PRIVACY POLICY

Last Modified and Effective: June 15, 2020

This Privacy Policy explains and governs the manner in which Access Securepak® (“Securepak”, “we”, or “us”) collects, uses, maintains, and discloses information related to your use of the Access Securepak package program services. By using our services, you are agreeing to the policies and practices described in this Privacy Policy. This Privacy Policy may change from time to time. When changes are made, we will update the “Last Modified and Effective” date at the top of this Privacy Policy and, in some cases, we may provide additional notice as described below. Your continued use of our services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy for updates. If you do not consent to these policies and practices, please do not use the website or services.

This Policy describes:

• Personal Information We Collect; 
  
  
• How We Collect Your Personal Information;
  
  
• How We Use Your Personal Information;
  
  
• How We Share Your Personal Information With Third Parties;
  
  
• How We Protect Your Information;
  
  
• California Privacy Rights;
  
  
• Children’s Privacy;
  
  
• Changes to the Policy; 
  
  
• How to Update Your Information and Manage Communications; and
  
  
• Contact for More Information. 

Personal Information We Collect 

“Personal Information,” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household. It does not include anonymous or aggregated data that cannot be associated with an individual or household.  

We may collect, use, store, and transfer different kinds of Personal Information about you, which we have grouped together as follows:

• Identity Information such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
  
  
• Financial Information such as bank account and routing numbers, credit card number, debit card number, and payment details.
  
  
• Commercial Information such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  
  
• Internet or Other Similar Network Activity such as browsing history, search history, information on your interaction with our services, website, applications, or advertisements.
  
  
• Marketing and Communications Data such as marketing campaign data, click throughs, your preferences in receiving marketing from us and our third parties, your communication preferences, email communications, chat communications, and audio recordings. 

How We Collect Your Personal Information

We may collect Personal Information from a variety of sources and methods. This includes:

• Information You Voluntarily Provide

 You may give us your Personal Information by filling in forms, creating and using an account, or by corresponding with us by post, phone, text, email, chat, or otherwise. This includes Personal Information you provide when you:

• Submit a Contact Us form or write to us
  
  
• Use the chat feature on our website
  
  
• Call, email, text, or fax us
  
  
• Create an account
  
  
• Order goods and/or services
  
  
•  Information We Collect When You Use Our Services

Information Automatically Collected

When you visit our website, our web server automatically collects your Internet protocol (IP) address, which is a number assigned to your computer when you connect to the Internet. Our web server may also be able to identify things like the type of web browser, operating system you use, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  When you access and use our services from your mobile devices, we receive data from that mobile device. This may include your location data, IP address and device type. We can and will use IP addresses to identify a user when necessary to enforce compliance with the website Terms of Use.  

Use of Cookies

Cookies are small files that we or our service provider transfer to your computer’s hard drive through your web browser that enables us or our service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to analyze movement on the website, such as total visitors to the website and pages viewed, for fingerprinting, site security, and to make improvements to the website.  Moreover, our website’s partners may also use cookies in connection with the services and websites to which our website links. Most web browsers are initially set up to receive cookies. If you do not want to receive cookies, browsers usually have a “Help” or “Internet Tools” feature that will show you how to prevent your browser from accepting new cookies and how to delete cookies from your computer. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. For more information about cookies, please visit http://www.allaboutcookies.org. 

We use third party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website.  Based on this information, Google Analytics compiles aggregated data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on Google Analytics, visit Google’s Privacy and Terms. 

•Information We Collect From Third Parties

We may collect Personal Information from other sources including our trusted partnerships with service providers. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used, and disclosed by these third parties.

How We Use Your Personal Information

Securepak uses information we collect about you or that you provide to us, including Personal Information, for the following business purposes:

• To provide you with our products and services and to operate our business.
  
  
• To facilitate your purchase and the shipment of items to the recipients you’ve selected.
  
  
• To provide detailed information on the status of your order.
  
  
• To contact you concerning your order, if necessary.
  
  
• To communicate with you and answer specific questions related to goods and services offered through our programs.
  
  
• To learn more about how visitors use the website (data analysis) and measure areas of interest for the purpose of improving the website, products, and services.
  
  
• For our internal marketing purposes, which include, but are not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you.
  
  
• To deliver customized content and advertising to you.
  
  
• To process payments for the goods and services.
  
  
• Enhancing the safety and security of the website, preventing potentially fraudulent, prohibited, or illegal activities, and enforcing our User Agreement.
  
  
• Accounting, auditing, and financial reporting.
  
  
• Resolving disputes and troubleshooting problems. 
  
  
• Responding to requests by government entities, in connection with an investigation of suspected or actual unlawful activity, and other duties as required by law. 
  
  
• For any other purposes disclosed at the time you provide your information or as otherwise set forth in this Policy.

How We Share Your Personal Information With Third Parties

We share information related to your account and purchase(s) in the following circumstances:

• Correctional Facilities.  We share Personal Information with our correctional facility customers in order to securely deliver the packages that you purchase for residents in the care and custody of these agencies.  
  
  
• Service Providers.  We contract with third parties to provide services for the Securepak programs. Your Personal Information may be disclosed to these third party service providers in order for us to provide you with our services. Third party services include, but are not limited to,  (1) processing your transaction (including your payment) and preventing fraud, (2) delivering your order, (3) supporting your use of our website, (4) providing operational, marketing or advertising support, and/or (5) other purposes to support our business, such as analyzing data. Service Providers are permitted to use your information only on our behalf. 
  
  
• Legal Process.  Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation, or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
  
  
• Internal Third Parties. We may share Personal Information with our direct and indirect parent companies Keefe Group, LLC and TKC Holdings, Inc., respectively, and other companies owned by or controlled by TKC Holdings, Inc., who may use the Personal Information for the purposes described herein.
  
  
• Business Transactions.  Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Privacy Policy.

How We Protect Your Information

We endeavor to incorporate physical, technical, and administrative safeguards and policy methods to protect your personally identifiable information. It is also important that you take steps to maintain the secrecy of your account information and secure access to your computer. Always be sure to log out of your account when using a shared or public computer. Please be aware that no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Therefore, we cannot guarantee its absolute security. It may be possible for third parties to intercept or access transmissions or private communications unlawfully.  Any such transmission is done at your own risk.

California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with certain additional privacy rights related to the Personal Information Securepak collects about you. Please see below to learn more about your rights under the CCPA. 

• Request to Know 

You may request no more than twice in any 12-month period and, subject to verification of your identity and certain exemptions, we will provide:

• The categories of Personal Information we collected about you.
  
  
• The categories of sources from which the Personal Information is collected.
  
  
• The categories of Personal Information sold or disclosed to a third party.
  
  
• The categories of third parties to whom such Personal Information is sold or disclosed.
  
  
• Our business or commercial purpose for collecting or selling Personal Information.
  
  
• The specific pieces of Personal Information we collected about you.
  
  
  
• Request to Delete 

You may request that we delete Personal Information we have collected from you, subject to verification of your identity and the exceptions provided by law.

• Request Not to Sell Personal Information 

You also have the right to opt-out from having your Personal Information sold to third parties.  However, this right does not apply here because Securepak does not sell Personal Information and we have not done so for the 12-month period preceding the last revision date of this CCPA Privacy Policy. Securepak has no actual knowledge of any sales of Personal Information of minors under 16 years of age. 

• Exercising Your CCPA Rights 

If you are a California resident and would like to submit a CCPA request, you or your authorized agent may:

• Contact us by phone at 1-877-777-9154, or
  
  
• Initiate a request by completing our online form which can be located here:  Exercise Your Rights
  Powered byOneTrust

Please note that these rights apply only to select California consumers and currently exclude job applicants, employees, and business contacts. Only you, or an agent you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. To authorize another person to make a verifiable request on your behalf, you must provide that person with written permission clearly describing their authority to make a request on your behalf. That agent must also be able to verify their identity with us and provide us with their authority to act on your behalf. An individual to whom you have provided Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code may also make a request on your behalf.

• What Are My CCPA Non-Discrimination Rights? 

We will not discriminate against you for exercising any of your CCPA rights, which means we will not:

• Deny you goods or services.
  
  
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  
  
• Provide you a different level or quality of goods or services.
  
  
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  
  
  
• How Will You Verify My Identity If I Make a CCPA Request? 

The verifiable consumer request must:

• Include your full legal name, email, billing address, and resident/inmate ID.*  
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

*Because orders are placed and tracked by the resident/inmate ID, to locate your information we need you to provide the resident/inmate ID(s) associated with the inmate(s)/resident(s) for whom you made purchases. 

We will use this information to verify your identity using reasonable methods in order to process your rights request. These methods may include matching information you provided to us with information already maintained by us or through the use of a third party identify verification service. Depending on the nature of the request, we may require additional verification actions be taken, including but not limited to providing a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.  

We will use the information you provide to verify your identity and to respond to your rights request and for no other purpose.

We cannot respond to your request or provide you with Personal Information if we are not able to verify your identity or authority to make the request or confirm the Personal Information relates to you.

You are not required to have an account with us to make a verifiable request.

•Other California Privacy Rights.  

California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes.  We do not share information we collect about you with third parties for those third parties’ direct marketing purposes.

Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including ours, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

Children’s Privacy 

This website is not directed to, nor do we knowingly collect Personal Information from, children under the age of 13. Children wishing to make purchases through our services must do so with the involvement of a parent or guardian.

Changes to the Policy

We may update the Privacy Policy as needed to reflect changes to our business and services.  We will post changes to the Privacy Policy on our website, with the effective date of the revisions prominently noted next to the “Last Modified and Effective” date. We ask that you review the Privacy Policy frequently to see changes made to the policy. If we make a material change to the Privacy Policy, we will provide appropriate notice (like adding a statement to our homepage or sending you a notification through email).

How to Update Your Information and Manage Communications

If you want to modify your registration information, please login to your account and make the necessary changes. At the time of registration, you may be given a choice whether you want to receive information about new features, offers or other notices related to Securepak and its services.  When you register, you may opt to not receive these communications by clicking a box that affirmatively declines to receive such information. You also have the option to opt out at a later date by following the instructions in the communication that you receive from us.

Contact for More Information

We welcome your questions and comments regarding our Privacy Policy. Please direct communications to our Customer Service Department at customerservice@securepak.net or 1-800-546-6283. You may also correspond in writing to Access Securepak, Attn: Customer Service, 10880 Lin Page Place, St. Louis, MO 63132.