mail to Firewood Marketing, Inc., 23 Geary Street, Suite 700, San Francisco, CA 94108.

  1. Information We Collect
  2. How We Use Information We Collect
  3. How We Share Information We Collect
  4. Security of your Personal Information
  5. Retention of Personal Information
  6. Cookies and Similar Tracking Technologies
  7. How to Access & Control Your Personal Data
  8. California Residents
  9. Employment Application

 

1. Information We Collect

You are free to explore our website without providing any personal information about yourself.

At your option, you may provide us with the following personal information: Name, email address, URL, employer, job title.  You may also provide us with the name of your employer, the size of the company and its annual revenue. Personal information can also include information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.

We also automatically collect information about your computer such as IP address, geographical location, browser characteristics, operating system and other technical information.  This information is primarily needed to maintain the security and operation of our website.

We do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at info@firewoodmarketing.com, so that we may delete the information.  Please also contact us if you wish any personal information you have provided to be deleted.  

 

2. How We Use Information We Collect

We use the personal information we collect in order to market our services to you. If at any time, you no longer wish to receive marketing overtures from us, please let us know.

We will never sell your personal information to any third party.

 

3. How We Share Information We Collect

We reserve the right to use or disclose your personal information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

We may share your personal information with service providers that help with our business activities including data storage or hosting services. We require our service providers to keep your personal information secure. We do not allow our service providers to use or share your personal information for any purpose other than providing services on our behalf.

 

4. Security of your Personal Information

We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. We secure the personal information you provide in a controlled, secure environment, protected from unauthorized access, use or disclosure. All personal information is protected using appropriate physical, technical and organizational measures.

 

5. Retention of Personal Information

We retain personal information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about our services, or as needed to comply with our legal obligations, or resolve disputes).

When we have no ongoing legitimate business need to process your personal information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request by contacting us at info@firewoodmarketing.com

 

6. Cookies and Online Tracking Technologies

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.  Cookies provide a convenience feature to save you time, or tell the Web server that you have returned to a specific page. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

You can refuse to accept cookies and enable “Do Not Track” signals as most devices and web browsers offer their own privacy settings. You will need to manage your privacy settings for each device and browser you use.  Our website does not support “Do Not Track” signals.

We collect statistical information about the usage of our site in order to continually improve the design and functionality, to monitor responses to content, to understand how visitors use the site and to assist us with resolving questions regarding the site. Google Analytics is used to collect much of this information. For more information about Google Analytics view Google’s Privacy Policy https://policies.google.com/privacy   You can also use the Google Analytics Opt-Out Browser Add-On to provide you the ability to prevent your data from being used by Google Analytics by going to https://tools.google.com/dlpage/gaoptout

We also use HubSpot as a third party vendor to manage our data.  You may review their cookie policy at https://legal.hubspot.com/cookie-policy, including how to opt-out.  

Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising initiative opt-out page http://optout.networkadvertising.org/?c=1#!/

 

7. How to Access & Control Your Personal Data

You can request access, correction, updates or deletion of your personal information by contacting us at info@firewoodmarketing.com, or by mail to Firewood Marketing, Inc., 23 Geary Street, Suite 700, San Francisco, CA 94108.

 

8. Privacy Statement – California

This PRIVACY NOTICE IS FOR CALIFORNIA RESIDENTS and supplements  the Privacy Statement of Firewood Marketing and its subsidiaries (collectively, “we,” “us,” or “our”). This Statement applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”).  We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer  or device (“personal information”). Specifically, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

 

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our website (http://firewoodmarketing-4548441.hs-sites.com/talk-a-guide-to-getting-the-most-out-of-your-digital-campaigns). For example, from submissions through our website portal or website usage details collected automatically.
  • From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we may enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. However, in certain instances a contract may not be feasible; for example, when providing protected classification characteristics under California or federal law.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:              Identifiers.
Category B:              California Customer Records personal information categories.
Category C:              Protected classification characteristics under California or federal law.
Category I:               Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with benefits or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or sharing that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us to:

  1. Complete the transaction for which we collected the personal information, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  4. Enable solely internal uses that are reasonably aligned with employee expectations based on your relationship with us.
  5. Comply with a legal obligation.
  6. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a request to us by either:

Only you may make a request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Response Timing and Format

We endeavor to respond to a request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (888) 791-8107
Email: info@firewoodmarketing.com
Postal Address: 23 Geary St., Ste. 700
San Francisco, CA 94108

 

9. Privacy Statement – Employment Application

This PRIVACY NOTICE FOR FIREWOOD EMPLOYEES applies to all Firewood employees (“employees” or “you”). This Statement also applies to all applicants for employment. We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California and other states privacy laws and are enforcing it throughout our organization. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an employee (“personal information”). Specifically, we have collected the following categories of personal information from employees and applicants within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. NO
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. YES
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

 

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or laws from any other states in regards to the confidentiality of medical information.
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994, and other states applicable laws.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our employees. For example, from documents that our employees provide to us related to their hire.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them. 
  • From third-parties. For example, background search companies and insurance companies

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to enroll you in benefits, for example.
  • To carry out our obligations and enforce our rights arising from any contracts, including employment agreements, both written and oral, entered into between you and us.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we may enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. However, in certain instances a contract may not be feasible; for example, when providing protected classification characteristics under California or federal law.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:              Identifiers.
Category B:              California Customer Records personal information categories.
Category C:              Protected classification characteristics under California or federal law.
Category I:               Professional or employment-related information.
Category J:              Education records for purposes of immigration procedures.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with benefits or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

Access to Specific Information and Data Portability Rights

Starting on January 1, 2021, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable employee request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or sharing that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

Starting on January 1, 2021, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable employee request, we will delete your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us to:

  1. Complete the transaction for which we collected the personal information, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.), and any other applicable state or federal privacy acts.
  4. Enable solely internal uses that are reasonably aligned with employee expectations based on your relationship with us.
  5. Comply with a legal obligation.
  6. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a request to us by either:

Only you may make a request related to your personal information.

You may only make a verifiable employee request for access or data portability twice within a 12-month period. The verifiable employee request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

Response Timing and Format

We endeavor to respond to a request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Non-Discrimination

The Company will not discriminate or retaliate against you for exercising any of your CCPA rights.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you via email.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

imma@firewoodmarketing.com and jwoodruff@firewoodmarketing.com