Privacy Policy
This privacy policy (the
“Privacy
Policy“) explains how Go
Referral Agent LLC (“Go Referral Agent
LLC,” “we,” or “us”) collects, uses, shares, and protects
information of the users of Go Referral Agent LLC's websites and mobile or other software applications
where this
Privacy Policy is posted (collectively, the “Website”). This Privacy Policy is designed to fulfill our
legal obligations in the places where we operate -- including, without limitation and where
applicable, the California Consumer Privacy Act (CCPA).
Please note that this Privacy Policy
only applies to the Website, and not to websites, applications, operating systems, or other platforms
of third parties (collectively, "Third-Party Platforms"), even if such Third-Party Platforms are
linked to or accessible from the Website. Each Third-Party Platform will have its own data collection
and usage practices, and may use their own cookies, web beacons, and other technology to collect
information from you. Go Referral Agent LLC is not responsible for the content or practices of any
Third-Party Platforms and, if you choose to visit or use them, you do so at your own risk.
1. Who controls your information?
Any information or other data provided to or gathered by Go Referral Agent LLC is
controlled by:
Go Referral Agent LLC
957 N Pennsylvania Ave
Winter Park, FL 32789
2. What types of information do we collect?
"Information," as
used in this Privacy Policy, means personal information that identifies, relates to, describes, is
capable of being associated with, or could reasonably be linked, directly or indirectly, with a
particular user or household. Examples include a user’s name, mailing address, email address, or IP
address.
Go Referral Agent LLC collects and/or has collected over the past twelve (12)
months the following categories of information about you and other users of the Website:
• Information You Provide to Us. We collect
information from you when you voluntarily provide it to us over the Website, including as part of
filling out a form for further information. Such information may include your name, email address,
telephone number(s), street address, city, state, signature, social security number, driver’s license
or state identification card number, debt or credit history, and whether you own or rent your
home.
• Content You Make Public. Go Referral Agent LLC
collects information from you that you voluntarily upload to the Website for public display ("Public
Information"), such as when you post a review. Once you submit Public Information, neither you nor Go
Referral Agent LLC are able to control how it may be copied, shared, or used by third parties, even if
you and/or Go Referral Agent LLC later delete such Public Information. Accordingly, you should
carefully consider what personal information you choose to include within your Public
Information.
• Device/Internet Connection Information. When
you use the Website, we automatically gather information made available by your web browser (such as
Microsoft Edge or Google Chrome), internet service provider (such as Comcast or Cox), and device (such
as your computer, phone, tablet, or fitness tracker), depending on your settings for each. For
example, we may collect your IP address, information about the operating system or type of device you
use, the device ID associated with your device, the date and time you access the Website, and your log
in attempts.
• Internet Activity Information. As explained
below in Sections 3 and 4 regarding Personalized Ads, we may also collect information about your
browsing history, search history, and information regarding your interaction with a particular
website, application, or advertisement, including the Website. We may collect information regarding
the websites, application, or advertisement you visited immediately before and after your use of the
Website.
• Geolocation Information. We may collect
information about where you are located, both generally and at the time you access the Website. For
example, we may collect your mailing address or ascertain your approximate location from your IP
address.
• Protected Class Information. Due to the
specific nature of Go Referral Agent LLC's services, you may be asked to provide information about
your gender, age, marital or family status, or citizenship.
• Biometric Information. We may collect
information regarding your physiological, biological or behavioral characteristics, including injuries
and other medical problems, and your medical history.
• Employment Information. We may collect
information about your employment, employment history, or salary.
• Health Insurance Information. We may collect
information about your health insurance, including whether you are receiving disability benefits; your
insurance policy number or subscriber identification number, or any unique identifier assigned to you
by an insurance company.
• Other Information. From time to time, we may
collect other information from you, such as when you make a claim for a prize pursuant to a contest or
other promotion run on the Website, when you request assistance through our customer service
department, or when you voluntarily subscribe to promotions, reminders, or newsletters. You will
always be asked for your consent in advance of providing such other information, and we will not
collect it without your permission.
3. How and when do we collect information about you?
Go Referral Agent LLC gathers information about you through the following sources
and means:
• When you enter or upload information to the Website. Go Referral Agent LLC collects information you provide to us, content you make public,
geolocation information, protected class information, biometric information, employment information,
and health insurance information when you enter such information on a form on the Website (including
during registration), sign up for newsletters or promotional material, enter contests, and otherwise
interact with the Website.
• When you communicate with us. Go Referral Agent
LLC may also collect information you provide to us, content you make public, geolocation information,
protected class information, biometric information, employment information, and health insurance
information from you outside of the Website, such as when you contact our customer service department,
email us (including any response to an email communication from Go Referral Agent LLC), or communicate
with Go Referral Agent LLC via social media, such as by posting on a page hosted by Go Referral Agent
LLC or tagging Go Referral Agent LLC in your own post. The information collected off the Website may
be combined with that collected through the Website—for example, if you fill out a form on the Website
and later call our customer service, the information from your call may be linked with your
form.
• When you communicate with us. Go Referral Agent
LLC may also collect information you provide to us, content you make public, geolocation information,
protected class information, biometric information, employment information, and health insurance
information from you outside of the Website, such as when you contact our customer service department,
email us (including any response to an email communication from Go Referral Agent LLC), or communicate
with Go Referral Agent LLC via social media, such as by posting on a page hosted by Go Referral Agent
LLC or tagging Go Referral Agent LLC in your own post. The information collected off the Website may
be combined with that collected through the Website—for example, if you fill out a form on the Website
and later call our customer service, the information from your call may be linked with your
form.
• Through Cookies, tracking tools, and other automated technologies.
When you use any website, certain information can be automatically collected
through technological means. When you access the Website, your web browser automatically sends us
device and internet connection information and certain internet activity information as described in
Section 2.
Go Referral Agent LLC also uses Cookies and web beacon technology to gather device
and internet connection information, internet activity information, geolocation information, and
biometric information. "Cookies" are files that are placed on your computer or other device by
websites you visit. The primary purpose of a Cookie is to identify you as a unique user of the
Website. Go Referral Agent LLC uses the following types of Cookies, some of which are placed by Third
Parties, to customize your Internet experience, keep you logged into websites, remember your search
terms, and advertise products or services to you:
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Type of Cookie
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Purpose of Cookie
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Necessary
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Necessary Cookies are essential in order for the Website to
display and perform properly. Necessary Cookies are used to identify you,
prevent security risks, and to allow you to perform account-related
functions.
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Preferences
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Preferences Cookies are used to store preferences set by you
and each user for their account, such as your language preferences.
Preferences Cookies improve your experience using the Website.
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Analytics and Performance
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Analytics and Performance Cookies collect information on how
you and other users interact with the Website. Often, this information is
aggregated, as discussed in Section 4, and is used to improve the
Website.
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Advertising
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We may also use Cookies and web beacons, including those
placed by Third Parties such as Google and Facebook, to deliver Personalized
Ads that may be of interest to you. We may also use a web beacon in email
messages sent to track your response. Cookies and web beacons also help us and
our Third-Party advertising partners ensure you do not see the same
advertisements over and over and to identify block unwanted ads. We also use
these tracking tools to better understand your behaviors and browsing
activities, and to generate, as discussed in Section 2.
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You can change your Cookie settings in your Internet browser (e.g., Chrome, Edge,
Firefox). If you disable Cookies, some of the features of the Website may not function
correctly. For more information, see https://www.allaboutcookies.org/.
• From Third Parties. Like many websites, Go
Referral Agent LLC uses Google services and Cookies to improve the Website. As such, when you
use the Website, your personal information may be shared with Google, and shared by Google with Go
Referral Agent LLC. You can learn more about how Google uses Cookies, and how to manage your Cookie
preferences in your Internet browser by visiting the Google Cookie Policy.
As explained above, Go Referral Agent LLC also uses pixels, tags, and Cookies set
by our Third Party advertising partners to track your online behavior and provide Personalized Ads to
you.
Remember, you can change your Cookie settings in your Internet browser (e.g.,
Chrome, Edge, Firefox). For more information, see https://www.allaboutcookies.org/.
You can better learn about such Third-Party data collection and advertising
practices, including how to revoke your consent to Personalized Ads, at the following websites:
4. How do we use your information?
Go Referral Agent LLC may use the information we've gathered from you or your
device, including through Cookies and Third Parties, for the following purposes:
• Business Purposes. When Go Referral Agent LLC
uses your information for a "Business Purpose," it means such use is reasonably necessary and
proportionate to achieve an operational purpose of Go Referral Agent LLC. The following are the
Business Purposes for which we may use your information:
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Business Purpose
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Types of Information
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For Security. Go Referral
Agent LLC uses the information we collect from you and other users to detect
security incidents, protect against malicious, deceptive, fraudulent, or
illegal activity, and to identify and prosecute those responsible for that
activity.
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Information you provide to us; Device/Internet Connection
Information; Internet Activity Information; Geolocation Information
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To Improve our Services. Go
Referral Agent LLC uses the information we collect from you and other users to
improve our information offerings and services. For example, we may consider
analytics, demographics, and user feedback collected via the Website in
determining whether there is sufficient demand for a new service.
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Information you provide to us; Content you make public;
Device/Internet Connection Information; Internet Activity Information;
Geolocation Information; Protected Class Information; Biometric Information;
Employment Information; Health Insurance Information
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To Improve the Website. Go
Referral Agent LLC uses the information we collect from you and other users to
provide and improve the Website. We use information to debug and
identify and repair errors that impair existing intended functionality of the
Website. As explained above, we use Cookies, including those placed by Third
Parties, to gather statistical information that helps us understand how you
and other users engage with the Website and improve its performance via
technological development.
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Information you provide to us; Content you make public;
Device/Internet Connection Information; Internet Activity Information;
Geolocation Information; Protected Class Information; Biometric Information;
Employment Information; Health Insurance Information
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To Personalize Your User Experience. We use information gathered from Cookies to authenticate your
logins, determine whether you are logged in or not, to allow you to set
personal preferences when using the Website, and to make it so you
don’t have to
reenter the same information when you visit the Website several times within a
short timeframe.
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Information you provide to us; Device/Internet Connection
Information; Internet Activity Information; Geolocation Information; Protected
Class Information; Biometric Information; Employment Information; Health
Insurance Information
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To Communicate with You. We
use your information to personalize communication with you, and to respond to
your requests regarding your purchases and information on our products and
services. We also use your information to notify you of updates to the Terms
or this Privacy Policy.
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Information you provide to us; Content you make public;
Device/Internet Connection Information; Internet Activity Information;
Geolocation Information; Protected Class Information; Biometric Information;
Employment Information; Health Insurance Information
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• Commercial Purposes. When Go Referral Agent LLC
uses your information for a "Commercial Purpose," it means such use is intended to advance Go Referral
Agent LLC's business interests, such as by inducing you to buy one of our products or services. The
following are the Commercial Purposes for which we may use your information:
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To Advertise to You.
We may use information gathered through Cookies and
web beacons, including those placed by Third Parties, to deliver ads to you
via the Website, and after you’ve left the Website, including advertising specific to your
personal interests. The purpose of this practice, which is sometimes called
“Personalized
Ads,” “retargeting,” or “remarketing” is to deliver content and advertising that is of interest to
you, and to avoid displaying irrelevant advertising to you.
You can better learn about
such Third-Party data collection and advertising practices, including how to
revoke your consent to Personalized Ads, at the following websites:
www.youronlinechoices.com/uk/your-ad-choices
www.networkadvertising.org/choices
www.aboutads.info/choices
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Information you provide to us; Content you make public;
Device/Internet Connection Information; Internet Activity Information;
Geolocation Information; Protected Class Information; Biometric Information;
Employment Information; Health Insurance Information
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• Scope and Legal Bases for Use. Go Referral
Agent LLC only processes your information to the extent that is necessary to accomplish the
above-stated Business and Commercial Purposes, which serves as our legitimate interest.
5. How do we share your information?
Go Referral Agent LLC may share your information with Third Parties for the
following
purposes:
• Business Purposes. When Go Referral Agent LLC
shares your information for a Business Purpose, it means such use is reasonably necessary and
proportionate to achieve an operational purpose of Go Referral Agent LLC. The following are the
Business Purposes for which we may share your information:
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Third Parties
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Business Purpose
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Types of Information
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Service Providers. These
Third Parties provide services to Go Referral Agent LLC that allow Go Referral
Agent LLC to operate the Website, provide services to customers, communicate
with customers, and so forth. Examples include email fulfillment providers,
customer management services, and so forth.
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For Security; to Improve Our Services; to Improve the
Website; and to Personalize Your User Experience. See Section 4 for more
information on these Business Purposes.
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Information you provide to us; Content you make public;
Device/Internet Connection Information; Internet Activity Information;
Geolocation Information; Protected Class Information; Biometric Information;
Employment Information; Health Insurance Information
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Our Affiliated Entities. Affiliated entities are different than Third Parties in that
they are businesses that are directly related to us and have common ownership
with us. We may disclose, transfer, and sell your information to our
affiliated entities, in which event, your information shall be treated by the
affiliated companies in accordance with this Privacy Policy. Should Kiito be
subject to an acquisition, merger, sale or other change of control or business
entity status, we reserve the right to transfer or assign your information as
part of that acquisition, merger or sale.
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For Security; To Fulfill Your Orders; to Improve Our Products
and Services; to Improve the Website, to Personalize Your User Experience; and
to Create Aggregate Information. See Section 4 for more information on
these Business Purposes.
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Information you provide to us; Content you make public;
Device/Internet Connection Information; Internet Activity Information;
Geolocation Information; Protected Class Information; Biometric Information;
Employment Information; Health Insurance Information
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Government Officials and Private Parties Pursuant to
Valid Legal Process. We may disclose your
information in response to subpoenas, court orders, and other legal processes.
In very rare circumstances, we may disclose personal information when we
believe it is necessary in order to prevent illegal, fraudulent, or injurious
actions that may cause harm to individuals.
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To comply with Go Referral Agent LLC's legal obligations and to
prevent illegal, fraudulent, or injurious actions that may cause harm to
individuals.
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Information you provide to us; Content you make public;
Device/Internet Connection Information; Internet Activity Information;
Geolocation Information; Protected Class Information; Biometric Information;
Employment Information; Health Insurance Information
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• Commercial Purposes. When Go Referral Agent LLC
shares your
information for a “Commercial Purpose,” it means such disclosure is intended to advance Go Referral
Agent LLC's business interests, such as by advertising our products or services. The following are the
Commercial Purposes for which we may share your information with Third Parties:
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Advertising Partners
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Advertising Partners
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Advertising Partners
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The Website serves as a portal where users like you can
seek information and connections on a particular topic, such as debt
management, bankruptcy, SSDI and legal representation. Thus, in order to serve
the Website's
purpose, we may disclose your personal information as needed to our
Third-Party advertising partners, including law firms, SSDI advocates, and
other advertising companies whose clients may be a good match for you.
As explained more fully in Section 6, Go Referral Agent LLC is paid for
passing on consumer leads to its clients, which leads include elements of your
personal information.
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To Advertise to You; to earn revenue through the provision
of consumer leads to our clients. See Section 4 for more information on these
Commercial Purposes.
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Information you provide to us; Content you make public;
Device/Internet Connection Information; Internet Activity Information;
Geolocation Information; Protected Class Information; Biometric Information;
Employment Information; Health Insurance Information
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6. Do we sell your information to others?
Yes. Please take notice that your information may
be sold to a Third Party. Go Referral Agent LLC generates revenue by
connecting our Third-Party partners with consumers who have expressed interest in their products and
services. In doing so, Go Referral Agent LLC passes on the personal information of the interested
consumers.
This type of business is called “lead generation,” and, under some laws and
regulations, could be considered the “sale” of personal information. The categories of information
that may be sold are:
• Information you provide to us
• Device/Internet Connection Information
• Internet Activity Information
• Geolocation Information
• Protected Class Information
• Biometric Information
• Employment Information
• Health Insurance Information
RIGHT TO OPT-OUT OF SALE OF PERSONAL INFORMATION
You have the right, at any time, to direct Go Referral Agent LLC not to
sell your information. You may do so by filling out the Do Not Sell My Personal Information form on
the Website.
7. How do we protect your information?
Go Referral Agent LLC, and the Third-Party vendors we use to store your
information, employ technical, administrative, and physical security measures (such as SSL encryption
and HTTPS protocol) that are designed to protect against the loss, misuse, and alteration of the
information under our control. We regularly review our security procedures to consider appropriate new
technology and methods.
However, no system can be completely secure. Therefore, although we take
steps to secure your information, we cannot promise, and you should not expect, that your personal and
commercial information, or other communications, will always remain secure.
The safety and security of your information also depends on you. Never share your
password with anyone else and notify us as soon as possible if you believe your account security has
been breached.
8. How long do we keep your information?
Go Referral Agent LLC will retain your information for the length of time necessary
to fulfill the Business Purposes and Commercial Purposes outlined in this Privacy Policy, unless a
longer retention period is required or permitted by law or valid court order. If you request deletion
of your information pursuant to Section 10, your request will be processed according to the timeframes
indicated therein and/or pursuant to any applicable legislation.
9. Do we transfer your information to a different country?
If you are visiting the Website from a location outside of the United States, your
connection will be through and to servers located in the United States, and all information you
provide will be processed and securely maintained in our web servers and internal systems located
within the United States. By using the Website, you authorize and
specifically consent to the transfer of personal data to the United States and its storage and use as specified above when you provide such information to
us.
10. What are your rights when it comes to accessing, correcting, or deleting
your information, and how can you exercise them?
You may access all information we’ve collected and retained about you for purposes
of correcting, amending, downloading, or deleting such information. Access can be obtained by logging
into your account, filling out a Privacy Request, or
contacting us at [email protected].
To protect your privacy and security, we may take reasonable steps to help
verify your identity before granting access, making corrections, providing you with information, or
deleting information.
• Access and correction
The easiest way to access and correct the personal information we have collected
about you is to log into your account. In the alternative, you may fill out a Privacy Request, or contact us at [email protected].
• Right to Request Disclosure
You have the right to request that Go Referral Agent LLC disclose the following to
you:
• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is
collected;
• The business or commercial purpose for collecting or selling personal
information;
• The categories of third parties with whom we share personal information;
and
• The specific pieces of personal information we have collected about you.
To request such a disclosure, please fill out a Privacy Request, or contact us at [email protected].
• Right to Request Deletion
You have the right to request that Go Referral Agent LLC delete any personal
information about the you which we have collected from you. To make such a request, please fill out a
Privacy Request, or contact us at [email protected].
• California Shine the Light Disclosure
Under California’s “Shine the Light” law, California residents who provide personal
information to the Website may request certain information regarding our disclosure of personal
information to third parties for their direct marketing purposes. To make such a request, please fill
out a Privacy Request, or contact us at [email protected].
• Cal. Bus. & Prof. Code § 22581 Disclosure
If you are a California resident under the age of 18, and a registered user of any
Website where this Privacy Policy is posted, California Business and Professions Code Section 22581
permits you to request and obtain removal of content or information you have publicly posted. To make
such a request, please fill out a Privacy Request, or
contact us at [email protected] with a detailed
description of the specific content or information. Please be aware that such a request does not
ensure complete or comprehensive removal of the content or information you have posted and that there
may be circumstances in which the law does not require or allow removal even if requested.
• RIGHT TO OPT-OUT OF SALE OF PERSONAL INFORMATION
You have the right, at any time, to direct Go Referral Agent LLC not to sell your
information. You may do so by filling out the Do Not Sell My
Personal Information form on the Website.
11. How do we protect the privacy of children?
• No Users Under 13
Go Referral Agent LLC will never knowingly collect any personal information about
children under the age of 13. If we obtain actual knowledge that we have collected personal
information about a child under the age of 13, that information will be immediately deleted from our
database. Because we do not collect such information, we have no such information to use or to
disclose to Third Parties. We have designed this policy in order to comply with the Children's Online
Privacy Protection Act (COPPA).
• Right to Opt In For Users 13 to 16
Go Referral Agent LLC will never sell the personal information of users if we have
actual knowledge that the user is less than 16 years of age, unless (in the case of consumers between
13 and 16 years of age) the user has affirmatively authorized the sale of their personal
information.
12. SMS Messaging Practices
• Third-Party Sharing
We do not sell, rent, or share your SMS opt-in information with third parties for
their marketing purposes.
• Message Frequency and Fees
You may receive up to 3 SMS messages per week. Standard message and data rates may
apply as determined by your carrier.
• Opt-Out and Support
You may opt-out of SMS messages at any time by replying STOP. For assistance, reply
HELP or contact us at [email protected].
13. How can you receive and opt-out from marketing communications?
By providing your email address to Go Referral Agent LLC through the Website or an
email initiated by you, you consent to receive emails from us,
including information concerning your account and advertising messages.
Depending upon your location, we may obtain additional consent from you via a checkbox disclosure or
an email requesting confirmation before you can receive such information.
Providing consent to promotional emails is NOT a condition of purchasing any goods
or services from Go Referral Agent LLC. You can unsubscribe to advertising emails at any time by
clicking the unsubscribe link within the email, or by contacting us at [email protected]. Please note that, even if you
unsubscribe from advertising emails, we will still send you any necessary, non-promotional emails
about your purchase, account, or updates to our Privacy Policy and Terms of Service.
14. Do we respond to Do Not Track (DNT) Signals?
DNT is a feature offered by some browsers which, when enabled, sends a signal to
websites to request that your browsing is not tracked. Go Referral Agent LLC does not currently
respond to DNT requests.
15. How will you know when we change the Privacy Policy?
Each time you use the Website, the then-current version of this Privacy Policy will
apply. Although most changes are likely to be minor, we reserve the right to modify this Privacy
Policy by posting such modification on this page; however, if changes are significant, we may provide
a more prominent notice or email you. Depending upon your location, we may obtain additional consent
from you via a checkbox disclosure or an email requesting consent before you can continue to use the
Website.
Unless we receive your express consent, any revised Privacy Policy will apply only
to information collected after the effective date of such revised Privacy Policy, and not to
information collected under any earlier version.
This Privacy Policy was last updated February 26, 2020.
16. How can you contact us regarding this Privacy Policy?
You can contact us via email at [email protected]. In this case, your information
transmitted by email will be stored. If needed, your information will be relayed to our Third Party
partners to for the sole purpose of processing any request by you in the communication.
