California Privacy / CPRA

This page supplements the Loyalty LTD Privacy Policy and applies to California residents where the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), applies.

www.alwayshereos.com is operated by Loyalty LTD, a Nevada domestic limited liability company located at 2206 Heavenly View Drive, Henderson, NV 89014, doing business under the AlwaysHereOS brand. Loyalty provides managed operations services to performance marketing companies. Loyalty does not operate its Clients' campaigns in its own name, does not buy or sell leads or calls for its own account, and does not act as an advertising network or lead aggregator.

1. Two Roles, Two Sets of Rules

Business and website contacts. For company owners, managers, employees, vendors, applicants, and website visitors who interact with us directly, Loyalty is the "business" under the CCPA/CPRA and this page describes your rights.

Client consumers. Where Loyalty accesses or receives information about a Client's consumers, leads, callers, or partners in order to perform managed operations services, Loyalty acts as a service provider to the Client that controls the data. Requests from those individuals should be directed to the company they interacted with. If you contact us, we will forward the request to the applicable Client and assist as their service provider.

2. California Privacy Rights

Subject to the above, California residents may have the right to:

• Know what categories of personal information we collect
• Know the categories of sources from which personal information is collected
• Know the business or commercial purposes for collecting or disclosing personal information
• Know the categories of third parties to whom information is disclosed
• Request access to specific pieces of personal information
• Request deletion of personal information
• Request correction of inaccurate personal information
• Opt out of the sale or sharing of personal information
• Limit the use and disclosure of sensitive personal information
• Not be discriminated against for exercising privacy rights
• Appeal a denial of a request

To exercise these rights, email privacy@alwayshereos.com, call (505) 477-3990, or use the Legal Request Form.

3. Categories of Personal Information We May Collect

Identifiers

• Name
• Business email address
• Phone number
• Company name
• IP address and device identifiers
• Online identifiers

Customer Records Information (Cal. Civ. Code § 1798.80)

• Contact information
• Company and role information
• Information submitted through website forms
• Consumer contact and transaction information, where contained in Client platforms and records we are given access to

Commercial Information

• Services inquired about, considered, or purchased
• Engagement volume and service history
• Form and call interaction history

Internet or Network Activity

• Pages viewed
• Browser type and device type
• Referring URLs
• Interactions with forms
• Click activity
• Cookie and analytics data

Geolocation Information

• Approximate location derived from IP address
• City, state, or ZIP code you submit

We do not collect precise geolocation.

Audio or Call Information

• Call recordings where permitted by law
• Call date, time, and duration
• Call notes

Professional or Employment-Related Information

• Job title or role
• Company monthly volume and verticals handled
• Platforms and systems in use
• Employment application materials, where you apply for a position

Inferences

• Whether a company is likely to be a fit for our services
• Service interest and stage of evaluation

Sensitive Personal Information

Loyalty does not seek to collect sensitive personal information through its website.

Sensitive personal information — such as account credentials or financial account information — reaches us only inside Client platforms and records we are given access to, and only to perform managed operations services. It is used solely for purposes permitted under California Civil Code Section 1798.121(a): performing the services requested and permitted business purposes such as security, quality control, and legal compliance.

We do not use or disclose sensitive personal information to infer characteristics about a consumer. As a result, the right to limit under Section 1798.121 does not apply to our use of that information, but you may still submit a request and we will confirm our practices in writing.

4. Sources of Personal Information

• You directly
• Website forms
• Calls and email correspondence
• Cookies and analytics tools
• Client companies
• A Client's partners, buyers, and vendors on a campaign
• Call tracking, affiliate tracking, and lead distribution platforms we are given access to
• Service providers and technology vendors
• Fraud prevention and identity verification tools
• Public sources

5. Purposes for Collecting and Using Personal Information

• Operate and secure the website
• Respond to inquiries and intake form submissions
• Evaluate, establish, and manage Client engagements
• Perform managed operations services on behalf of Clients
• Communicate about engagements, campaigns, and status
• Invoice, bill, and collect for services
• Analyze website performance and improve content
• Detect and prevent fraud
• Maintain consent, opt-out, and suppression records
• Comply with legal and recordkeeping obligations
• Process privacy, opt-out, and CPRA requests
• Evaluate applicants for employment

6. Categories of Third Parties to Whom Information May Be Disclosed

• Service providers and contractors, including hosting, secure document transfer, CRM, email, analytics, call recording, payment processing, and data security vendors
• Client companies
• A Client's platforms, partners, buyers, and vendors on a campaign, at the Client's direction
• Legal, accounting, compliance, insurance, and audit advisors
• Government and regulatory authorities where required by law
• Parties involved in an actual or proposed corporate transaction

We do not disclose personal information to lead buyers, lead aggregators, data brokers, list vendors, or advertising networks for their own purposes.

7. Sale or Sharing of Personal Information

Loyalty does not sell personal information. Loyalty does not share personal information for cross-context behavioral advertising.

In the preceding twelve (12) months, we have not sold or shared personal information, and we have not sold or shared the personal information of consumers under 16 years of age.

Because we do not sell or share, there is nothing to opt out of. You may nonetheless submit a request at optout@alwayshereos.com or through the Legal Request Form, and we will confirm our practices to you in writing and record your preference.

Because there is no sale or sharing, opt-out preference signals such as Global Privacy Control have no sale or sharing activity to apply to.

8. Right to Limit Use of Sensitive Personal Information

As explained in Section 3, we do not use or disclose sensitive personal information for purposes beyond those permitted by California Civil Code Section 1798.121(a).

To submit a limitation request anyway, email privacy@alwayshereos.com or use the Legal Request Form.

9. Right to Know

California residents may request that we disclose the categories or specific pieces of personal information we have collected about them in the preceding 12 months, subject to verification and applicable exceptions.

To submit a request, email privacy@alwayshereos.com or use the Legal Request Form.

10. Right to Delete

California residents may request deletion of personal information collected from them, subject to legal exceptions.

We may retain information where permitted or required by law, including for:

• Legal and regulatory recordkeeping
• Fraud prevention and security
• Legal claims and dispute resolution
• Consent and suppression records needed to honor your opt-out
• Completing a transaction or request you initiated
• Internal uses reasonably aligned with your expectations
• Client consumer records we hold as a service provider, which are governed by the Client's instructions and applicable law

To submit a deletion request, email privacy@alwayshereos.com or use the Legal Request Form.

11. Right to Correct

California residents may request correction of inaccurate personal information we maintain about them.

To submit a correction request, email privacy@alwayshereos.com or use the Legal Request Form.

12. Right to Non-Discrimination

We will not discriminate against you for exercising privacy rights. We do not deny services, charge different prices, or provide a different level of service because you exercised a privacy right.

Certain services and website functionality depend on the information provided. If you ask us to delete or restrict information, some features or services may become unavailable.

13. Authorized Agents

California residents may use an authorized agent to submit a privacy request where permitted by law.

We may require written proof that the agent is authorized to act on your behalf, and may require you to verify your identity directly with us.

Authorized agent requests should be submitted to privacy@alwayshereos.com or through the Legal Request Form.

14. Verification of Requests

We may need to verify your identity before processing certain requests.

Verification typically involves matching two or three data points you provide against information we already maintain — for example, name, business email address, phone number, and company. For requests seeking specific pieces of personal information, we apply a higher standard of verification.

If we cannot verify a request, we may deny or limit it as permitted by law, and we will explain why.

15. Response Timing and Appeals

We will acknowledge requests within ten (10) business days and respond within forty-five (45) days, with one additional forty-five (45) day extension where permitted, in which case we will notify you of the extension.

If we deny a request in whole or in part, you may appeal by replying to our response with the subject line "Privacy Appeal" or by emailing privacy@alwayshereos.com.

16. Retention

We retain personal information for as long as reasonably necessary for the purposes described in the Privacy Policy and this page.

Retention periods vary based on the type of information, business need, legal obligations, consent records, fraud prevention, dispute resolution, and audit requirements. Client consumer records are retained under the applicable Client agreement and applicable law.

17. California "Shine the Light"

California Civil Code Section 1798.83 permits California residents with an established business relationship with us to request information about our disclosure of personal information to third parties for those third parties' direct marketing purposes.

We do not disclose personal information to third parties for their direct marketing purposes.

To submit a request, email privacy@alwayshereos.com with the subject line "California Shine the Light Request."

18. How to Exercise California Privacy Rights

Loyalty LTD
2206 Heavenly View Drive
Henderson, NV 89014

Phone: (505) 477-3990
Privacy requests: privacy@alwayshereos.com
Opt-out requests: optout@alwayshereos.com
General support: support@alwayshereos.com

Or use the Legal Request Form.

Related pages: Privacy Policy · Terms & Conditions · TCPA Consent · Opt Out Request