This Website Privacy Policy (the “Policy”) describes the information practices, policies and procedures of Talon HC, Inc., a Delaware corporation, and/or its affiliates (“Talon” or “we”) with regard to our websites and other public-facing online services (the “Services”), including without limitation www.talonfi.com (the “Site”). 

We understand your concerns about privacy and your interest in knowing how your information is used and safeguarded, and we want to provide you with more information on these topics.

1. Personal Information We Collect

We may collect information that describes or relates to you (“personal information”).  Where required by applicable law, we will obtain your consent for the collection, use and/or disclosure of your personal information.

You represent and warrant that you will only provide information and use the Site acting in your capacity as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit or other legal entity, and that your communications and transactions with Talon occur solely within the context of Talon providing the Site to the company, partnership, sole proprietorship, nonprofit or other legal entity that you represent.

Certain services, requests and features proposed via our Site require that you voluntarily provide us with some personal information (including, but not limited to, name, postal address, email address); availing yourself of any of these services, requests and features is voluntary. We collect this information for our business purposes, such as providing information, products and services, and our marketing activities.

2. How We May Disclose Your Personal Information

In certain situations, Talon may disclose personal information (described herein) that we collect, in accordance with our legitimate interests and business purposes as stated in this Privacy Policy and set forth below.

• Operating Services and Site and Providing Related Support. To provide and operate our Site and Services, communicate with you about your use of the Site and Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, communicate with you, and for similar service and support purposes.
  
  

• Business Mergers or Acquisitions. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company, subject to the same terms of this privacy policy, or a policy that provides equal or greater protections for the personal information. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.

• In Response to Legal Process. We may disclose your personal information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  
  

• To Protect You, Us, and Others. We disclose your personal information when we believe it is appropriate to do so to investigate, prevent, or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy, or as evidence in litigation in which we are involved.
  
  

We may disclose personal information to the following:

• Service Providers. We may share personal information we collect with service providers who perform activities on our behalf, such as payment processing, data analytics, marketing and promotional services, website hosting and technical support. In accordance with applicable law, our service providers are required to take appropriate security measures to protect your personal information in line with our policies and are not permitted to use personal information for their own purposes.
  
  

• Third-party providers. We may disclose personal information to our third-party providers, such as our hosting or internet service providers, with whom we have contracted.
  
  

• Children’s Privacy
  
  

Talon’s Site, products and services are intended for a general audience and are not directed to children, including those under the age of sixteen (16). As such we do not knowingly collect, use, solicit or disclose personal information about children less than 16 years of age. If you are under the age of 16, we ask that you do not access the Site. 

4. How We Safeguard Your Information

We implement and maintain appropriate administrative, physical, and technical security safeguards to help protect the personal information we collect about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

5. International Transfers

We do not represent or warrant that the Site, or any part thereof, are appropriate or available for use in any particular geographic location. If you choose to access the Site, you do so on your own initiative and at your own risk, and you are responsible for complying with all local laws, rules, and regulations applicable in your jurisdiction. Please note that the Site are hosted in the United States and are governed by United States law. If you are visiting the Site from outside the United States, please be aware that your information will be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using the Site, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

6. Privacy Questions and Contacting Us

If you have any questions or concerns about our Privacy Policy or data practices, or our compliance with applicable law please contact us by email privacy@talonfi.com. 

7. Additional Disclosures for California Residents

The following disclosure pertain specifically to California residents.

1. California Privacy Rights

If you are a California resident, you may have the following rights under the California Consumer Privacy Act (“CCPA”) with respect to your personal information.

• Right to Know/Access. You have the right to request (subject to certain exemptions):

  • The categories of personal information we collected about you;

  • The sources from which we have collected that personal information;

  • Our business or commercial purpose for collecting, selling, or sharing that Personal Information;

  • The categories of third parties to whom we have disclosed that personal information; and

  • A copy of the specific pieces of personal information we have collected.

• Right to Correct. You have the right to request that we correct inaccuracies in your personal information.

• Right to Delete. Subject to certain exceptions, you have the right to request deletion of personal information that we have collected from you. Please note, Talon is not obligated to delete personal information that is necessary to provide services that you request or required to comply with applicable laws.
  
  

• Right to Opt-Out. Under the CCPA, California residents may have the right to opt-out of the “sale,” or “sharing,” of personal information. California CCPA defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA), the following categories of personal information: Identifiers, and Internet or Other Electric Network Activity Information to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old. 

• Right to Limit Use and Disclosure. Subject to certain conditions and exceptions, you may have the right to limit the use and disclosure of “sensitive personal information,” as defined under the CPRA. However, we do not engage in activities triggering this right.

• Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

2. How To Exercise Your Privacy Rights

To exercise any of these rights, California residents may email us privacy@talonfi.com.

In the request, please include “California Privacy Rights Request” in the first line of the description and specify which right you are seeking to exercise. We will confirm receipt of your request within 5 business days. 

Talon will need to confirm your identity before fulfilling the request, so please provide us with your name, street address, city, state, and ZIP code. We may require additional information from you to help us verify your identity and process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf. We may also ask you directly to verify that you have authorized your authorized agent to act on your behalf.

If personal information about you has been processed by us as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.

3. Notice of The Right to Opt-Out of Sale or Sharing

To the extent Talon sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by emailing us at privacy@talonfi.com.