Personally Identifiable and Other Information We Collect
A. Information About Our Users
The categories of PII we may collect from you include without limitation:
Identifiers – Including without limitation your real name, alias, account name, internet protocol address, unique identifiers, email address, birthdate, postal address, phone number, driver’s license number, or other similar identifiers. Our web servers automatically collect unique identifiers that can be used to recognize you or your device, including without limitation your domain name, Internet Protocol address, beacons, pixel tags or other device and mobile identifiers or similar technology.
Demographic Information – Including without limitation your name, signature, Social Security number, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information. Some PII included in this category may overlap with other categories.
Commercial Information – Including without limitation a history of the Services you purchased, obtained or considered, types of appointments you scheduled, and other purchasing or consuming histories or tendencies.
Internet or Other Electronic Network Activity Information – Including without limitation your browsing history, search history, and any other information regarding your interaction with our Services, advertisements, or third party applications.
Audio and Visual Information – Including without limitation photos or video recordings that may be taken of you if you visit any of our showrooms, offices and properties (e.g., as a security measure and to ensure the safety of our properties, we may also use video surveillance technology at our showrooms, offices and properties), and voice recordings of you when you call our customer support or leave messages on our voice mail boxes.
Inferences Drawn About Your Preferences – Including without limitation your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes, decisions, and actions as it relates to our Services.
Other Categories of Personal Data that Relates to or is Reasonably Capable of Being Associated With You – Including without limitation the messages, home system and warranty information, age and history of your home and its improvements, and other content and information you provide us during our inspections, estimates, performance of Services and any conversations and emails you have with our staff as it relates to our Services.
Data About Others – Including without limitation PII of individuals who reside in your household, such as their name, phone number, and postal address. Please do not share PII of other individuals with us unless you have their permission to do so.
B. How We Collect Your Information
ASI collects your PII from the following categories of sources: Information you voluntarily provide to us; Information we collect automatically from you through our operating system and platform; and Information from third parties including without limitation advertising networks, internet service providers, data analytic providers and social networks. Some ways we may collect data from you include, without limitation, when you:
- Schedule an appointment.
- Request an estimate proposal for our Services.
- Sign up for our newsletters.
- Enter into service contracts with us when you purchase goods from us and/or engage our Services.
- Use our Web Site (i.e., through our browser cookies, web beacons, and other similar technology).
- Voluntarily complete a survey or send us messages or other content regarding feedback and inquiries relating to our Services, marketing material, events, and other advertisement and collaboration proposals.
- Voluntarily disclose PII to our service providers and staff.
- Voluntarily comment on our social media posts hosted by third party platforms or tag or otherwise link us on your social media posts.
- Visit our showrooms, offices and properties (i.e., through our video surveillance technology).
- Use our guest Wi-Fi service at our showrooms, offices and properties.
- Interact with other third parties (e.g., our service providers) and provide your consent for them to share your PII with us.
C. Aggregated Data
We compile anonymous, aggregated statistics from Users for a variety of internal and marketing purposes. Such purposes include without limitation, benchmarking, determining appropriate levels of hardware, determining the numbers of employees that will be needed to provide the Services to our Users, and reporting numbers of Users and/or web sites that use the Services. This anonymous, aggregated data is not used in any way that can identify an individual person or User.
D. Web Site Viewing Information
There are two types of cookies: session and persistent. Session cookies disappear from your electronic device when you close your web browser or turn off your electronic device. Persistent cookies remain on your electronic device after you close your browser or turn off your computer. You can remove persistent cookies by following directions provided in your internet browser’s “help” file. If you have chosen to identify yourself to us then we use session cookies containing encrypted information to allow us to uniquely identify you.
2. Log Files
As is true of most web sites, we gather certain information automatically and store it in log files. This information does not identify individual users. Log files include internet protocol addresses, device (your computer or other device used to access our Web Sites) identifiers, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer our Web Sites, to see how users move around our Web Sites, and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to PII. Whenever we associate non-personally identifiable information or a device identifier with your PII, we will treat it as PII. We collect certain anonymous information from your visit to our Web Sites via industry standard and commercially available web analytics solutions.
3. Clear Gifs (Web Beacons) and Embedded Scripts
We use clear gifs (a.k.a. web beacons) that help us better manage content on our Web Sites by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s electronic device hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our Users’ PII. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. For more information on how to opt-out of these emails, please see the section below entitled “Choice and Opt-Out.”
Third party applications (such as widgets) created by third party developers may also be available on our Web Sites. We do not control the third party developers, and cannot dictate their actions. When a User engages with a third party application, that User is interacting with the third party developer, not with us. We encourage Users not to provide PII to third party’s application unless the User knows the party with whom it is interacting.
An embedded script is programming code that is designed to collect information about your interactions with our Web Sites, such as the links you click on. The code is temporarily downloaded onto your computer or device from our web server or a third party service provider. It is active only while you are connected to one of our Web Sites and is deactivated or deleted thereafter.
II. Use of Information Collected
ASI collects and uses your PII for various business and commercial purposes, including without limitation to:
- Perform the Services requested by you, including providing estimate proposals and recommending equipment to be used and purchased to perform the Services;
- Contact you to remind you of scheduled appointments or follow up on estimate proposals.
- Give you access to information you request;
- Help establish and verify the identity of Users and comply with all applicable laws and regulations;
- Respond to your comments and Services requests;
- Perform our contractual obligations to you;
- Process, service or enforce transactions, and sending related communications;
- Enable you to participate in our Web Sites’ features;
- Improve our Services, advertisements, and customer outreach;
- Customize your experience on our Web Sites or to provide you with specific content that is most relevant to you;
- Contact you with regard to your use of our Services and our technical notices, updates, security alerts, information about our policy changes, and other administrative messages;
- Contact you to further discuss your interest in us and our Services, and to send information regarding our company or partners (such as promotions and events);
- Effect transactions for our Services (e.g. to process the sale of our products or other part(s) or equipment needed to perform the Services);
- Maintain the security and integrity of our systems, operations, and Services;
- Prevent and address fraud, unlawful access, and breach of our policies and terms;
- Pursue legal matters and process insurance claims;
- Analyze trends and usage, such as the efficiency of deliveries and operations, and troubleshoot problems with our Web Sites, software, or Wi-Fi systems;
- Facilitate our accounting, auditing, reporting requirements and our internal business purposes;
- Fulfill any other business or commercial purposes at your direction or with your consent and for purposes disclosed at the time you provide your information or as otherwise set forth in this Policy.
III. Information Sharing and Disclosure
A. Non-Personally Identifiable and Aggregated Information
Anonymous click stream, number of page views calculated by pixel tags, and aggregated demographic information that we collect from our Web Sites may be shared with our advertisers and business partners.
We may also perform statistical analyses of User behavior and characteristics in order to measure interest in and use of the various areas of our Web Sites. In addition, we may in the future inform advertisers of such information as well as the number of Users that have been exposed to or clicked on their advertising banners. We will, however, provide only anonymous, aggregated data from these analyses to third parties.
We do not link anonymous, aggregate user data with PII.
B. Personally Identifiable Information
We may share PII with third parties in particular situations.
We may in connection with our Web Sites use the services of third parties (i.e., technology consultants and CRM vendors), who may, in the course of providing services to us, be given access to the information you have provided to us. Each of these service providers is contractually obligated to provide services to us in a manner consistent with this Policy.
Our employees, agents, and contractors must have a business reason to obtain access to your PII. We may share your PII with those who help us manage or provide the Services (e.g., attend scheduled appointments, perform repairs, maintenance installations, and to provide statistical analyses, data processing, and product order fulfillment), or with outside contractors, agents or sponsors who help us with the administration aspects of our Services.
These outside contractors or agents may temporarily store some information on their servers, but they may only use your PII to provide us with a specific service and not for any other purpose. We may also provide your PII to a third party in those instances where you have chosen to receive certain information and have been notified that the fulfillment of such a request requires the sharing of your PII. We also may share your PII with companies that are affiliated with us if we have a business reason to do so.
If in the future we intend to share personally identifiable information with third parties acting other than as our agents or service providers, we will provide you with the opportunity to opt-out prior to the sharing.
C. Law Enforcement and Assignment
We reserve the right to disclose your PII pursuant to a subpoena or other judicial or administrative order, when required by law, when we believe that disclosure is necessary to protect our rights, the rights of our affiliated companies, the rights or safety of any individual or the public, and rights of our Users or any third party. In addition, if we sell all or part of our business, make a sale or transfer of all or a material part of our assets, or are otherwise involved in a merger or transfer of all or a material part of our business, we may transfer your PII to the party or parties involved in the transaction as part of that transaction.
D. Storage and Transfer of Information
Our Web Sites are operated in the United States and intended for Users located in the United States only. If you are located in the European Union, Canada, or anywhere else outside of the United States, please note that information we collect, including, without limitation, PII, will be transferred to, processed, and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your PII may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using our Web Sites or providing us with any information, you consent to this transfer, processing and storage of your information in the United States. Please be aware that any information you provide to us or we obtain as a result of your use of our Web Sites that is shared with our affiliates or vendors may be transferred to, processed, and stored at locations outside of the United States if those affiliates or vendors are located outside of the United States. Any information processed, transferred or stored by affiliates or vendors that are located outside of the United States will be subject to applicable privacy laws in the country in which such affiliates or vendors are located. By using or providing your information to our Web Sites you consent to the collection, transfer, storage and processing of your information in this manner.
E. Categories of Third Parties We Share Information With
The categories of third parties to whom we may disclose and have shared information, include without limitation:
- Service Providers – We share information with entities that help us with maintaining and operating our websites, applications, payment processing, data analytics, marketing and advertising, and for other business and commercial purposes discussed in this Policy. Our service providers include without limitation our internet service providers, data analytics providers, and data brokers. These companies may only use such information to perform specific services that we have contracted them for and may not use it for any other purpose, although we may permit them to use aggregate information which does not identify you or de-identified data for any purpose except as prohibited by applicable law.
- Vendors – We may share information with vendors and other entities in connection with tailoring advertisements, measuring and improving our Web Sites and advertising effectiveness, helping us execute the Services that you have engaged us for, or furthering our other business and commercial purposes discussed in this Policy. Some examples include without limitation our operating systems and platforms, social networks, or suppliers of parts and equipment needed to perform the Services. These companies may act as our service providers, or in certain contexts, independently decide how to process your information.
- Affiliates – We may share information with our related entities including without limitation our parent, subsidiaries and sister companies, or to their employees, agents, contractors, representatives, legal counsel and/or accountants, for: operational, management and administrative purposes; internal audit, legal, regulatory, security, insurance, financial, processing and other similar purposes; or as otherwise permitted or required by law.
- Third Parties in Connection With a Merger, Acquisition or Other Business Transaction – We may share information if ASI is involved in a merger, acquisition, sale of all or a portion of its assets, financings, joint ventures, reorganizations, dissolution, liquidations, or other event where we sell or transfer all or a portion of our business assets or equity. We will not provide you with notice before disclosure in such cases.
- Government Entities – ASI must disclose information about you in response to lawful requests by public authorities, including but not limited to meet national security or law enforcement requirements. We may share information about you in connection with legal requirements, such as in response to an authorized subpoena or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud. Such disclosures may be carried out without notice to you.
- Third Parties that You Direct Us to Share With – We share information at your request or direction. We may also share your information with other third parties as required by applicable law or to those you have consented or directed us to share your information with.
IV. Choice and Opt-Out
In certain instances we provide you the opportunity to “opt-out” of having your PII used for certain purposes, when we ask for this information. For example, you may at any time notify us that you are no longer interested in engaging our Services and to cease communication with you regarding any estimate proposals of Services that we have provided you.
If you signed up for our newsletters and no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each communication or by contacting us and instructing us to cease sending you such communications.
V. Changing Your Information
Users may update or change their PII by notifying us and requesting we update our records or otherwise. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
The security of your PII is important to us. When you provide us with sensitive information (such as credit card number and/or social security number) on our order forms or contracts, we may encrypt that information using SSL.
We follow generally accepted industry standards to protect the PII submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.
VII. Links to and Content From Other Sites
Our Web Sites may contain links to and content from other web sites, and those third parties may collect web site usage information and information that identifies the computer or device you are using when web pages from our Web Sites are sent to your browser. We are not responsible for the privacy practices or the content of non-ASI affiliated web sites. ASI affiliated linked web sites are not under our control and we are not responsible for the contents of any such linked sites, any link contained in such linked sites, or any changes or updates to such sites. We are not responsible for any transmission received from any non-ASI entity affiliated web sites including without limitation any webcasting or other methods of transmission. Links to non-ASI entity affiliated web sites are provided only as a convenience. We do not endorse any link made available through our Web Sites that is not an ASI entity affiliated web site. We encourage all users of our Web Sites to read the privacy policies of each and every web site visited when linking directly from our Web Sites.
This Policy applies only to information collected by our Web Sites.
VIII. Public Areas of the Web Sites
If you use a public area of our Web Sites (e.g., our customer review board), you should be aware that any PII you submit there can be read, collected, or used by other Users of these forums, and could be used to send you unsolicited messages. We are not responsible for the PII you choose to submit on such forums.
In addition, if you provide to us directly, or you choose to post on the portions of our Web Sites that are viewable by others, any comments, ideas, or suggestions that are accompanied by your name (which is PII), or your first name and your last name initial, we may use both your comments, ideas, and suggestions, and your name, for our marketing purposes without compensation or acknowledgment of any kind.
The minimum age to register for the Services is 18 years old. We do not knowingly collect PII from individuals under the age of 18. Individuals under the age of 18 should not provide any information on our Web Sites. We ask that parents supervise their children while the children are online.
X. Changes in this Policy
We reserve the right to modify this Policy at any time, so please review it frequently. If we make material changes to this Policy, we will notify you here, by email, or by means of a notice on our home page. Your continued use of our Web Sites after we post a revised Policy constitutes your acceptance of the new Policy and its terms. If, however, we materially change our practices regarding the collection or use of your PII, your PII will continue to be governed by this Policy that was in place at the time you provided the PII unless we provide notice to you of the changes in the Policy and you do not object to the change.
XI. California Residents: Your California Privacy Rights.
California residents have specific rights regarding their PII as described below. These rights are subject to certain exceptions. When required, we will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time.
- Right to Know About PII That is Collected or Disclosed – You have the right under the California Consumer Privacy Act (“CCPA”) to request that we disclose certain information regarding our practices with respect to your PII. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:
- The categories of PII we have collected about you in the last 12 months.
- The categories of sources for the PII we have collected about you in the last 12 months.
- Our business or commercial purpose for collecting PII.
- The categories of third parties with whom we share PII.
- The specific pieces of PII we collected about you.
- If we disclosed your PII to a third party for a business purpose, a list of the PII types that each category of recipient received.
- Right to Request Deletion of PII – You have the right under the CCPA to request that we delete any of your PII that we collected from you and retained, subject to certain exceptions. If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will delete all information that we are not allowed to maintain under applicable law.
- How to Exercise the Above Rights – To exercise your rights discussed described above, please submit a verifiable consumer request by contacting us. You may make a verifiable consumer request no more than two times within a 12-month period. The verifiable request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected PII or an authorized representative. Such verification process will involve you confirming at least three pieces of PII we have collected about you, and will increase in scope in the event the nature of your request relates to the disclosure of sensitive PII or the deletion of any PII;
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it; and
- Include a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know/Delete request has been made.”
- Right to Appoint an Authorized Agent – You are also permitted to designate an authorized agent to submit the above requests on your behalf. For an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity according to the above method before processing the authorized agent’s request.
- Right to Non-Discrimination for Exercising Privacy Rights and Notice of Financial Incentive – You may exercise your rights under the CCPA without discrimination. However, if you choose not to provide us with certain information, our ability to provide you with certain Services may be hindered, or in some cases, may bar us completely from providing them. For example, if you do not provide us with your contact information and home address then we will not be able to inspect your home and prepare an estimate of our Services for you. Further if you do not provide us with material information relating to your home, we may not be able to properly diagnose and recommend the repairs or equipment needed to service your requests.
- Additional Disclosures Related to Collection, Use, and Disclosure of PII – Sections I through III of this Policy describes the categories of PII we collect, categories of sources of PII that we collect from, the business or commercial purpose for collection, and categories of third parties we disclose information to.
- Sale of Personal Data – We do not believe that we sell your PII as defined under the CCPA and we will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law.
- Direct Marketing and Do Not Track Signals – Under California’s “Shine the Light” law, California residents may request and obtain a notice once a year about the PII we shared with other businesses for their own direct marketing purposes. Such a notice will include a list of the categories of PII that were shared (if any) and the names and addresses of all third parties with which the PII was shared (if any). The notice will cover the preceding calendar year. To obtain such a notice, please contact us as described below. In addition, under this law you are entitled to be advised how we handle “Do Not Track” browser signals. ASI does not personally track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, most web browsers (like Safari) allow you to set the DNT signal on your browser so third parties (particularly advertisers) know you do not want to be tracked.
XII. Contact Information
If you have any questions about this Policy, please contact us at address or telephone number listed below. Or to have your information removed from our database, please complete the request form located here.
4870 Viewridge Av. #200
San Diego, California 92123
1 (619) 363-5566
Date of Last Revision: August 28, 2020