Last Modified: January 5th, 2022

This Privacy Notice for California Residents (“Privacy Notice”) supplements any other privacy notice provided by BuyerForesight, a Step2 Strategy, LLC (“BuyerForesight,” “we,” “us,” or “our”) and applies solely to individuals who reside in the State of California (“consumers” or “you”). Terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this Privacy Notice.

Categories of Personal Information We Collect about California Consumers

Over the past twelve months, we have collected the following categories of information from California Consumers:

• Personal identifiers such as name, telephone number, payment information, physical address, email address, username, password and other credentials used to access BuyerForesight’s products and services.
• Commercial information, such as records of services purchased or received from us.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with the Website, application, or advertisement.
• Unique identifiers, including Internet Protocol address, device identifier, cookies, beacons, or other similar technologies.
• Audio recordings and electronic information.
• Professional or employment-related information, including company name, company physical address and email address and telephone or fax number, education, current or past employment history.
• Inferences reflecting your preferences, characteristics, predispositions, behavior, and attitudes drawn from: (1) the information we collect when you visit the Website, use our apps, or interact with our tools, widgets or plug-ins or our official social media pages or related social media apps, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers and vendors, regarding content and other data posted on the internet (such as public locations on the internet), and (3) information we purchase from third parties in order to create a profile about a consumer.

Sources of Collection

Over the past twelve months, we collected the above categories of personal information from the following sources:

• You.
• Service providers, vendors, and affiliates.
• Public databases.
• Social media platforms and third-party partners, such as analytics or marketing providers.

Purposes for Which We Collect this Personal Information

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

• To fulfill or meet the reason you provided the information.
• To provide, support, personalize, and develop the Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, applications, purchases, subscriptions, transactions, and payments and to prevent transactional fraud.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of the Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve the Website, products, and services.
• 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.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of BuyerForesight’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by BuyerForesight is among the assets transferred.

Third Parties to Whom We Have Disclosed Personal Information

We have disclosed personal information in all or substantially all of the categories identified in this Privacy Notice for business purposes to the following categories of third parties over the past twelve months:

• Third party service providers.
• Joint marketing partners.
• Affiliates.
• Clients.

We also share information about your physical location with our affiliates, clients, joint marketing partners, and other third parties to, for example, enhance location-based services. In addition, except as described below, unless you opt out, we may share other personal information with third parties for those parties’ own purposes, such as to offer products or services that may interest you.

Third Parties to Whom We Have Disclosed Personal Information

Within the past twelve months, we have disclosed personal information to third parties for monetary or other valuable consideration. The categories of personal information we have disclosed are:

• Personal identifiers.
• Internet and other network activity information.
• Inferences drawn from your personal information.

We have no actual knowledge of any sale of information of minors under 16 years of age.

Your Rights and Choices

The CCPA provides consumers that are California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. We will honor requests received and verified to the extent required by applicable law and within the time provided by law.

Right to Access and Information regarding Personal Information. You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you over the twelve month period preceding your request.

Right to Request Deletion of Personal Information. You have the right to request that we delete personal information that we have collected from you.

Right to Opt Out. You have the right to opt out of the future disclosure of personal information about you for monetary or other valuable consideration.

Non-Discrimination. You have the right to not be discriminated against because of your exercise of your rights under the CCPA.

Financial Incentive. We may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior consent, which you may revoke at any time.

Requests to Exercise Your Rights

You may request to exercise the foregoing rights by:

• Submitting a request by visiting our Web Form
• By submitting an email to [email protected]

Please note that we will ask for additional information to match with information we have on file in order to verify your identity before acting on your request to exercise your rights. The personal information that we use to verify your identity will not be used for any other purpose.

Data Sharing for Direct Marketing Purposes

California Civil Code Section §1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. To make such a request please send us an email setting forth your preferences to [email protected]

How To Contact Us

You also may write to us at: Step2 Strategy, LLC, 314 W. Superior St., Suite 500-2, Duluth, Minnesota 55802.

If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by sending an email to [email protected].

Should you have a disability that prevents or limits your ability to access this policy, please email us at [email protected] or call us at +1 218-302-1460. We will work with you to provide this notice in an alternative format.