Bristol CPM Inc.,O/A 123Pro and its affiliates, parents, and subsidiaries ("123Pro" or "we", "us", or the "Company") take your privacy seriously. This Privacy Policy explains how we collect, use, share, and protect your Personal Information. If you do not want us to handle your Personal Information in this manner, please do not use the 123Pro Platform. Personal Information is information that relates to you as an individually identifiable person, such as your name, e-mail address, and mobile number. We assume that usage of the 123Pro platform confirms that you have read and understood this privacy policy and therefore agree to its contents.

This Privacy Policy explains: 

• What information we collect

• How we use that information

• How we may share that information

• How we protect your information

• Our Privacy Shield Privacy Policy and information specific to non-US users

• How to contact us with questions about this Privacy Policy

This Privacy Policy applies only to (a) information that we collect on the websites 123Pro.com,  (the "Site") and (b) through the 123Pro mobile applications, including the mobile application for service requesters and the mobile application for service professionals (the "App") (collectively the "123Pro Platform"). 

I. INFORMATION WE COLLECT 

a) Personal Information You Give Us 

We collect information that you voluntarily share with us through the 123Pro Platform.

If you are using the 123Pro Platform to request professional services, or contact 123Pro or its third-party service providers, you may give us:

• Contact information, such as your name, physical address, telephone number, and email address

• Information about your home, such as the number of bedrooms, the types of appliances, zip code or postal code where your home is located and your instructions for servicing your home

• Billing information, such as credit or debit card number, expiration date & security code and/or information regarding your PayPal, Google Wallet or other digital payment accounts and the 123Pro Platform itself

• Ratings and reviews of the service professionals you engage through the 123Pro Platform

If you participate on the 123Pro Platform as a service professional, or contact 123PRo or its third-party service providers, you may give us:

• Contact information, such as your name, email address, mailing address, and phone number

• Log-in information, including your 123Pro Platform username and password

• Application information, if requesting consideration to participate as a service professional through the 123Pro Platform, such as your experience, skills, eligibility to work, and availability

• Photographs of yourself

• Social Security  or Social Insurance number, if you are a service professional who wishes to participate on the 123Pro Platform in the United States or Canada and you are selected for a background check

If you apply on the 123Pro Platform for employment with 123PRo, you may give us:

• Contact information, including your name, email address, telephone number, and mailing address

• Resume and LinkedIn profile

More about payment card information: 

Although users can submit credit card or other payment card information to pay for a service through the 123Pro Platform, 123PRo does not receive this information itself. Payment card information is transmitted directly to a third-party payment card processor, (Payment Gateway Provider), through an Internet connection secured by industry-standard Transport Layer Security (TLS) encryption technology. These payment gateway providers then communicate to 123Pro whether your payment has cleared, but does not provide payment card information to 123Pro. 

Surveys 

You may, at your choice, complete surveys on the 123Pro Platform or distributed by 123Pro about, for example, your level of satisfaction with the 123Pro Platform, your engagement with the 123Pro Platform, and your awareness of 123Pro Platform features. In some cases, we may link the information you provide in the survey with Personal Information in your 123Pro account, such as your name or email address. When linked to Personal Information, your survey information becomes Personal Information too.

b) Information We Collect Through Technology 

We collect information through technology to enhance our ability to serve you. When you access and use the 123Pro Platform, or contact 123Pro or its third-party service providers, 123Pro and, in some cases, our third-party service providers collect information about you or how you interact with the 123Pro Platform. We describe below a few of the methods we use to collect information through technology.

When you visit the 123Pro Platform, we collect your Internet Protocol (IP) address. An IP address is often associated with the portal you used to enter the Internet, like your Internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. However, we may link the last IP address you used to access the 123Pro Platform to Personal Information you provide us. Where, according to local law, IP addresses and the like are considered Personal Information, we treat them as such.

We may also collect a unique identifier for your computer, mobile device, or other device used to access the 123Pro Platform ("Device Identifier"). A Device Identifier is a number that is automatically assigned to the device you used to access the 123Pro Platform. We may link the Device Identifier to other information about your visit, such as what pages you viewed, and to Personal Information you provide us, such as your name. 

Do We Use Cookies? 

Yes we do, more information can be found below regarding this subject.

Web Beacons 

We may include small graphic images or other web programming code, called web beacons (also known as "pixel tags", "web bugs" or "clear GIFs"), in our web and mobile pages and messages. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Web users. In contrast to cookies, which are stored in a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons help us better manage content on the 123Pro Platform by informing us what content is effective, monitoring how users navigate the 123Pro Platform, counting users of the 123Pro Platform, and counting how many e-mails sent by us were actually opened.

Your 'Do Not Track' Browser Setting 

We do not support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser's settings to let the websites you visit know that you do not want the websites collecting your Personal Information.

We do track your online activities over time and across third-party websites or online services. For example, we use web beacons to help us determine what links or advertisers brought you to our Site. We also use third-party service providers to display advertisements to you on other websites based on your activities while on the 123Pro Platform.

c) Information Collected by Mobile Applications 

When you use the App, the App may automatically collect and store some or all of the following information from your mobile device ("Mobile Device Information"), including, but not limited to: 

• The type of Internet browsers you use with the App.

• Your preferred country site.

• Your mobile operating system.

• Your phone number or other identifiers assigned to your mobile device, including: The IP address of your mobile device, The manufacturer and model of your mobile device

We may also collect information about how you use the App, such as the amount of time you spend using the App, how many times you use a specific feature of the App over a given time period, how often you use the App, and actions you take in the App. In addition, we may gather information about the website from which you downloaded the App to help us determine what App download site is most effective (collectively "App Usage Information"). 

We may link your Mobile Device Information and App Usage Information to Personal Information you have provided us, in which case we will treat the combined information as Personal Information.

Location Tracking 

If you are a service professional using 123Pro’s mobile application for supplier professionals (the "Pro Portal"), we may collect your geographic location by using Global Positioning System (GPS) information sent to us from the Pro Portal. For more information on when this information is collected, how we use it, and with whom it is shared, services professionals should refer to the Supplier Professional Agreement available on the service professional portal. 

We only collect location information about service professionals who have been accepted to participate on the 123Pro Platform and not about service requesters or about supplier professionals applying to participate in the 123Pro Platform.

d) Information You Provide About A Third Party 

If you choose to use our referral service to tell a friend about the 123Pro Platform, we may collect your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the 123Pro Platform. We store this information only to send this one-time email and to track the success of our referral program. We do not use this information for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you refer a friend, your e-mail address may be included in the message sent to your friend.

If you are using the 123Pro Platform to request professional services, you may provide us ratings and reviews of the service professionals you engage through the 123Pro Platform.

e) Information Third Parties Provide About You 

Conversion Tracking: We may supplement the information we collect about you through the 123Pro Platform with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, websites on which we have placed advertisements, such as Google, may tell us which ads about 123Pro you clicked. This is often called "conversion tracking."

Background Checks: In addition, third parties we contract to conduct background checks on service professionals, may share the results of the background check with 123Pro.

Recording Phone Calls: Selected third-parties, including those who may assist in providing customer service support, may monitor and/or record the contents of phone calls made through or in relation to the 123Pro Platform, after notice to you and with your consent.

Social Networking Sites: If you login to the 123Pro Platform through a social networking site, such as Facebook, we may collect your Facebook authentication token and account identification number and use that information to provide you with access to your account on the 123Pro Platform.

Ratings and Reviews: If you are using the 123Pro Platform as a service professional, we may receive information about you in the form of ratings and reviews from requesters who engaged your professional services through the 123Pro Platform.

Photographs of Completed Services: If you are using the 123PRo Platform to request services, service professionals booked through the 123Pro Platform may take photographs of completed services and provide them to 123Pro.

Message Interception: If you call or text (SMS) message a service professional or service requester using the telephone number provided by 123Pro, 123Pro uses a third party to mask your telephone number. During this process, 123Pro and a third party we contract will receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages.

If you send a message to a service professional or service requester in the App, 123Pro uses a third party to process the communications. During this process, 123Pro and the third party may receive in real time and store message data, including the date, time, and content of the messages.

If you are using the 123Pro Platform as a service professional, we may receive information about you in the form of ratings and reviews from Requesters who engaged your professional services through the 123Pro Platform.

We will apply this Privacy Policy to any Personal Information received from third parties, unless we have disclosed otherwise.

f) Information You Provide to a Third Party 

The 123Pro Platform includes links from the 123Pro Platform to sites or applications operated by third parties ("Third-Party Sites") and plug-ins (such as Twitter buttons) from Third-Party Sites. 

For example, service professionals may be directed to a Third Party Site, so that the Third Party Site can conduct a background check. The Third Party Site may ask the service professional for identifying information to conduct the background check.

Some Third-Party Sites link to 123Pro and share information with 123Pro. For example, in some cases, you can book services through the 123Pro Platform with one of our booking partners (“Booking Partner”), such as Amazon, Facebook, Lendnorth and other third party sites. In that case, you might provide the booking information, such as your name, telephone number, email address, and booking address, to the Booking Partner. The Booking Partner might then share the necessary booking information with us. 

123Pro does not control any Third-Party Sites, and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by that site's privacy policy.

We recommend that you read the Third-Party Site's privacy policy if you choose to enter any Third-Party Site or click on a plug-in.

II. HOW WE USE THE PERSONAL INFORMATION WE COLLECT 

We – including without limitation our affiliates, parents, and subsidiaries – use the information we collect to serve our customers, consider applicants, market and promote our services, and improve your experience at the 123Pro Platform. Some examples include:

• Scheduling, rescheduling, and cancelling services

• Rating and reviewing service professionals

• Providing public profiles of service professionals

• Addressing service complaints

• Communicating with you by email, telephone, or text message, in accordance with your wishes

• Managing payments for services

• Considering whether to engage service professionals on the 123Pro Platform

• Evaluating job applications to work at 123Pro

• Improving customer service

• Sending you marketing and promotional emails, on behalf of 123Pro or selected third parties, unless you have told us you do not want to receive such emails

• Troubleshooting technical problems on the 123Pro Platform

• Responding to questions and feedback

• Conducting research and analysis

• Running online or mobile sweepstakes, contents, or other promotions

• Marketing and advertising 123Pro products and services and those of selected third parties

• Continuously evaluating and improving the online and mobile user experience

• Preventing, discovering and investigating violations of this Privacy Policy or any applicable terms of service or terms of use for the Mobile Application, and investigating fraud, chargebacks or other matters

• Contacting you with regard to your use of the 123Pro Platform and, in our discretion, changes to the 123Pro Platform and/or the 123Pro Platform policies

• Compliance with the law or to protect the rights, property, or safety of 123Pro, our users, or others, including to maintain network and information security, for fraud prevention, and to report suspected criminal acts

By using the 123Pro platform, you expressly consent and agree to accept and receive communications from us, including via text message, calls, and push notifications to the cellular telephone number you provided to us. Standard text messaging charges applied by your cell phone carrier will apply to text messages we send. By consenting to being contacted by 123Pro, you understand and agree that you may receive communications, including marketing communications generated by automatic telephone dialing systems and/or which will deliver prerecorded messages, sent by or on behalf of 123Pro, its affiliated companies and/or Users/Professionals, including but not limited to: operational communications concerning your account or use of the 123Pro Platform or Services, updates concerning new and existing features on the 123PRo Platform, communications concerning promotions run by us, and news concerning 123Pro and industry developments. You acknowledge that you are not required to consent to receive promotional messages as a condition of using the 123Pro Platform or the Services. If a contact number you have provided to us is no longer your number, you agree to notify us promptly that you can no longer be reached at that number. You represent that you have received, and are authorized to convey to us, the consent of any authorized users on your account to be contacted by us as described in this Section. You agree that all consents provided in this Section will survive cancellation of your account. You may opt-out of receiving promotional or marketing texts or calls from 123Pro at any time. You may opt-out of receiving all text (SMS) messages from 123Pro (including informational or transactional messages) by replying with the word “STOP” to a text message from us; however you acknowledge that opting out of receiving all texts may impact your use of the 123Pro Platform or the Services. You also acknowledge that 123Pro or its third party service providers may record customer service calls after notice to you and with your consent, in order to assist you when you contact our customer support services.

You agree to 123Pro’s use of a service provider to mask your telephone number when you call or exchange text (SMS) messages with a Service Professor or Service Requestor using a telephone number provided by 123Pro. During this process, 123Pro and its service provider will receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages. You agree to the masking process described above and to 123Pro’s use and disclosure of this call data for its legitimate business purposes.

The information described in this section may be transferred to, or processed and stored in, the United States, Canada and other countries, which may employ greater or less restrictive data protection laws. In all cases, we will take appropriate measures to protect your personal information in accordance with the policies described herein.

Data Retention 

We delete the back-ups of the databases containing your Personal Information after 24 months.

III. HOW WE SHARE THE INFORMATION WE COLLECT 

We may sell, rent, or trade your Personal Information to third parties as disclosed in this Privacy Policy at the time you provide your information. The following are some of the ways we share your information:

a) Affiliated Companies 

We may share your Personal Information among our various affiliates, parents, and subsidiaries, including without limitation Lendnorth Financial, Amazon, Facebook and Google for purposes of facilitating aspects of services offered through the 123Pro Platform and for marketing purposes.

b) Service Professional Profiles, Service Instructions by Requesters, and Ratings and Reviews by Requesters 

The 123Pro Platform may display profiles of the supplier professionals who participate on the 123Pro Platform. These profiles may include the service professional’s name, and ratings and reviews about the service professional provided by their customers. The service professional’s profile may be visible to all users of the 123Pro Platform and on Booking Partners’ websites.

If you provide a rating or review about a service professional, we may post your first name, the initial of your last name, and the name of your neighborhood along with your rating or review on the service professional’s profile on the 123Pro Platform and on Booking Partners’ websites. In addition, service professionals may use your ratings and reviews, as well as this personal information about you, in their own marketing materials.

If you provide information about your home to request a booking or a quote for a service, we may post your first name, the initial of your last name, the type of service requested, your zip code and region, the number of service providers requested, the date of your booking or quote request, your requested service date, and any description of the requested service or service instructions or notes that you provide on the 123Pro Platform.

c) Third Parties Providing Services on Our Behalf 

Third party companies and individuals provide or facilitate certain aspects of the services offered through the 123Pro Platform on our behalf. We may provide these third-party service providers with access to your information, including your Personal Information, so that they can perform these services for us. We require these third-party service providers to provide safeguards for your Personal Information similar to the ones that we provide.

The following are some examples of how we share your information with third-party service providers.

• Data Analytics. We retain third-party service providers to help us perform data analytics regarding your interactions with the 123Pro Platform. For example, Google Analytics and Bounce Exchange may track what pages users visit on the Site, whether users use any coupon codes, and what services users request to determine how users use the Site. For example, Branch Metrics and Mixpanel collect and provide reports to us showing how you interact with the 123Pro Platform using information, such as your IP address, browser ID and Device Identifier. 

• In some cases, these third-party service providers, such as Epsilon, may in turn share your Personal Information, such as your name and email address, with other third parties for their marketing-related purposes. 

• Platform Features. Service providers help us to provide functions available through the 123Pro Platform. For example, we may share your Device Identifier with Urban Airship so that it can help us to send you push notifications. We may share your telephone number and call data with Twilio, as described in Section I(e), above, so that Twilio can mask your telephone number. We share your telephone number, call data, device id and other 123Pro account and device information with Layer, as described in Section I(e), above, to help facilitate communication using the App. 

• Payment Processing. We use payment gateway provider, a third-party service provider, to process any billing information, including credit card information you submit. 

• User Reviews Aggregation. We use third-party service providers, such as Bazaarvoice, to aggregate user reviews and publish them on third party websites. 

• Email Delivery. We use third-party service providers, such as Customer.io and Sendgrid, Zendesk to deliver email to our users. 

• Background Check Service Providers. When service professionals applying to participate on the 123Pro Platform in the United States or Canada provide their Social Security or Social Insurance numbers for a background check, the Social Security or Social Insurance number is transmitted using TLS encryption to the background check service provider. 123Pro also securely provides American and Canadian service professional's Social Security numbers to the check processor. 

• Marketing and Promotional Vendors and Partners. We may share Personal Information with third party service providers who assist us with marketing, and with other trusted parties whom we believe offer products or services that may be of interest to you. 

• Digital Vault Services. If you participate in 123Pro Secure Access, 123Pro uses KeyCafe, a third-party service provider, to store and provide digital access for your keys to services professionals participating on the 123Pro platform. As part of this service, 123Pro will provide KeyCafe your name and your physical keys. If you provide services to a customer who participates in 123Pro Secure Access, 123PRo uses KeyCafe, a third-party service provider, to provide digital access to the customer's keys. As part of this service, 123Pro will provide KeyCafe your mobile phone number. 

• Customer Support. We use third-party service providers to assist with providing customer support for questions you may have about your account and use of the 123Pro Platform. We may disclose your Personal Information to such service providers to assist with responding to your questions. 

• Legal Advice. We may disclose your Personal Information to an attorney in the process of obtaining legal advice. 

d) Banks and Credit Card Companies 

We may disclose your Personal Information to banks and credit card companies in the process of investigating payment fraud and/or responding to disputed charges.

e) Third Parties Providing Information on Available Services or Marketing Offers 

By using the 123Pro Platform, you may be contacted, either by 123Pro or directly by selected third parties, with opportunities to receive information on available services or marketing offers. If you agree to share your Personal Information to receive this information or marketing offers, your Personal Information may be disclosed to such third parties. All the information you disclose to the third parties will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to sharing your Personal Information with them. If you later decide that you no longer want to receive communication from such a third party, you will need to contact that third party directly.

f) Booking Partners 

We share your Personal Information with Booking Partners. For example, Amazon, Facebook, customers can book services through the 123Pro Platform from the Amazon, Facebook, Google websites including those customers in the United Kingdom, sites and apps. Upon request, we provide our Booking Partner with information about the services you booked or provided, as applicable, through the 123Pro Platform.

g) Sweepstakes, Contests and Promotions 

We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the 123Pro Platform that may require providing Personal Information to register. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. Please read the official rules carefully. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners' list.

h) Social Network Site Authentication 

If you choose to log-in to the 123Pro Platform through Facebook, Twitter, or another social networking site, we may share information about your account with the social networking site.

i) Administrative and Legal Reasons 

Required Disclosures: 

We may be required to disclose Personal Information in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.

Legal Compliance and Protections: 

We may disclose account and other Personal Information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of 123Pro, our users, or others. This includes exchanging Personal Information with other companies and organizations for fraud prevention and credit risk reduction.

h) Corporate Transactions 

We reserve the right to disclose and transfer your information, including your Personal Information:

• To a subsequent owner, co-owner, or operator of the 123Pro Platform or successor database.

• In connection with a corporate merger, consolidation, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

CHILDREN'S ONLINE PRIVACY PROTECTION ACT COMPLIANCE 

We do not collect any information from anyone under 13 years of age. The 123Pro Platform, and products and services offered through it, are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorized to use the 123Pro Platform.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE/YOUR CALIFORNIA PRIVACY RIGHTS 

California residents who use the 123Pro Platform may request that we provide certain information regarding our disclosure of your Personal Information to third parties for their direct marketing purposes. You can make such a request by e-mail to admin@123Pro.com

IV. HOW WE PROTECT THE PERSONAL INFORMATION WE COLLECT 

The security and confidentiality of your Personal Information is important to us. We have implemented technical, administrative, and physical security measures to protect your Personal Information from unauthorized access or disclosure and improper use.

For example, when users book services, the information they input is encrypted through TLS encryption. We do not store credit card information on our servers, and we use TLS encryption to protect your credit card information when it is transferred to our third-party payment processor. In addition, access to your Personal Information is restricted in our offices. Only employees who need the Personal Information to perform a specific job, for example, sales representatives, managers, and customer service staff, are granted access to Personal Information. All employees with access to Personal Information are kept up-to-date on our security and privacy practices. After a new policy is added, these employees are notified and/or reminded about the importance we place on privacy, and what they can do to enhance protection for our users' Personal Information.

It is important for you to protect against unauthorized access to your account password and to your computer. Be sure to log out of your account or to close your browser after you have completed your visit to our Site.

Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Information.

V. YOUR CHOICES REGARDING THE INFORMATION WE COLLECT 

You may contact admin@123Pro.com to update, correct, or delete your Personal Information. You may also update, correct, and delete some of your Personal Information through your account on the 123Pro Platform. 

In addition, you may cancel or modify the email communications you have chosen to receive from the 123Pro Platform by following the instructions contained in emails from us.

VI. HAVE QUESTIONS? 

If you have any questions about this Privacy Policy, we'll do our best to answer them promptly. Here's how to contact us:

Email: 
admin@123Pro.com 

Mailing Address: 
Bristol CPM Inc. C/O 123Pro
2910 South Sheridan Way 
Oakville, ON, Canada L6J 7L9 

VII. OUR PRIVACY SHIELD PRIVACY POLICY AND INFORMATION SPECIFIC TO NON-U.S. USERS 

a) All locations outside of the United States

The Personal Information collected through the Site is downloaded to a server maintained by 123Pro in the United States or Canada. 123Pro will comply with requests to exercise individual data rights in accordance with applicable law. You can contact admin@123Pro.com to request to exercise your data rights. 

b) For Individuals in the EU, EEA and/or Switzerland 

To provide an adequate level of protection for Personal Information received from the Member States of the European Economic Area ("EEA") and from Switzerland, 123Pro ("123Pro") complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce (“Privacy Shield Principles”) when processing the Personal Information of natural persons located in the EEA and Switzerland (collectively, "EEA Individuals") whose data is transferred into the US pursuant to the Privacy Shield. EEA Individuals include users of the 123Pro Platform, such as service requesters and service professionals. EEA Individuals also include employees of 123Pro. affiliated companies located in the Member States. Please note that service professionals who provide services through the 123Pro Platform are independent contractors and are not employees of 123Pro or employees of any of 123Pro affiliated companies, including those located in the Member States. 

123Pro has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. 

c) Notice 123Pro’s Use And Disclosure Of Personal Information 

Before processing the Personal Information of any EEA Individual, 123Pro, or its local affiliate, provides the EEA Individual with a notice concerning the processing of his or her Personal Information. The notice, including this Privacy Policy, are available for review on the 123Pro Platform and/or provided directly to the EEA Individual. 

123Pro receives the Personal Information of 123Pro Platform users and processes it for the purposes described in this Privacy Policy. 123PRo may disclose this Personal Information to third parties as described in the Privacy Policy. 

123Pro receives the Personal Information of applicants for employee positions located in the Member States and Switzerland ("Applicants")to administer the recruitment process and, of employees, to administer the employment relationship. Examples of the purposes for which 123Pro collects and uses employee and Applicant Personal Information include, without limitation, recruitment; workforce management; to administer compensation, payroll, and benefits; to address various legal obligations related to the employment relationship, including discovery obligations in civil litigation; to administer training; to administer 123Pro’s compliance process; and for emergency contact purposes. 

The employee and Applicant Personal Information that 123Pro receives from the EEA and Switzerland consists largely of information provided by Applicants, such as resumes and completed job applications and information created by 123Pro or its affiliates to administer the employment relationship, such as business contact information, and compensation and benefits information.

123Pro may disclose employee and Applicant Personal Information, subject to written agreement, to authorized service providers who provide services related to the administration of the recruitment process and/or the employment relationship. 123Pro also may disclose employee and Applicant Personal.

Information to corporate affiliates in connection with the recruitment process and for internal employment administration purposes, such as to administer access to physical facilities and information systems and for succession planning.

123Pro may be required to disclose, and may disclose, EEA and Swiss Personal Information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.

d) Cross-Border Data Transfers: 

The Personal Information collected through the Site will be transferred to the United States and Canada. The recipients of Personal Information collected through the Site (listed in Section III above) are located in the United States and Canada or in the country where the data was collected and the data that is transferred will be subject to Privacy Shield. 

e) Legal Bases For Processing: 

Consent and as Required by Law: 123Pro processes your Personal Information with your consent and as required by law. 

Contract: Users can enter into two different types of contracts through the 123Pro Platform: (1) a contract between service requesters and service professionals regarding professional services, and (2) a contract between the user and 123Pro whereby 123Pro facilitates the arrangement of the professional services contract in exchange for a share of the fee for the contracted professional services. To take steps necessary to respond to users’ requests to enter into both types of contracts, 123Pro processes Personal Information from service requesters, including contact information, services requested, and worksite location information, and from service professionals, including contact information, skills and experience, background check information, preferred times, and preferred locations. To facilitate the performance of the service professional agreement and to perform the contract with users, 123Pro must process Personal Information, including the service requester’s billing information, the service professional’s receivables information and geographic location information, and both parties’ text messages and phone calls through the 123Pro Platform. 

123Pro cannot facilitate service professional contracts through the 123Pro Platform or enter into contracts with users unless users provide this Personal Information. 

Legitimate Interests: 123Pro also processes Personal Information as necessary for its legitimate interests as follows: 

• Marketing and advertising: Unless you opt out as described below, we use your Personal Information as necessary to provide you information about the services that we think might interest you, in accordance with applicable law. 

• Network and information security, fraud prevention, and reporting suspected criminal acts: In the event of fraud, a security incident, or a suspected criminal act, we would examine Personal Information that appeared to be linked to the incident as necessary to determine what happened, remediate, report to the authorities, and prevent a recurrence. 

Right to Object to Processing for Direct Marketing or Legitimate Interests: 

EEA Individuals have the right to object to the processing of their Personal Information for purposes of 123Pro’s direct marketing or legitimate interests by contacting 123Pro at admin@123Pro.com

Automated decision-making: 

123Pro sometimes uses EEA Individuals’ Personal Information submitted through the Site for automated decision-making. For example, 123Pro may display advertisements and send emails to you containing content automatically chosen based on the services you have ordered through the 123Pro Platform in the past. However, 123Pro will not use EEA Individuals’ Personal Information submitted through the Site for automated decision-making, including profiling, which produces legal effects or similarly significantly affects the EEA Individual. 

Individual Rights: 

EEA Individuals have the right to access their Personal Information collected by the Site and to request that 123Pro update, correct, or delete their Personal Information as provided by applicable law. EEA Individuals also have the right to object to, or restrict, 123Pro’s processing of their Personal Information. 

In addition, EEA Individuals have the right to data portability concerning their Personal Information. Subject to certain limitations, the right to data portability allows EEA Individuals to obtain from 123Pro, or to ask 123Pro to send to a third party, a digital copy of the Personal Information that they provided to the Site. EEA Individuals’ right to access their Personal Information includes their right to receive a copy of all, or a portion, of their Personal Information in 123Pro’s possession as long as 123Pro’s providing the Personal Information would not adversely affect the rights and freedoms of others. 

f) Choice: How To Opt Out Of Collection Of Your Personal Information By 123Pro And Transfer To Third Parties 

123Pro may disclose EEA Individuals’ Personal Information transferred to the United States and Canada pursuant to the Privacy Shield to non-agent third parties as described in Section III above. In some cases, as described in Section III of this Privacy Policy, our third-party service providers may in turn share the Personal Information of 123Pro Platform users with other third parties. You may opt out of such disclosures and onward transfers by writing to admin@123Pro.com 

123Pro will offer EEA Individuals whose Personal Information has been transferred to the United States pursuant to the Privacy Shield the opportunity to opt out from: (a) the disclosure of their Personal Information to any non-agent third parties not already listed in Section III above and (b) the use of their Personal Information for purpose(s) that are not compatible with the purpose(s) for which the Personal Information was originally collected or subsequently authorized by the Individual. 123Pro will provide EEA Individuals with clear, conspicuous, and readily available mechanisms to exercise choice, should such circumstances arise. Any withdrawal will apply only prospectively, and 123Pro will continue to retain the Personal Information that EEA Individuals provided before they withdrew their consent for as long as allowed or required by applicable law. 

g) Access And Correction: How You Can Exercise Your Rights 

123Pro acknowledges EEA Individuals’ right to access and correct their Personal Information. Upon reasonable request, 123Pro will grant EEA Individuals reasonable access to their Personal Information and will permit them to correct, amend or delete Personal Information that is inaccurate or incomplete. EEA Individuals wishing to exercise these rights may do so by contacting admin@123Pro.com. Employees should contact their local manager to exercise these rights. 

h) Enforcement: What To Do If You Have a Complaint 

In compliance with the Privacy Shield Principles, 123Pro commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact 123Pro at admin@123Pro.com. 

123Pro has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. 

123Pro commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the EU DPA’s and Swiss FDPIC with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship. 

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction 

Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Contact details for the Swiss Federal Data Protection and Information Commissioner can be found at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection---switzerland.html 

In compliance with the Privacy Shield Principles, 123Pro commits to resolve complaints about our collection or use of employees’ Personal Information. Current or former employees with inquiries regarding the Privacy Shield or who wish to submit a complaint concerning the handling of their Personal Information should first contact 123Pro at: admin@123Pro.com. Current or former employees who are not satisfied with the internal resolution of a complaint may seek redress from the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner (the “Commissioner”), as applicable. 123PRo will cooperate in investigations by, and comply with the advice of, the panel and/or Commissioner with regard to an employee’s Personal Information transferred from the EU and/or Switzerland in the context of the employment relationship. 

123Pro is subject to the jurisdiction and enforcement authority of Canadian federal laws.

i) Liability 

123Pro may be liable for the onward transfer of EEA and Swiss Personal Information to agent third parties pursuant to the Privacy Shield unless we can prove that we were not a party to the actions giving rise to the damage. 

Cookies Policy 

Websites maintained by 123Pro (collectively the "Site") use a number of different cookies. This Cookies Policy explains the following:

- What are cookies?

- Cookies we use and why we use them

- E.U. user’s right to refuse cookies 

WHAT ARE COOKIES? 

Cookies are small files that are downloaded to your device when you visit a website. The cookie then sends information back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu. 

Cookies perform many different functions, such as letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience.

COOKIES AND WHY WE USE THEM 

Cookies can be categorized by who puts the cookie on the user's computer (or other device the user uses to browse the website).

First-party cookies are cookies placed by the party operating the website. For example, any cookies we (123Pro) place on your computer from our Site are first-party cookies. 

Third-party cookies are cookies placed from a website by a party that does not own or operate that website. 

We use only first-party cookies on our Site.

Cookies are also often categorized by function. We use four types of cookies by function on our Site:

1. Essential Cookies 

These are cookies that are strictly necessary for the functioning of the website or for performing services that an individual user has requested. For example, we use a cookie that remembers that you are logged into the Site until you log out.

2. Analytical Cookies 

These cookies collect information about how visitors use a website — for instance, which pages visitors go to most often, and whether visitors get error messages from web pages. Analytical cookies don't collect information that identifies a visitor. All information that analytical cookies collect is aggregated and therefore anonymous. These cookies are used only to improve how a website functions.

We use cookies provided by third-party service providers, including Google Analytics, Optimizely, and New Relic, to help us analyze how users use the Site.

The Google Analytics cookies collect data tied to a user's IP address, 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 the Site. You can object to the collection of your information by Google Analytics by clicking here. We place cookies provided by Optimizely to test whether changes we have made to the Site work properly. 

Like the cookies provided by Google Analytics and Optimizely, the cookies provided by New Relic collect information about your visit to the Site, such as delays you might experience when using Site features. The New Relic cookies assign an identification number, called a "session ID", to your visit to our Site. Information collected about your visit is sent to New Relic and tied to the session ID. Each visit generates a new session ID, and session IDs between different visits are not linked to identify you. New Relic deletes the session ID at the end of your visit.

The cookies provided by each third-party service provider send the information they collect to that third-party service provider. For example, the cookies provided by Google Analytics send information about your Site interactions to Google Analytics. Each third-party service provider then compiles aggregated data using the information received and sends us reports on the aggregated data. These reports are not shared with other parties. We use the reports to offer better Site experiences and tools in the future.

Although these cookies provide information to the third-party service providers, they are first-party cookies because we place them ourselves.

3. Functional Cookies 

These cookies allow the website to remember choices users make and to provide enhanced, personalized features. For example, we use cookies provided by Olark.com that allow you to continue chatting with customer support when navigating between pages.

4. Targeting/Advertising Cookies 

Targeting/advertising cookies are cookies used to deliver advertisements relevant to the user. They remember that a user has visited a website and share this information with other organizations, such as advertising vendors.

Cookies in this category may include Remarketing Cookies. These are cookies that remember that you visited our Site after you leave. Sometimes they collect information about what pages of our Site you visited. They then share this information with our third-party vendors, such as AppNexus, Google, Nanigans, Facebook, and Twitter. Based on this information, the third-party vendors show you advertisements on third-party websites for 123Pro products that we think may interest you based on what you viewed on our Site.

You may opt out of Google's use of cookies by visiting Google's Ads Settings here. You can also opt out of the use by other third-party vendors, such as AppNexus, of information from cookies placed by the Site by visiting the Network Advertising Initiative opt-out page. However, not all of our third-party vendors participate in the Network Advertising Initiative opt-out page. 

Cookies can also be categorized by how long they remain on your device. There are two broad categories of duration:

1. Persistent cookies 

Persistent cookies remain on your device until deleted manually or automatically.

2. Session cookies 

Session cookies remain on your device until you close your browser when they are automatically deleted.

We use both session and persistent cookies on our Site.

Location of information processing: 

The information collected by our cookies is processed in servers located in the United States and in Canada.

E.U. USERS' RIGHT TO REFUSE COOKIES 

Users in the European Union (E.U.) have the right to refuse to allow cookies to be placed on the device they use to access the Site. We describe below how E.U. users can reject cookies used by our Site.

Rejecting Cookies Through Browser Settings: 

The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. For more information on using browser settings to reject cookies, please visit www.allaboutcookies.org. 

You should note that rejecting cookies in your browser settings may mean that any preferences you set on this Site will be lost and that the Site may not work as well. In addition, using the browser settings to reject cookies may also cause your browser to reject cookies from all websites, not just this Site.

HAVE QUESTIONS? 

If you have any questions about our Cookie Policy, we'll do our best to answer them. You can email us at admin@123Pro.com 

COOKIE POLICY UPDATES 

If we change our Cookie Policy, we will post those changes on this page and update the Cookie Policy modification date above. If we materially change this Cookie Policy in a way that affects how we use or disclose your personal information, we will notify you by prominently posting a notice of such changes before making them and by stating the effective date of the changes.

CHANGE TO THIS PRIVACY POLICY 

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date below. If we materially change this Privacy Policy in a way that affects how we use or disclose your Personal Information, we will notify you by prominently posting a notice of such changes before making them and by stating the effective date of the changes. 

Bristol CPM Inc.,O/A 123Pro and its affiliates, parents, and subsidiaries ("123Pro" or "we", "us", or the "Company") take your privacy seriously. This Privacy Policy explains how we collect, use, share, and protect your Personal Information. If you do not want us to handle your Personal Information in this manner, please do not use the 123Pro Platform. Personal Information is information that relates to you as an individually identifiable person, such as your name, e-mail address, and mobile number. We assume that usage of the 123Pro platform confirms that you have read and understood this privacy policy and therefore agree to its contents.

This Privacy Policy explains: 

• What information we collect

• How we use that information

• How we may share that information

• How we protect your information

• Our Privacy Shield Privacy Policy and information specific to non-US users

• How to contact us with questions about this Privacy Policy

This Privacy Policy applies only to (a) information that we collect on the websites 123Pro.com,  (the "Site") and (b) through the 123Pro mobile applications, including the mobile application for service requesters and the mobile application for service professionals (the "App") (collectively the "123Pro Platform"). 

I. INFORMATION WE COLLECT 

a) Personal Information You Give Us 

We collect information that you voluntarily share with us through the 123Pro Platform.

If you are using the 123Pro Platform to request professional services, or contact 123Pro or its third-party service providers, you may give us:

• Contact information, such as your name, physical address, telephone number, and email address

• Information about your home, such as the number of bedrooms, the types of appliances, zip code or postal code where your home is located and your instructions for servicing your home

• Billing information, such as credit or debit card number, expiration date & security code and/or information regarding your PayPal, Google Wallet or other digital payment accounts and the 123Pro Platform itself

• Ratings and reviews of the service professionals you engage through the 123Pro Platform

If you participate on the 123Pro Platform as a service professional, or contact 123PRo or its third-party service providers, you may give us:

• Contact information, such as your name, email address, mailing address, and phone number

• Log-in information, including your 123Pro Platform username and password

• Application information, if requesting consideration to participate as a service professional through the 123Pro Platform, such as your experience, skills, eligibility to work, and availability

• Photographs of yourself

• Social Security  or Social Insurance number, if you are a service professional who wishes to participate on the 123Pro Platform in the United States or Canada and you are selected for a background check

If you apply on the 123Pro Platform for employment with 123PRo, you may give us:

• Contact information, including your name, email address, telephone number, and mailing address

• Resume and LinkedIn profile

More about payment card information: 

Although users can submit credit card or other payment card information to pay for a service through the 123Pro Platform, 123PRo does not receive this information itself. Payment card information is transmitted directly to a third-party payment card processor, (Payment Gateway Provider), through an Internet connection secured by industry-standard Transport Layer Security (TLS) encryption technology. These payment gateway providers then communicate to 123Pro whether your payment has cleared, but does not provide payment card information to 123Pro. 

Surveys 

You may, at your choice, complete surveys on the 123Pro Platform or distributed by 123Pro about, for example, your level of satisfaction with the 123Pro Platform, your engagement with the 123Pro Platform, and your awareness of 123Pro Platform features. In some cases, we may link the information you provide in the survey with Personal Information in your 123Pro account, such as your name or email address. When linked to Personal Information, your survey information becomes Personal Information too.

b) Information We Collect Through Technology 

We collect information through technology to enhance our ability to serve you. When you access and use the 123Pro Platform, or contact 123Pro or its third-party service providers, 123Pro and, in some cases, our third-party service providers collect information about you or how you interact with the 123Pro Platform. We describe below a few of the methods we use to collect information through technology.

When you visit the 123Pro Platform, we collect your Internet Protocol (IP) address. An IP address is often associated with the portal you used to enter the Internet, like your Internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. However, we may link the last IP address you used to access the 123Pro Platform to Personal Information you provide us. Where, according to local law, IP addresses and the like are considered Personal Information, we treat them as such.

We may also collect a unique identifier for your computer, mobile device, or other device used to access the 123Pro Platform ("Device Identifier"). A Device Identifier is a number that is automatically assigned to the device you used to access the 123Pro Platform. We may link the Device Identifier to other information about your visit, such as what pages you viewed, and to Personal Information you provide us, such as your name. 

Do We Use Cookies? 

Yes we do, more information can be found below regarding this subject.

Web Beacons 

We may include small graphic images or other web programming code, called web beacons (also known as "pixel tags", "web bugs" or "clear GIFs"), in our web and mobile pages and messages. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Web users. In contrast to cookies, which are stored in a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons help us better manage content on the 123Pro Platform by informing us what content is effective, monitoring how users navigate the 123Pro Platform, counting users of the 123Pro Platform, and counting how many e-mails sent by us were actually opened.

Your 'Do Not Track' Browser Setting 

We do not support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser's settings to let the websites you visit know that you do not want the websites collecting your Personal Information.

We do track your online activities over time and across third-party websites or online services. For example, we use web beacons to help us determine what links or advertisers brought you to our Site. We also use third-party service providers to display advertisements to you on other websites based on your activities while on the 123Pro Platform.

c) Information Collected by Mobile Applications 

When you use the App, the App may automatically collect and store some or all of the following information from your mobile device ("Mobile Device Information"), including, but not limited to: 

• The type of Internet browsers you use with the App.

• Your preferred country site.

• Your mobile operating system.

• Your phone number or other identifiers assigned to your mobile device, including: The IP address of your mobile device, The manufacturer and model of your mobile device

We may also collect information about how you use the App, such as the amount of time you spend using the App, how many times you use a specific feature of the App over a given time period, how often you use the App, and actions you take in the App. In addition, we may gather information about the website from which you downloaded the App to help us determine what App download site is most effective (collectively "App Usage Information"). 

We may link your Mobile Device Information and App Usage Information to Personal Information you have provided us, in which case we will treat the combined information as Personal Information.

Location Tracking 

If you are a service professional using 123Pro’s mobile application for supplier professionals (the "Pro Portal"), we may collect your geographic location by using Global Positioning System (GPS) information sent to us from the Pro Portal. For more information on when this information is collected, how we use it, and with whom it is shared, services professionals should refer to the Supplier Professional Agreement available on the service professional portal. 

We only collect location information about service professionals who have been accepted to participate on the 123Pro Platform and not about service requesters or about supplier professionals applying to participate in the 123Pro Platform.

d) Information You Provide About A Third Party 

If you choose to use our referral service to tell a friend about the 123Pro Platform, we may collect your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the 123Pro Platform. We store this information only to send this one-time email and to track the success of our referral program. We do not use this information for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you refer a friend, your e-mail address may be included in the message sent to your friend.

If you are using the 123Pro Platform to request professional services, you may provide us ratings and reviews of the service professionals you engage through the 123Pro Platform.

e) Information Third Parties Provide About You 

Conversion Tracking: We may supplement the information we collect about you through the 123Pro Platform with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, websites on which we have placed advertisements, such as Google, may tell us which ads about 123Pro you clicked. This is often called "conversion tracking."

Background Checks: In addition, third parties we contract to conduct background checks on service professionals, may share the results of the background check with 123Pro.

Recording Phone Calls: Selected third-parties, including those who may assist in providing customer service support, may monitor and/or record the contents of phone calls made through or in relation to the 123Pro Platform, after notice to you and with your consent.

Social Networking Sites: If you login to the 123Pro Platform through a social networking site, such as Facebook, we may collect your Facebook authentication token and account identification number and use that information to provide you with access to your account on the 123Pro Platform.

Ratings and Reviews: If you are using the 123Pro Platform as a service professional, we may receive information about you in the form of ratings and reviews from requesters who engaged your professional services through the 123Pro Platform.

Photographs of Completed Services: If you are using the 123PRo Platform to request services, service professionals booked through the 123Pro Platform may take photographs of completed services and provide them to 123Pro.

Message Interception: If you call or text (SMS) message a service professional or service requester using the telephone number provided by 123Pro, 123Pro uses a third party to mask your telephone number. During this process, 123Pro and a third party we contract will receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages.

If you send a message to a service professional or service requester in the App, 123Pro uses a third party to process the communications. During this process, 123Pro and the third party may receive in real time and store message data, including the date, time, and content of the messages.

If you are using the 123Pro Platform as a service professional, we may receive information about you in the form of ratings and reviews from Requesters who engaged your professional services through the 123Pro Platform.

We will apply this Privacy Policy to any Personal Information received from third parties, unless we have disclosed otherwise.

f) Information You Provide to a Third Party 

The 123Pro Platform includes links from the 123Pro Platform to sites or applications operated by third parties ("Third-Party Sites") and plug-ins (such as Twitter buttons) from Third-Party Sites. 

For example, service professionals may be directed to a Third Party Site, so that the Third Party Site can conduct a background check. The Third Party Site may ask the service professional for identifying information to conduct the background check.

Some Third-Party Sites link to 123Pro and share information with 123Pro. For example, in some cases, you can book services through the 123Pro Platform with one of our booking partners (“Booking Partner”), such as Amazon, Facebook, Lendnorth and other third party sites. In that case, you might provide the booking information, such as your name, telephone number, email address, and booking address, to the Booking Partner. The Booking Partner might then share the necessary booking information with us. 

123Pro does not control any Third-Party Sites, and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by that site's privacy policy.

We recommend that you read the Third-Party Site's privacy policy if you choose to enter any Third-Party Site or click on a plug-in.

II. HOW WE USE THE PERSONAL INFORMATION WE COLLECT 

We – including without limitation our affiliates, parents, and subsidiaries – use the information we collect to serve our customers, consider applicants, market and promote our services, and improve your experience at the 123Pro Platform. Some examples include:

• Scheduling, rescheduling, and cancelling services

• Rating and reviewing service professionals

• Providing public profiles of service professionals

• Addressing service complaints

• Communicating with you by email, telephone, or text message, in accordance with your wishes

• Managing payments for services

• Considering whether to engage service professionals on the 123Pro Platform

• Evaluating job applications to work at 123Pro

• Improving customer service

• Sending you marketing and promotional emails, on behalf of 123Pro or selected third parties, unless you have told us you do not want to receive such emails

• Troubleshooting technical problems on the 123Pro Platform

• Responding to questions and feedback

• Conducting research and analysis

• Running online or mobile sweepstakes, contents, or other promotions

• Marketing and advertising 123Pro products and services and those of selected third parties

• Continuously evaluating and improving the online and mobile user experience

• Preventing, discovering and investigating violations of this Privacy Policy or any applicable terms of service or terms of use for the Mobile Application, and investigating fraud, chargebacks or other matters

• Contacting you with regard to your use of the 123Pro Platform and, in our discretion, changes to the 123Pro Platform and/or the 123Pro Platform policies

• Compliance with the law or to protect the rights, property, or safety of 123Pro, our users, or others, including to maintain network and information security, for fraud prevention, and to report suspected criminal acts

By using the 123Pro platform, you expressly consent and agree to accept and receive communications from us, including via text message, calls, and push notifications to the cellular telephone number you provided to us. Standard text messaging charges applied by your cell phone carrier will apply to text messages we send. By consenting to being contacted by 123Pro, you understand and agree that you may receive communications, including marketing communications generated by automatic telephone dialing systems and/or which will deliver prerecorded messages, sent by or on behalf of 123Pro, its affiliated companies and/or Users/Professionals, including but not limited to: operational communications concerning your account or use of the 123Pro Platform or Services, updates concerning new and existing features on the 123PRo Platform, communications concerning promotions run by us, and news concerning 123Pro and industry developments. You acknowledge that you are not required to consent to receive promotional messages as a condition of using the 123Pro Platform or the Services. If a contact number you have provided to us is no longer your number, you agree to notify us promptly that you can no longer be reached at that number. You represent that you have received, and are authorized to convey to us, the consent of any authorized users on your account to be contacted by us as described in this Section. You agree that all consents provided in this Section will survive cancellation of your account. You may opt-out of receiving promotional or marketing texts or calls from 123Pro at any time. You may opt-out of receiving all text (SMS) messages from 123Pro (including informational or transactional messages) by replying with the word “STOP” to a text message from us; however you acknowledge that opting out of receiving all texts may impact your use of the 123Pro Platform or the Services. You also acknowledge that 123Pro or its third party service providers may record customer service calls after notice to you and with your consent, in order to assist you when you contact our customer support services.

You agree to 123Pro’s use of a service provider to mask your telephone number when you call or exchange text (SMS) messages with a Service Professor or Service Requestor using a telephone number provided by 123Pro. During this process, 123Pro and its service provider will receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages. You agree to the masking process described above and to 123Pro’s use and disclosure of this call data for its legitimate business purposes.

The information described in this section may be transferred to, or processed and stored in, the United States, Canada and other countries, which may employ greater or less restrictive data protection laws. In all cases, we will take appropriate measures to protect your personal information in accordance with the policies described herein.

Data Retention 

We delete the back-ups of the databases containing your Personal Information after 24 months.

III. HOW WE SHARE THE INFORMATION WE COLLECT 

We may sell, rent, or trade your Personal Information to third parties as disclosed in this Privacy Policy at the time you provide your information. The following are some of the ways we share your information:

a) Affiliated Companies 

We may share your Personal Information among our various affiliates, parents, and subsidiaries, including without limitation Lendnorth Financial, Amazon, Facebook and Google for purposes of facilitating aspects of services offered through the 123Pro Platform and for marketing purposes.

b) Service Professional Profiles, Service Instructions by Requesters, and Ratings and Reviews by Requesters 

The 123Pro Platform may display profiles of the supplier professionals who participate on the 123Pro Platform. These profiles may include the service professional’s name, and ratings and reviews about the service professional provided by their customers. The service professional’s profile may be visible to all users of the 123Pro Platform and on Booking Partners’ websites.

If you provide a rating or review about a service professional, we may post your first name, the initial of your last name, and the name of your neighborhood along with your rating or review on the service professional’s profile on the 123Pro Platform and on Booking Partners’ websites. In addition, service professionals may use your ratings and reviews, as well as this personal information about you, in their own marketing materials.

If you provide information about your home to request a booking or a quote for a service, we may post your first name, the initial of your last name, the type of service requested, your zip code and region, the number of service providers requested, the date of your booking or quote request, your requested service date, and any description of the requested service or service instructions or notes that you provide on the 123Pro Platform.

c) Third Parties Providing Services on Our Behalf 

Third party companies and individuals provide or facilitate certain aspects of the services offered through the 123Pro Platform on our behalf. We may provide these third-party service providers with access to your information, including your Personal Information, so that they can perform these services for us. We require these third-party service providers to provide safeguards for your Personal Information similar to the ones that we provide.

The following are some examples of how we share your information with third-party service providers.

• Data Analytics. We retain third-party service providers to help us perform data analytics regarding your interactions with the 123Pro Platform. For example, Google Analytics and Bounce Exchange may track what pages users visit on the Site, whether users use any coupon codes, and what services users request to determine how users use the Site. For example, Branch Metrics and Mixpanel collect and provide reports to us showing how you interact with the 123Pro Platform using information, such as your IP address, browser ID and Device Identifier. 

• In some cases, these third-party service providers, such as Epsilon, may in turn share your Personal Information, such as your name and email address, with other third parties for their marketing-related purposes. 

• Platform Features. Service providers help us to provide functions available through the 123Pro Platform. For example, we may share your Device Identifier with Urban Airship so that it can help us to send you push notifications. We may share your telephone number and call data with Twilio, as described in Section I(e), above, so that Twilio can mask your telephone number. We share your telephone number, call data, device id and other 123Pro account and device information with Layer, as described in Section I(e), above, to help facilitate communication using the App. 

• Payment Processing. We use payment gateway provider, a third-party service provider, to process any billing information, including credit card information you submit. 

• User Reviews Aggregation. We use third-party service providers, such as Bazaarvoice, to aggregate user reviews and publish them on third party websites. 

• Email Delivery. We use third-party service providers, such as Customer.io and Sendgrid, Zendesk to deliver email to our users. 

• Background Check Service Providers. When service professionals applying to participate on the 123Pro Platform in the United States or Canada provide their Social Security or Social Insurance numbers for a background check, the Social Security or Social Insurance number is transmitted using TLS encryption to the background check service provider. 123Pro also securely provides American and Canadian service professional's Social Security numbers to the check processor. 

• Marketing and Promotional Vendors and Partners. We may share Personal Information with third party service providers who assist us with marketing, and with other trusted parties whom we believe offer products or services that may be of interest to you. 

• Digital Vault Services. If you participate in 123Pro Secure Access, 123Pro uses KeyCafe, a third-party service provider, to store and provide digital access for your keys to services professionals participating on the 123Pro platform. As part of this service, 123Pro will provide KeyCafe your name and your physical keys. If you provide services to a customer who participates in 123Pro Secure Access, 123PRo uses KeyCafe, a third-party service provider, to provide digital access to the customer's keys. As part of this service, 123Pro will provide KeyCafe your mobile phone number. 

• Customer Support. We use third-party service providers to assist with providing customer support for questions you may have about your account and use of the 123Pro Platform. We may disclose your Personal Information to such service providers to assist with responding to your questions. 

• Legal Advice. We may disclose your Personal Information to an attorney in the process of obtaining legal advice. 

d) Banks and Credit Card Companies 

We may disclose your Personal Information to banks and credit card companies in the process of investigating payment fraud and/or responding to disputed charges.

e) Third Parties Providing Information on Available Services or Marketing Offers 

By using the 123Pro Platform, you may be contacted, either by 123Pro or directly by selected third parties, with opportunities to receive information on available services or marketing offers. If you agree to share your Personal Information to receive this information or marketing offers, your Personal Information may be disclosed to such third parties. All the information you disclose to the third parties will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to sharing your Personal Information with them. If you later decide that you no longer want to receive communication from such a third party, you will need to contact that third party directly.

f) Booking Partners 

We share your Personal Information with Booking Partners. For example, Amazon, Facebook, customers can book services through the 123Pro Platform from the Amazon, Facebook, Google websites including those customers in the United Kingdom, sites and apps. Upon request, we provide our Booking Partner with information about the services you booked or provided, as applicable, through the 123Pro Platform.

g) Sweepstakes, Contests and Promotions 

We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the 123Pro Platform that may require providing Personal Information to register. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. Please read the official rules carefully. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners' list.

h) Social Network Site Authentication 

If you choose to log-in to the 123Pro Platform through Facebook, Twitter, or another social networking site, we may share information about your account with the social networking site.

i) Administrative and Legal Reasons 

Required Disclosures: 

We may be required to disclose Personal Information in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.

Legal Compliance and Protections: 

We may disclose account and other Personal Information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of 123Pro, our users, or others. This includes exchanging Personal Information with other companies and organizations for fraud prevention and credit risk reduction.

h) Corporate Transactions 

We reserve the right to disclose and transfer your information, including your Personal Information:

• To a subsequent owner, co-owner, or operator of the 123Pro Platform or successor database.

• In connection with a corporate merger, consolidation, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

CHILDREN'S ONLINE PRIVACY PROTECTION ACT COMPLIANCE 

We do not collect any information from anyone under 13 years of age. The 123Pro Platform, and products and services offered through it, are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorized to use the 123Pro Platform.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE/YOUR CALIFORNIA PRIVACY RIGHTS 

California residents who use the 123Pro Platform may request that we provide certain information regarding our disclosure of your Personal Information to third parties for their direct marketing purposes. You can make such a request by e-mail to admin@123Pro.com

IV. HOW WE PROTECT THE PERSONAL INFORMATION WE COLLECT 

The security and confidentiality of your Personal Information is important to us. We have implemented technical, administrative, and physical security measures to protect your Personal Information from unauthorized access or disclosure and improper use.

For example, when users book services, the information they input is encrypted through TLS encryption. We do not store credit card information on our servers, and we use TLS encryption to protect your credit card information when it is transferred to our third-party payment processor. In addition, access to your Personal Information is restricted in our offices. Only employees who need the Personal Information to perform a specific job, for example, sales representatives, managers, and customer service staff, are granted access to Personal Information. All employees with access to Personal Information are kept up-to-date on our security and privacy practices. After a new policy is added, these employees are notified and/or reminded about the importance we place on privacy, and what they can do to enhance protection for our users' Personal Information.

It is important for you to protect against unauthorized access to your account password and to your computer. Be sure to log out of your account or to close your browser after you have completed your visit to our Site.

Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Information.

V. YOUR CHOICES REGARDING THE INFORMATION WE COLLECT 

You may contact admin@123Pro.com to update, correct, or delete your Personal Information. You may also update, correct, and delete some of your Personal Information through your account on the 123Pro Platform. 

In addition, you may cancel or modify the email communications you have chosen to receive from the 123Pro Platform by following the instructions contained in emails from us.

VI. HAVE QUESTIONS? 

If you have any questions about this Privacy Policy, we'll do our best to answer them promptly. Here's how to contact us:

Email: 
admin@123Pro.com 

Mailing Address: 
Bristol CPM Inc. C/O 123Pro
2910 South Sheridan Way 
Oakville, ON, Canada L6J 7L9 

VII. OUR PRIVACY SHIELD PRIVACY POLICY AND INFORMATION SPECIFIC TO NON-U.S. USERS 

a) All locations outside of the United States

The Personal Information collected through the Site is downloaded to a server maintained by 123Pro in the United States or Canada. 123Pro will comply with requests to exercise individual data rights in accordance with applicable law. You can contact admin@123Pro.com to request to exercise your data rights. 

b) For Individuals in the EU, EEA and/or Switzerland 

To provide an adequate level of protection for Personal Information received from the Member States of the European Economic Area ("EEA") and from Switzerland, 123Pro ("123Pro") complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce (“Privacy Shield Principles”) when processing the Personal Information of natural persons located in the EEA and Switzerland (collectively, "EEA Individuals") whose data is transferred into the US pursuant to the Privacy Shield. EEA Individuals include users of the 123Pro Platform, such as service requesters and service professionals. EEA Individuals also include employees of 123Pro. affiliated companies located in the Member States. Please note that service professionals who provide services through the 123Pro Platform are independent contractors and are not employees of 123Pro or employees of any of 123Pro affiliated companies, including those located in the Member States. 

123Pro has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. 

c) Notice 123Pro’s Use And Disclosure Of Personal Information 

Before processing the Personal Information of any EEA Individual, 123Pro, or its local affiliate, provides the EEA Individual with a notice concerning the processing of his or her Personal Information. The notice, including this Privacy Policy, are available for review on the 123Pro Platform and/or provided directly to the EEA Individual. 

123Pro receives the Personal Information of 123Pro Platform users and processes it for the purposes described in this Privacy Policy. 123PRo may disclose this Personal Information to third parties as described in the Privacy Policy. 

123Pro receives the Personal Information of applicants for employee positions located in the Member States and Switzerland ("Applicants")to administer the recruitment process and, of employees, to administer the employment relationship. Examples of the purposes for which 123Pro collects and uses employee and Applicant Personal Information include, without limitation, recruitment; workforce management; to administer compensation, payroll, and benefits; to address various legal obligations related to the employment relationship, including discovery obligations in civil litigation; to administer training; to administer 123Pro’s compliance process; and for emergency contact purposes. 

The employee and Applicant Personal Information that 123Pro receives from the EEA and Switzerland consists largely of information provided by Applicants, such as resumes and completed job applications and information created by 123Pro or its affiliates to administer the employment relationship, such as business contact information, and compensation and benefits information.

123Pro may disclose employee and Applicant Personal Information, subject to written agreement, to authorized service providers who provide services related to the administration of the recruitment process and/or the employment relationship. 123Pro also may disclose employee and Applicant Personal.

Information to corporate affiliates in connection with the recruitment process and for internal employment administration purposes, such as to administer access to physical facilities and information systems and for succession planning.

123Pro may be required to disclose, and may disclose, EEA and Swiss Personal Information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.

d) Cross-Border Data Transfers: 

The Personal Information collected through the Site will be transferred to the United States and Canada. The recipients of Personal Information collected through the Site (listed in Section III above) are located in the United States and Canada or in the country where the data was collected and the data that is transferred will be subject to Privacy Shield. 

e) Legal Bases For Processing: 

Consent and as Required by Law: 123Pro processes your Personal Information with your consent and as required by law. 

Contract: Users can enter into two different types of contracts through the 123Pro Platform: (1) a contract between service requesters and service professionals regarding professional services, and (2) a contract between the user and 123Pro whereby 123Pro facilitates the arrangement of the professional services contract in exchange for a share of the fee for the contracted professional services. To take steps necessary to respond to users’ requests to enter into both types of contracts, 123Pro processes Personal Information from service requesters, including contact information, services requested, and worksite location information, and from service professionals, including contact information, skills and experience, background check information, preferred times, and preferred locations. To facilitate the performance of the service professional agreement and to perform the contract with users, 123Pro must process Personal Information, including the service requester’s billing information, the service professional’s receivables information and geographic location information, and both parties’ text messages and phone calls through the 123Pro Platform. 

123Pro cannot facilitate service professional contracts through the 123Pro Platform or enter into contracts with users unless users provide this Personal Information. 

Legitimate Interests: 123Pro also processes Personal Information as necessary for its legitimate interests as follows: 

• Marketing and advertising: Unless you opt out as described below, we use your Personal Information as necessary to provide you information about the services that we think might interest you, in accordance with applicable law. 

• Network and information security, fraud prevention, and reporting suspected criminal acts: In the event of fraud, a security incident, or a suspected criminal act, we would examine Personal Information that appeared to be linked to the incident as necessary to determine what happened, remediate, report to the authorities, and prevent a recurrence. 

Right to Object to Processing for Direct Marketing or Legitimate Interests: 

EEA Individuals have the right to object to the processing of their Personal Information for purposes of 123Pro’s direct marketing or legitimate interests by contacting 123Pro at admin@123Pro.com

Automated decision-making: 

123Pro sometimes uses EEA Individuals’ Personal Information submitted through the Site for automated decision-making. For example, 123Pro may display advertisements and send emails to you containing content automatically chosen based on the services you have ordered through the 123Pro Platform in the past. However, 123Pro will not use EEA Individuals’ Personal Information submitted through the Site for automated decision-making, including profiling, which produces legal effects or similarly significantly affects the EEA Individual. 

Individual Rights: 

EEA Individuals have the right to access their Personal Information collected by the Site and to request that 123Pro update, correct, or delete their Personal Information as provided by applicable law. EEA Individuals also have the right to object to, or restrict, 123Pro’s processing of their Personal Information. 

In addition, EEA Individuals have the right to data portability concerning their Personal Information. Subject to certain limitations, the right to data portability allows EEA Individuals to obtain from 123Pro, or to ask 123Pro to send to a third party, a digital copy of the Personal Information that they provided to the Site. EEA Individuals’ right to access their Personal Information includes their right to receive a copy of all, or a portion, of their Personal Information in 123Pro’s possession as long as 123Pro’s providing the Personal Information would not adversely affect the rights and freedoms of others. 

f) Choice: How To Opt Out Of Collection Of Your Personal Information By 123Pro And Transfer To Third Parties 

123Pro may disclose EEA Individuals’ Personal Information transferred to the United States and Canada pursuant to the Privacy Shield to non-agent third parties as described in Section III above. In some cases, as described in Section III of this Privacy Policy, our third-party service providers may in turn share the Personal Information of 123Pro Platform users with other third parties. You may opt out of such disclosures and onward transfers by writing to admin@123Pro.com 

123Pro will offer EEA Individuals whose Personal Information has been transferred to the United States pursuant to the Privacy Shield the opportunity to opt out from: (a) the disclosure of their Personal Information to any non-agent third parties not already listed in Section III above and (b) the use of their Personal Information for purpose(s) that are not compatible with the purpose(s) for which the Personal Information was originally collected or subsequently authorized by the Individual. 123Pro will provide EEA Individuals with clear, conspicuous, and readily available mechanisms to exercise choice, should such circumstances arise. Any withdrawal will apply only prospectively, and 123Pro will continue to retain the Personal Information that EEA Individuals provided before they withdrew their consent for as long as allowed or required by applicable law. 

g) Access And Correction: How You Can Exercise Your Rights 

123Pro acknowledges EEA Individuals’ right to access and correct their Personal Information. Upon reasonable request, 123Pro will grant EEA Individuals reasonable access to their Personal Information and will permit them to correct, amend or delete Personal Information that is inaccurate or incomplete. EEA Individuals wishing to exercise these rights may do so by contacting admin@123Pro.com. Employees should contact their local manager to exercise these rights. 

h) Enforcement: What To Do If You Have a Complaint 

In compliance with the Privacy Shield Principles, 123Pro commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact 123Pro at admin@123Pro.com. 

123Pro has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. 

123Pro commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the EU DPA’s and Swiss FDPIC with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship. 

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction 

Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Contact details for the Swiss Federal Data Protection and Information Commissioner can be found at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection---switzerland.html 

In compliance with the Privacy Shield Principles, 123Pro commits to resolve complaints about our collection or use of employees’ Personal Information. Current or former employees with inquiries regarding the Privacy Shield or who wish to submit a complaint concerning the handling of their Personal Information should first contact 123Pro at: admin@123Pro.com. Current or former employees who are not satisfied with the internal resolution of a complaint may seek redress from the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner (the “Commissioner”), as applicable. 123PRo will cooperate in investigations by, and comply with the advice of, the panel and/or Commissioner with regard to an employee’s Personal Information transferred from the EU and/or Switzerland in the context of the employment relationship. 

123Pro is subject to the jurisdiction and enforcement authority of Canadian federal laws.

i) Liability 

123Pro may be liable for the onward transfer of EEA and Swiss Personal Information to agent third parties pursuant to the Privacy Shield unless we can prove that we were not a party to the actions giving rise to the damage. 

Cookies Policy 

Websites maintained by 123Pro (collectively the "Site") use a number of different cookies. This Cookies Policy explains the following:

- What are cookies?

- Cookies we use and why we use them

- E.U. user’s right to refuse cookies 

WHAT ARE COOKIES? 

Cookies are small files that are downloaded to your device when you visit a website. The cookie then sends information back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu. 

Cookies perform many different functions, such as letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience.

COOKIES AND WHY WE USE THEM 

Cookies can be categorized by who puts the cookie on the user's computer (or other device the user uses to browse the website).

First-party cookies are cookies placed by the party operating the website. For example, any cookies we (123Pro) place on your computer from our Site are first-party cookies. 

Third-party cookies are cookies placed from a website by a party that does not own or operate that website. 

We use only first-party cookies on our Site.

Cookies are also often categorized by function. We use four types of cookies by function on our Site:

1. Essential Cookies 

These are cookies that are strictly necessary for the functioning of the website or for performing services that an individual user has requested. For example, we use a cookie that remembers that you are logged into the Site until you log out.

2. Analytical Cookies 

These cookies collect information about how visitors use a website — for instance, which pages visitors go to most often, and whether visitors get error messages from web pages. Analytical cookies don't collect information that identifies a visitor. All information that analytical cookies collect is aggregated and therefore anonymous. These cookies are used only to improve how a website functions.

We use cookies provided by third-party service providers, including Google Analytics, Optimizely, and New Relic, to help us analyze how users use the Site.

The Google Analytics cookies collect data tied to a user's IP address, 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 the Site. You can object to the collection of your information by Google Analytics by clicking here. We place cookies provided by Optimizely to test whether changes we have made to the Site work properly. 

Like the cookies provided by Google Analytics and Optimizely, the cookies provided by New Relic collect information about your visit to the Site, such as delays you might experience when using Site features. The New Relic cookies assign an identification number, called a "session ID", to your visit to our Site. Information collected about your visit is sent to New Relic and tied to the session ID. Each visit generates a new session ID, and session IDs between different visits are not linked to identify you. New Relic deletes the session ID at the end of your visit.

The cookies provided by each third-party service provider send the information they collect to that third-party service provider. For example, the cookies provided by Google Analytics send information about your Site interactions to Google Analytics. Each third-party service provider then compiles aggregated data using the information received and sends us reports on the aggregated data. These reports are not shared with other parties. We use the reports to offer better Site experiences and tools in the future.

Although these cookies provide information to the third-party service providers, they are first-party cookies because we place them ourselves.

3. Functional Cookies 

These cookies allow the website to remember choices users make and to provide enhanced, personalized features. For example, we use cookies provided by Olark.com that allow you to continue chatting with customer support when navigating between pages.

4. Targeting/Advertising Cookies 

Targeting/advertising cookies are cookies used to deliver advertisements relevant to the user. They remember that a user has visited a website and share this information with other organizations, such as advertising vendors.

Cookies in this category may include Remarketing Cookies. These are cookies that remember that you visited our Site after you leave. Sometimes they collect information about what pages of our Site you visited. They then share this information with our third-party vendors, such as AppNexus, Google, Nanigans, Facebook, and Twitter. Based on this information, the third-party vendors show you advertisements on third-party websites for 123Pro products that we think may interest you based on what you viewed on our Site.

You may opt out of Google's use of cookies by visiting Google's Ads Settings here. You can also opt out of the use by other third-party vendors, such as AppNexus, of information from cookies placed by the Site by visiting the Network Advertising Initiative opt-out page. However, not all of our third-party vendors participate in the Network Advertising Initiative opt-out page. 

Cookies can also be categorized by how long they remain on your device. There are two broad categories of duration:

1. Persistent cookies 

Persistent cookies remain on your device until deleted manually or automatically.

2. Session cookies 

Session cookies remain on your device until you close your browser when they are automatically deleted.

We use both session and persistent cookies on our Site.

Location of information processing: 

The information collected by our cookies is processed in servers located in the United States and in Canada.

E.U. USERS' RIGHT TO REFUSE COOKIES 

Users in the European Union (E.U.) have the right to refuse to allow cookies to be placed on the device they use to access the Site. We describe below how E.U. users can reject cookies used by our Site.

Rejecting Cookies Through Browser Settings: 

The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. For more information on using browser settings to reject cookies, please visit www.allaboutcookies.org. 

You should note that rejecting cookies in your browser settings may mean that any preferences you set on this Site will be lost and that the Site may not work as well. In addition, using the browser settings to reject cookies may also cause your browser to reject cookies from all websites, not just this Site.

HAVE QUESTIONS? 

If you have any questions about our Cookie Policy, we'll do our best to answer them. You can email us at admin@123Pro.com 

COOKIE POLICY UPDATES 

If we change our Cookie Policy, we will post those changes on this page and update the Cookie Policy modification date above. If we materially change this Cookie Policy in a way that affects how we use or disclose your personal information, we will notify you by prominently posting a notice of such changes before making them and by stating the effective date of the changes.

CHANGE TO THIS PRIVACY POLICY 

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date below. If we materially change this Privacy Policy in a way that affects how we use or disclose your Personal Information, we will notify you by prominently posting a notice of such changes before making them and by stating the effective date of the changes.