Last Modification: 3/15/21
As you review our policy, here are a few general principles to keep in mind:
Our services are intended for a United States audience. If you visit or use one of our websites or online services, your information may be transferred or processed in the United States.
Our services and products are not intended for children under 13. We do not knowingly collect personal information from children under 13 without parental consent.
If you are a California resident, you may have rights under the California Consumer Privacy Act.
Collection of Information
In addition, personal non-public information is required for several of our products and we may ask you to provide them to us. These include:
Collection of personal information from or about you such as your name, email address, mailing address, and telephone number(s);
Completing contracts and related forms, which include social security number, information about existing retirement accounts a customer holds;
Retirement account history, including information about the transactions and balances in a customer’s accounts;
Financial information to determine availability of financing solutions for you;
Correspondence, written, telephonic or electronic between a customer and Doxa7 or service providers to Doxa7;
If you purchase our services, we will ask you to provide payment information; and
Use of Information
We will use the above-collected information in a number of ways including:
Qualifying customers for Doxa7’s products and services;
Processing applications and transactions;
Verifying your identity (such as when you access your account information);
Preventing fraud and enhancing the security of your account or our services;
Responding to your requests and communicating with you;
Managing your preferences;
Performing analytics concerning your use of our services, including your responses to our emails and the pages and advertisements you view;
Providing you tailored content and marketing messages;
Operating, evaluating, and improving our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing, and other internal functions);
Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations, and our policies; and
For any other purposes that we may specifically disclose at the time you provide, or we collect your information.
We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations. Your specific consent shall be secured when necessary.
You agree that the above-mentioned information will be retained or stored for as long as the purposes for which they are being processed have not been satisfied. Doxa7 will retain and use your information as necessary to comply with legal obligations, resolve disputes, and enforce its agreements.
Disclosure of Client Information
We may disclose personal information to third parties who are not affiliated with Doxa7 in certain circumstances. Examples may include:
As Authorized – if you request or authorize the disclosure of the information;
As Permitted by Law – for example, sharing information with companies who maintain or service customer accounts for Doxa7 is permitted and is essential for us to provide clients with necessary or useful services with respect to their accounts. Furthermore, we may disclose or report personal information, such as account and transaction data, where we believe in good faith that disclosure is required or permitted under law (e.g., to cooperate with regulators, receivers, or to resolve client disputes);
Outside Counsel – Doxa7 products/contracts generally include consultation with outside counsel. Your information will be available to the Outside Counsel in order to facilitate prompt communication and completion of your contract;
Partners – If you were referred to Doxa7 by one of Doxa7’s Partners (a Franchisor, a Business/Franchise Broker or Consultant, a Lender, or a Financial Professional), we may provide information to the Partner as to your qualification towards Doxa7’s products, your status in our processes, and/or other information that is helpful for the parties unless you specifically direct us otherwise;
Doxa7 Third Party Service Providers;
Third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation, or merger; and
Doxa7-affiliated websites and businesses in an effort to bring you improved service across our family of products and services, when permissible under relevant laws and regulations.
By providing your information to Doxa7, you consent to receive information and offers from Doxa7 at the email address or telephone numbers you have provided, including auto-dialed calls, and SMS or MMS messages. If you do not wish to receive offers for additional products or services, you should not provide your personal information or contact information through our website. Should you wish to stop receiving further offers, you may contact us at [email protected].
Doxa7 encourages you to keep your information current and updated. You may email us at [email protected] to request to update your information. When you request access to your information, we will take reasonable steps to confirm your identity before granting you access and updating your information.
Security of Client Information
We train our staff to safeguard personal information of our clients, and they are required to use such information for business purposes only. Doxa7 maintains the following policies and procedures regarding privacy with its staff:
Sensitive information stored electronically in our databases, such as Social Security Numbers, Birth Dates, Credit Card Numbers, etc. are encrypted. Access to this information is controlled and stored on secured servers to protect against unauthorized use and access.
Paper files containing sensitive information are kept in secure areas where access is closely controlled and monitored.
Staff receives training on the types of information we can and cannot disclose to individuals and/or organizations outside Doxa7.
California Privacy Rights
If you reside in California, you may also make the following more specific requests with respect to your personal information in accordance with applicable law:
Access – You can request by clicking here, we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the categories of personal information sold or disclosed, the business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we share the personal information, and the specific pieces of personal information collected about you over the past 12 months.
Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions by clicking here.
As is the case for all consumers regardless of residency, we will not discriminate against you because you exercised any of these rights. Note that for purposes of these rights, personal information does not include information about job applicants, employees, and other of our personnel; information about employees and other representatives of third-party entities we may interact with; or information we have collected as a service provider to our clients.
California residents can exercise these rights online by emailing us at [email protected]. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record-keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.
California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent and ensure the agent has the necessary information to complete the verification process.
Erasure or Blocking of Personal Information
You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your personal information. You can exercise this right upon discovery and substantial proof of the following:
Your personal information is incomplete, outdated, false, or unlawfully obtained;
It is being used for purposes you did not authorize;
Said information is no longer necessary for the purposes for which they were collected;
You decided to withdraw consent, or you object to its processing and there is no overriding legal ground for its processing;
Said information concerns information prejudicial to you unless justified by freedom of speech, of expression, or of the press, or otherwise authorized by court order or by law;
The processing of said information is unlawful; or
The Personal Information Controller or the Personal Information Processor violated your rights as data subject.
You may submit your request for suspension, withdrawal, blocking, and/or removal by submitting a written request to [email protected].
Ira Crisologo is the Personal Information Controller who determines what purposes personal information held will be used for. Should your personal information be disclosed to third parties under the data-sharing agreement, such third parties are also the personal information controllers.
If you have any complaints, concerns, or questions regarding the processing of your information, please contact us at [email protected].