Privacy Policy

Effective Date.

This Privacy Policy was last updated on June 1, 2023.

The Connect Me Better website and platform (the “Website”) is owned and operated by OmniEngine LLC (“OmniEngine” or the “Company”), a Delaware limited liability company. This Privacy Policy, together with our Terms of Use (collectively, the “Agreement”) form a legally binding agreement between you (“you” or “your”) and OmniEngine (“us”, “we” or “our”). This Agreement governs your access to and use of any of our Websites, your use or attempted use of our products and services, and your use or attempted use of our (and our affiliates’) clients/service providers’ (the “Service Providers”) products and services (collectively, the “Services”). Your use of the Website shall be deemed to constitute your consent to be bound by this Agreement and shall be enforceable in the same way as if you had signed this Agreement.

Contents

1. Scope of the Policy
2. Information We Collect
3. How We Use Your Information
4. How We Share Your Information
5. How We Store and Protect your Information
6. Your Rights and Choice Regarding Your Data
7. Third Party Links and Behavioral Tracking
8. Children’s Data
9. Security Policy
10. International Users
11. Changes to This Privacy Policy
12. Contact Us

1. Scope of the Policy

This policy applies to all visitors to this Website and all OmniEngine’s websites and services, including any apps, websites, features, and other services. Please remember that your use of this website is also subject to our Terms of Use.

2. Information We Collect
   

A. Personal, Business and Financial DataOmniEngine collects personal information when you visit the Website and/or during your communications and/or interactions with our representatives and Service Providers. Much of this information is collected during the intake, registration and/or application process and, while some items are optional, some are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Website; in some cases, this additional information will be required by us as a condition of your availing yourself of OmniEngine’s and/or the Service Providers’ goods or services, or your continued use of the Services.

Generally, the type of information we collect includes, but is not limited to:

• Data required to verify your identity and any consents necessary for receipt of the Services;
• Personal, business, and financial data necessary to assess your eligibility to utilize the Services on the Website; and
• Non-identifiable and aggregated personal/business data pertaining to your Website visits that help the Company evaluate and maintain quality control with respect to the features, functionality, and user experience of the Website.

B. Personal/Business Data

Registration pages and forms require you to provide basic personal data. This includes your name, email address, home or business address, zip code, and phone number. The Company uses this data to:  (i) establish your eligibility to utilize the Company’s or the Service Providers’ goods and services; (ii) verify your age (if applicable); (iii) guard against potential fraud; (iv) contact you if we would like to reach you; (v) improve its Services; and (vi) maintain regular and reliable communications with you regarding interest in Company, its affiliates or their respective Service Providers’ Services, activities and related matters.

We also gather the names, telephone numbers, and email addresses of users and visitors who contact us through the Website with questions about the Company, our affiliates, our Service Providers, the Website, or the Services.

C. Other Personal DataThe Company may send one or more “cookies” to your computer. Cookies are small text files placed on your web browser when you visit our Website that store information on your computer, such as your Website preferences. We use cookies to track your activity on the Website as a unique person.

When you enter sensitive information on our online forms (including when we collect geolocation information), we encrypt the transmission of that information using Transport Layer Security (TLS). We utilize industry standard physical, technical, and administrative controls and procedures to safeguard the information we collect, to prevent unauthorized access or disclosure, to maintain data accuracy, and to allow only the appropriate use of your personal data. Because no method of transmission over the Internet or method of electronic storage is completely secure, we cannot guarantee its absolute security.

You can set your web browser to inform you when cookies are set, or to prevent cookies from being set altogether. Please note, however, that if you decline to use cookies, you may experience reduced functionality and slower site response times. In some instances, declining to use our authentication-related cookies may prevent you from using the Website and the Services entirely.

The Company and its service providers may also collect web surfing data related to your use of the Website. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Website. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.

Web surfing data and similar information may be aggregated for administrative purposes. We may use this aggregated information in the administration of the Website to improve its usability and to evaluate the success of marketing and advertising campaigns. We also use it to help optimize the Website based on the needs of our users.

A summary of the categories of personal information that we collect from you within the last twelve (12) months:

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

• Directly from you: For example, from forms/surveys you complete, information you input into the Website, and any other communications between you and the Company and/or its representatives, including information relating to products and services you purchase from our Service Providers.
• Directly from our Service Providers: For example, from documents or files that our Service Providers give us including, but not limited to, suppression lists/do not call lists.
• Indirectly from you: For example, from observing your actions on the Website.
• From third parties that contract/interact with us or our affiliates in connection with the Services we perform.  For example, from third parties that may contact you, on our behalf or on our Service Providers’ behalf, to provide you relevant content or from third parties that help us perform the Services.

3. How We Use Your Information

We use your personal information to:

Communicate With You.
We may use the information we collect from you to provide you additional information on goods or services that you have requested. In accordance with applicable laws, this may include phone communications, text messages and/or emails at the phone number/address you have provided or additional marketing communications by email.

We may also send you responses to emails you send us, if appropriate.  We may send user surveys, requests for user feedback regarding user experience and Website operations, or marketing offers from us or from us on behalf of our marketing partners. Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary. If you do not wish to receive these surveys, user feedback emails, and/or marketing offers, please opt out in any offer email you receive from us.

Provide Customer Support.
We work hard to provide the best experience possible, including supporting you when you need it. To do this, we use your personal information to:

• Assist you in resolving questions or issues you have regarding the Website; and
• Provide you support or respond to you.

Improve the Website.
We are always working to improve your experience and provide you with new and helpful features. To do this, we use your personal information to:

• Perform research, testing, and analysis;
• Develop new products, features, partnerships, and services;
• Prevent, find, and resolve software or hardware bugs and issues; and
• Monitor and improve our operations and processes, including security practices, algorithms, and other modeling.

Performing Services.
For example, we use the personal information you submit through our website or via our representatives to help us provide you with information, products, or services that you request from us; in addition, we will use your information to customize our Services for you, including facilitating your transactions with Service Providers, hosting our Website, managing databases, performing analyses, and marketing services.

Notices.
Email alerts and other notices concerning our Services and our Service Providers’ products/services that may be of interest to you.

Audits.
Auditing interactions with users. For example, monitoring traffic to our Website, counting ad impressions, and auditing legal and regulatory compliance.

Security.
For example, maintaining the safety, security, and integrity of our business, services to our Service Providers, Website and its Services, databases, and other technology assets, including preventing fraud, detecting security breaches, and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations.

Debugging/Repair.
For example, identifying and repairing errors in our Website’s functionality.

Short-term Uses.
For example, ad customization that does not involve or contribute to profiling.

Internal Research for Tech Development.
For example, testing, research, analysis, and product development, including to develop and improve our Website and Services.

Quality and Safety Maintenance and Verification.
For example, improving, upgrading, or enhancing our Services or Website, and verifying the quality or safety of our Website or Services.

Other Commercial Purposes.
For example, as described to you when collecting your personal information resulting in a commercial transaction with our Service Providers and/or to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for any purposes other than those disclosed in this Privacy Policy without first providing you notice.

Respond to Legal Proceedings and Obligations.
Occasionally the law, government entities, or other regulatory bodies impose demands and obligations on us with respect to the Services we seek to provide. In such a circumstance, we may use your personal information to respond to those demands or obligations.

4. How We Share Your Information

Sharing With Third Parties for Business Purposes.
We may share or sell your personal information to a third party for a business purpose including those who may offer services that complement those provided by us or which we believe may be of interest to you. When we disclose personal information for a business purpose, we 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 for performing the contract.

We may work with (among others) providers of hosting services for the Website, electronic signature providers, and electronic payment service providers. We may engage third parties to help us carry out certain other internal functions such as account processing, client or Service Provider services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing or data storage. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.

We may share or sell your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Our Service Providers.
• Our vendors, third party vendors and service providers that help us perform the Services offered by the Website.

For Legal Reasons.
We may share your personal information in response to a legal obligation, or if we have determined that sharing your personal information is reasonably necessary or appropriate to:

• Comply with any applicable federal, state, or local law or regulation, civil, criminal, or regulatory inquiry, investigation or legal process, or enforceable governmental request;
• Respond to legal process (such as a search warrant, subpoena, summons, or court order);
• Enforce our Terms and Conditions;
• Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law; or
• Exercise or defend legal claims, protect against harm to our rights, property, interests, or safety or the rights, property, interests, or safety of you, third-parties, or the public as required or permitted by law.

In Connection with a Sale or Merger.
We may share your personal information while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.

Otherwise With Your Consent.
With your permission or upon your direction, we may disclose your personal information to interact with a third party or for other purposes.

5. How We Store and Protect your Information

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. We restrict access to your personally identifying information to employees who need to know that information to operate, develop or improve our services.

6. Your Rights and Choice Regarding Your Data

A. All Users.

Review and Request Changes. If you would have to review and request changes of your personal information that has been collected by the Website, please contact inquiries@omniengine.com.

Email Subscriptions. You can always unsubscribe from our commercial or promotional emails by clicking unsubscribe in those messages. We will still send you transactional and relational emails about your use of the Website.

Cookie Tracking. You can modify your cookie settings on your browser, but if you delete or choose not to accept our cookies, you may be missing out on certain features of the Website.

“Do Not Track” Signals. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. We honor “Do Not Track” signals and do not track, plant cookies, or use advertising when a “Do Not Track” browser mechanism is in place.

B. Specific State Rights.

1. California Residents.

Shine the Light. Cal. Civ. Code § 1798.83 permits customers of OmniEngine who are California residents to request certain information regarding and/or opt-out of our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident and would like to make such a request, please e-mail us at inquiries@omniengine.com and include your full name, residential address, e-mail address, and phone number, along with why you are writing, so that we can process your request in an efficient manner.

CCPA. The California Consumer Privacy Act (CCPA) provides California residents with the additional rights listed below.

Right to Know. You have the right to know and see what data we have collected about you over the past 12 months preceding your request, including:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting your personal information;
• The categories of third parties with whom we have shared your personal information; and
• The specific pieces of personal information we have collected about you.

Right to Delete. You have the right to request that we delete the personal information we have collected from you unless we need to retain that information for a specified purpose as exempted under state law.

Right to Correct. You have the right to request that we correct inaccurate personal information.

Do Not Sell or Share My Personal Information. You have the right to request that we do not sell or share your personal information. Please click here so that we can process your request. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization.

Other Rights. You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.

Exercising Your California Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us using the following method:

E-mail: You may write to us to exercise rights. Please include your full name, residential address, e-mail address, and phone number, along with why you are writing, so that we can process your request in an efficient manner. Please e-mail us at inquiries@omniengine.com.

Webform: You may fill out a Webform to exercise rights. Please include your full name, e-mail address, and phone number, along with why you are writing, so that we can process your request in an efficient manner.

Toll-Free Telephone Number: You may call us at (888) 808-1787 to exercise rights. Please include your full name, residential address, e-mail address, and phone number, along with why you are calling, so that we can process your request in an efficient manner.

Response Timing. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

2. Colorado Residents.

Effective July 1, 2023.

The Colorado Privacy Act (CPA) provides Colorado residents with the additional rights listed below.

Right to Know. You have the right to confirm whether we are processing your personal data and access such data, including:

• The categories of personal information we have collected about you;
• The purpose for processing your personal information;
• How you can exercise your rights and appeal a decision regarding your request;
• The categories of personal information that we have shared with third parties; and
• The categories of third parties with whom we have shared your personal information.

Right to Correct. You have a right to correct inaccuracies in the personal data we have collected about you, considering the nature of the personal data and the purposes of the processing of your personal data.

Right to Delete. You have the right to request that we delete the personal information we have collected from you unless we need to retain that information for a specified purpose as exempted under state law.

Right to Obtain a Copy. You have a right to obtain a copy of the personal data we have collected on you.

Right to Opt Out. You have the right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Appeal. If we decline to act regarding your request, you have the right to appeal this decision. We will decide the outcome of your appeal within 60 days of receipt of such appeal, and we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Other Rights.  You also have the right not to be discriminated against for exercising any of the rights listed above.

Exercising Your Colorado Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under Colorado law, please contact us using the following method:

E-mail: You may write to us to exercise rights. Please include your full name, residential address, e-mail address, and phone number, along with why you are writing, so that we can process your request in an efficient manner. Please e-mail us at inquiries@omniengine.com.

Webform: You may fill out a Webform to exercise rights. Please include your full name, e-mail address, and phone number, along with why you are writing, so that we can process your request in an efficient manner.

Toll-Free Telephone Number: You may call us at (888) 808-1787 to exercise rights. Please include your full name, residential address, e-mail address, and phone number, along with why you are calling, so that we can process your request in an efficient manner.

Response Timing. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing. If we decline to act regarding a consumer request, we will inform you of the reason within 45 days of receiving that request.

3. Connecticut Residents.

Effective July 1, 2023.

The Connecticut Data Privacy Act (CTDPA) provides Connecticut residents with the additional rights listed below.

Right to Know. You have the right to confirm whether we are processing your personal data and access such data, including:

• The categories of personal information we have collected about you;
• The purpose for processing your personal information;
• How you can exercise your rights and appeal a decision regarding your request;
• The categories of personal information that we have shared with third parties; and
• The categories of third parties with whom we have shared your personal information.

Right to Correct. You have a right to correct inaccuracies in the personal data we have collected about you, considering the nature of the personal data and the purposes of the processing of your personal data.

Right to Delete. You have the right to request that we delete the personal information we have collected from you unless we need to retain that information for a specified purpose as exempted under state law.

Right to Obtain a Copy. You have a right to obtain a copy of the personal data we have collected on you.

Right to Opt Out. You have the right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Appeal. If we decline to act regarding your request, you have the right to appeal this decision. We will decide the outcome of your appeal within 60 days of receipt of such appeal, and we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Other Rights.  You also have the right not to be discriminated against for exercising any of the rights listed above.

Exercising Your Connecticut Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under Connecticut law, please contact us using the following method:

E-mail: You may write to us to exercise rights. Please include your full name, residential address, e-mail address, and phone number, along with why you are writing, so that we can process your request in an efficient manner. Please e-mail us at inquiries@omniengine.com.

Webform: You may fill out a Webform to exercise rights. Please include your full name, e-mail address, and phone number, along with why you are writing, so that we can process your request in an efficient manner.

Toll-Free Telephone Number: You may call us at (888) 808-1787 to exercise rights. Please include your full name, residential address, e-mail address, and phone number, along with why you are calling, so that we can process your request in an efficient manner.

Response Timing. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing. If we decline to act regarding a consumer request, we will inform you of the reason within 45 days of receiving that request.

4. Nevada Residents.

Do Not Sell My Personal Information. Nevada residents have the right to request that we do not sell your personal information. Please click here so that we can process your request. We aim to respond to a consumer request for within 60 days of receiving that request.

5. Virginia Residents.

The Virginia Consumer Data Protection Act (VCDPA) provides Virginia residents with the additional rights listed below.

Right to Know. You have the right to confirm whether we are processing your personal data and access such data, including:

• The categories of personal information we have collected about you;
• The purpose for processing your personal information;
• How you can exercise your rights and appeal a decision regarding your request;
• The categories of personal information that we have shared with third parties; and
• The categories of third parties with whom we have shared your personal information.

Right to Correct. You have a right to correct inaccuracies in the personal data we have collected about you, considering the nature of the personal data and the purposes of the processing of your personal data.

Right to Delete. You have the right to request that we delete the personal information we have collected from you unless we need to retain that information for a specified purpose as exempted under state law.

Right to Obtain a Copy. You have a right to obtain a copy of the personal data we have collected on you.

Right to Opt Out. You have the right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Appeal. If we decline to act regarding your request, you have the right to appeal this decision. We will decide the outcome of your appeal within 60 days of receipt of such appeal, and we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Other Rights.  You also have the right not to be discriminated against for exercising any of the rights listed above.

Exercising Your Virginia Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under Virginia law, please contact us using the following method:

E-mail: You may write to us to exercise rights. Please include your full name, residential address, e-mail address, and phone number, along with why you are writing, so that we can process your request in an efficient manner. Please e-mail us at inquiries@omniengine.com.

Webform: You may fill out a Webform to exercise rights. Please include your full name, e-mail address, and phone number, along with why you are writing, so that we can process your request in an efficient manner.

Toll-Free Telephone Number: You may call us at (888) 808-1787 to exercise rights. Please include your full name, residential address, e-mail address, and phone number, along with why you are calling, so that we can process your request in an efficient manner.

Response Timing. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing. If we decline to act regarding a consumer request, we will inform you of the reason within 45 days of receiving that request.

7. THIRD PARTY LINKS AND BEHAVIORAL TRACKING

Third Party Links.
We may include links or offers to third-party products or services on our website. These third-party sites have separate and independent privacy policies. We are not responsible or liable for the content and activities of these third-party sites.

Third Party Information Gathering.
OmniEngine includes content and ads from third parties that may perform user activity tracking other than that described herein. These other sites may place their own cookies on your computer, collect data or solicit personal information. For more information about each third-party content provider, cookies, and how to “opt-out”, please refer to such third-party advertiser’s privacy policy.

8. Children’s Data

To use the Website, you must be 18 years or older and have the power to enter a binding contract with us and not be barred from doing so under any applicable laws; or 13 years or older and have your parent or guardian’s consent to the Agreement. The Website is not intended for children under the age of 13 and no person under the age of 13 may use the Website. If you use the Website, you are affirming that you are at least 13 years old.

9. SECURITY

A. Access Limitations

We limit access to the personal information we have about you to those affiliates, employees, contractors, representatives and Service Providers who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards, and controls to protect your information. The Website is built upon a secure infrastructure with multiple layers of protection, and we use industry-standard encryption technologies to safeguard your information.

B. Notifications of Security Systems Breach

If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Website in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

C. Take Precautionary Measures

You can take several precautions to protect the security of your computer and personal information. For instance, you can use a strong password and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on the Website, be sure that you log out and close the browser window. You should also be aware of fraudulent attempts to gain access to your account information through “phishing,” whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake site, scammers will ask for login information to gain access to people’s accounts and withdraw their money.

We will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go to the Website directly from your browser’s home page.

10. International Users

The Website may be accessed by users located outside the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States, and that by providing your personal information on or through the Website then you consent to that transfer. As a result, personal information under the Company’s custody or control may be accessible to regulatory authorities, the courts and law enforcement officials in accordance with the laws of the United States.

11. Changes to This Privacy Policy

We may update this policy from time to time as the Website changes and privacy law evolves. If we update it, we will do so online. When you use the Website, you are agreeing to the most recent terms of this policy.

12. Contact Us

This Website is operated by OmniEngine LLC, located at 3600 E University Dr, Suite E-1050, Phoenix, AZ 85034. If you have any questions or concerns about your privacy or anything in this policy, please contact us at inquiries@omniengine.com.