Privacy Policy

State Specific Consumer Privacy Rights

Last updated: December 23rd, 2024

This Privacy Policy describes how Rex Direct Net, Inc., (“the Company”, “We”, “Us” or “Our”) policies and procedures on the collects, uses, protects, and discloses your Personal Data (defined below) and how to exercise any rights you might have with respect to this data. It governs information We collect through Our website (walkintubadvice.com) (“Site”) and information We collect from you or third parties through any other means to provide Our services or perform other business activities (collectively, “Services”). The Site and Services are intended only for United States residents. This Privacy Policy does not apply to Personal Data We collect from or about job applicants, employees, or independent contractors.

Please read this Privacy Policy, which is part of, and incorporated into, our Terms and Conditions, before using the Site or Services. By using the Site and/or Services, you agree and acknowledge that you read, understand, and agree to be bound to our Privacy Policy and Terms and Conditions and you agree to our use of your information consistent with the Terms of Use and this Privacy Policy, subject to your rights described below. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE EXIT THIS PAGE AND DO NOT ACCESS OR USE THIS SITE OR SERVICES.

NOTICE AT COLLECTION

DATA WE COLLECT

Personal Data

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Data”), including:

Some of the Personal Data listed above may be considered Sensitive Personal Data under relevant privacy laws. This includes health information, precise geolocation information, and sex life or sexual orientation. Each type of Sensitive Personal Data may overlap with a category of Personal data listed above.

The type of Personal Data We collect about you may vary based on how you use Our Sites and/or Services and your relationship with Us.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on Our Site (“Usage Data”). For example, each time you use this Site, We may collect internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, and HTTP headers from your browser. Among other things, this data helps Us estimate Our audience size and usage patterns, recognize you when you return to Our Site, store information about your preferences, customize Our Site according to your interests, and speed up your searches. If the data We automatically collect is capable of being associated with you, directly or indirectly, We treat it as Personal data under the categories of Identifiers or Internet or other electronic network information, as appropriate. If this information is not capable of being individually associated with you, We treat it as Usage Data.

Communication Recordings

We may record and retain calls and the contents of your interactions with us, including web forms, chat transcripts, session use, or other written/electronic communications between you and us. By communicating with us, you consent to Our recording and retention of communications.

Deidentified Information

We may anonymize or aggregate Personal Data so that it is no longer capable of being associated with you in which case it will be considered “Deidentified Data”. We will not attempt to reidentify you or any other person from Deidentified Data. We may use and disclose Deidentified Data for any purpose without restriction.

USE OF PERSONAL DATA

We may use Personal Data, including Sensitive Personal Data, for general business purposes, including:

We may also use Personal Data and/or Sensitive Personal Data as described to you at the point of collection, with your consent, or as otherwise required or permitted by applicable laws.

Some products and/or services offered may ask for consent for a soft pull credit inquiry. If that is the case, we will ask you for the following types of information: contact information (such as name, address, phone number, and email address) and the option to consent. You understand by providing consent, you agree you are authorizing and providing written instructions for Us to obtain your credit profile from any consumer reporting agency which can be used to evaluate your financial history for the purpose of providing you with targeted offers based on your credit profile.

By providing consent, you are providing “written instructions” to Us and its employees, agents, subsidiaries, affiliates, contractors, third party data sources and suppliers, and all other credit reporting agencies under the Fair Credit Reporting Act (FCRA), as amended, to access your credit files from each national credit reporting agency and to exchange information about you with each such national credit reporting agency in order to verify your identity and to provide the products and/or services to you. You agree and hereby authorize Us, its agents and employees, to provide your personally identifiable information to third parties as provided in this Privacy Policy, as may be amended from time to time, You waive any and all claims against Us and its agents and employees for the acts or omissions of these third parties with regard to the use or disclosure of such information. A soft pull credit inquiry will not negatively impact your credit score and are only visible to you. Soft pull inquiries may be reflected on your credit report for up to two years.

Third-Party Selling and Sharing

We may sell or share your Personal Data with other companies who may not be considered Service Providers (“Third Parties”), These companies may use your Personal Data for their everyday business purposes, including marketing, customer service, fulfillment, and related purposes. In the past 12 months We sold and shared Personal Data as follows:

• Network Partners – we sold and shared Identifiers, Characteristics of Protected Classifications Under California or Federal Law, Geolocation Information, Commercial Information, Internet or Other Electronic Network Activity Information, Professional or Employment Information and Consumer Inferences
• Targeted advertising, social media, and analytics companies – We sold and shared Identifiers, Characteristics of Protected Classifications Under California or Federal Law, Geolocation Information, Commercial Information, Internet or Other Electronic Network Activity Information, Professional or Employment Information and Consumer Inferences for the purposes described above. These companies may use your Personal Data for additional purposes outlined in their privacy policies.
• Business Partners – We may share your subscriber information which includes your Identifiers, Characteristics of Protected Classifications Under California or Federal Law, Geolocation Information, Commercial Information, Internet or Other Electronic Network Activity Information, Professional or Employment Information and Consumer Inferences, with our business partners. The business partners include general business partners, affiliates, and joint venture partners. We share this information with them so that they can send you information about our products and services as well as third party products and services. When you choose to take part in our services and/or offerings, you are authorizing us to provide your email address and subscriber information you have entered to our business partners. You may adjust your subscription at any time via links provided in any email that you receive.

RETENTION OF YOUR PERSONAL DATA

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

OTHER PRIVACY DISCLOSURES

HOW WE COLLECT DATA

Directly From You

We may ask you to provide Us with Personal Data when you communicate with Us online or offline, including web forms, marketing or promotional programs, and in connection with a product/service offered by Our Affiliates (an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for the election of directors or other managing authority) or Network Partners We may also capture your contact information, such as phone numbers and email addresses when you contact us.

Third-Party Data Sources

We may collect Personal data from third-party data sources such as Network Partners, Marketing & Data Analytic Partners, and Service Providers that interact with Us in connection with existing Website visitor information, the Website function and the Services We perform. We may receive additional Personal Data from third party sources that we may append to existing consumer information, such as email, phone number and address verification. We use this supplemental information to better understand our consumers, deliver relevant offers and advertising, and improve our services.

When you request select Services, We may ask for your consent to conduct a soft credit pull to obtain your credit score and debt amount from your personal credit report and other information about you from each consumer reporting agency in order to verify and confirm data you have already provided to connect you with the appropriate network partner to provide the services you request. You understand that a soft credit pull will not negatively impact your credit score and may be reflected on your credit report for up to two years. By giving your consent, you are providing “written instructions” to Us under the Fair Credit Reporting Act (FCRA), as amended, to access your Account Information from each national consumer reporting agency about you. You also agree and hereby authorize Us to transmit your information to Our authorized service providers as provided in this Privacy Policy as necessary to provide you with the Services you have requested. This information will not be shared or disclosed to any non-affiliated third party. We will only use this information for verification and confirmation purposes.

Tracking Technologies and Cookies

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as pixels to track your interaction with Our Site and to improve the experience of Our Site and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of Our Sites may not work if you delete or disable cookies.

We use the following types of cookies:

• Strictly Necessary: These cookies are essential to operate the Sites and provide you with services you have requested.

• Functional: These cookies enable certain features or non-essential functionality on Our Sites. For example, We might use these cookies to recognize you and remember your preferences or settings when you return to Our Sites so We can provide you with a more personalized experience.

• Advertising Cookies: These cookies allow Us and third parties to learn more about you, including your use of Our Sites and other websites, and advertise products or services that might interest you as further indicated below.

• Analytics Cookies: These cookies help Us and third parties understand how Our Sites are working and who is visiting Our Sites.

We and third parties also use tools that enables Us to track certain aspects of a user’s visit to Our Sites. This technology helps Us better manage content on Our Sites by informing Us what content is effective, how consumers engage with Our Sites, and how consumers arrive at and/or depart from Our Sites. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether a user views a web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.

If you arrive at Our Sites by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you searched that led you to Our Sites, may be transmitted to Us and We may use it. You should review the Privacy Policy of any website from which you reached Our Sites to determine what information the operator collects and how it uses such information. We may retain information about you provided to Us by other websites and will use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

We do not use technology that recognizes “do-not-track” signals or global privacy settings from your web browser because this Service relies on sharing your information to function and we do not track users other than for aggregate statistical purposes.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Trusted Form and Jornaya

We use ActiveProspect’s TrustedForm and/or Jornaya’s Lead ID Script to independently document users’ consent to be contacted. These scripts may be embedded on our website and collect the following information when you interact with the page(s) where the script is present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user’s computer, time on the page, date and time that the script was loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user’s browser. For more information about ActiveProspect’s data use and collection policies and practices, please review the ActiveProspect Privacy Policy, located at https://activeprospect.com/privacy-policy/. For more information about Jornaya’s data use and collection policies and practices, please review the Jornaya Privacy Policy, located at https://marketing.verisk.com/privacy-policy-jornaya/.

Marketing Opt-Outs

We or authorized third parties acting on Our behalf may use your Personal Data to contact you via email with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or by contacting Us.

DISCLOSURE OF DATA

Service Providers

We may provide your Personal Data to other businesses to provide services to Us or on Our behalf (“Service Providers”). Categories of Service Providers We use include:

• Fulfillment and account servicing vendors, which help Us provide products, services and information to you, service your account or benefits, and collect past due balances;

• Payment processors, which help Us to accept and process the payments for Our products/services to you;

• Marketing and communications vendors, which help Us market Our products/services to you, conduct promotions, surveys, and other outreach campaigns;
• Consumer credit vendors, which help Us verify your credit history which can be evaluated for the purpose of providing you with targeted offers based on your credit profile.
• Verification vendors, which help Us verify and validate the information you have provided to Us for accuracy to fulfill our services and improve Our advertising and marketing;

• Research and development vendors, which help Us develop and improve Our products and services;

• Data and business analytics vendors, which help Us collect, analyze, and improve the accuracy of Our data (including Personal Information), and the activities of visitors to Our Site;

• IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;

• Information management providers, which provides services that append data to our existing consumer records. We use this information to better understand our site visitors, deliver relevant offers and advertising, and improve our Services, advertising and marketing campaigns.

• Professional service firms, which provide accounting, legal, auditing, and other professional services; and

• General service providers, which help Us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.

We require each Service Provider to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Data from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Data We provide to them other than as specified by us.

In the past twelve months We may have disclosed each category of Personal Data that We collect (listed above) to Service Providers.

Other Third-Party Disclosures

We may occasionally disclose your Personal Data to Third Parties, for purposes such as:

• To comply with the law;
• To respond to legal requests (including court orders, investigative demands and subpoenas) if, in Our discretion, We believe it is necessary or appropriate;
• To prevent or stop any illegal, unethical, or legally actionable activity;
• To protect the safety, property, or rights of ourselves, consumers, or any other third party;
• If We are merged, acquired, or sold, or in the event of a divestiture, restructuring, reorganization, or transfer of some or all of Our assets and the disclosure is necessary to complete the transaction;
• To businesses controlling, controlled by, or under common control with us; and
• For additional purposes with your consent where such consent is required by law.

In the past twelve months, We disclosed Identifiers to third parties in connection with proposed or finalized corporate transactions.

PERSONAL DATA WE COLLECT AS A SERVICE PROVIDER FOR OUR CLIENTS

When acting for companies on whose behalf we perform work as a service provider (“Clients”), we may collect, use, and disclose Personal Data for the purpose of servicing those Clients. The specific categories of Personal Data collected and how that Personal Data is used or disclosed is determined by our Clients and will vary.

The Personal Data collected, used, and disclosed on our Clients’ behalf is governed by their privacy policies. When acting on behalf of a Client, we supply that Client with all information requested by them or consistent with their contract. This information is usually what is required to facilitate a specific transaction but can vary depending on the Client. If you request information about the Personal Information we collect, use, and disclose on our Clients’ behalf, we will direct you to contact the Client(s).

TRANSFER OF YOUR PERSONAL DATA

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Data.

SECURITY OF YOUR PERSONAL DATA

The security of your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, We cannot guarantee its absolute security.

If you are a resident of California, Colorado Connecticut, Nevada, Virginia or Utah, you may have additional rights to access and control your Personal Data. Exemptions may apply. Consumer privacy rights for residents of these states include:

Right to Opt-Out from the Sale or Sharing of Personal Data

You have the right to direct Us not to sell or share (for targeted or cross-context behavioral advertising purposes) your Personal Data to Third Parties. We will process requests within 15 business days, subject to any applicable exceptions and extensions permitted by law.

To opt-out of the sale of Personal Data you can contact Us or fill Our this FORM HERE. Additionally, Service Providers We partner with (for example, Our marketing and data analytic partners) may use technology on the Service that “sells” Personal Data as defined by applicable law.

If you wish to opt out of the use of your Personal Data for interest-based advertising purposes and these potential sales as defined under applicable law, you may do so by following the instructions below. Please note that any opt out is specific to the browser you use. You may need to opt-out of every browser that you use.

Mobile Devices
Your mobile device may give you the ability to opt-out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

Right to Know

You have the right to request twice per 12-month period that We provide you (i) the categories or specific pieces of Personal Data We collected about you; (ii) the categories of sources from which We collected your Personal Data; (iii) the business or commercial purpose for which We collected your Personal Data; and (iv) the categories of Third Parties with whom We sold, shared, or disclosed your Personal Data. including the categories of Personal Data sold, shared, or disclosed to each and the purposes for doing so. We are not permitted to provide access to specific pieces of Personal Data that creates a high risk of potential harm from disclosure to an unauthorized person such as social security numbers and driver’s license numbers. To protect consumers’ Personal Data, you must provide required information and/or documentation to verify your identity. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law.

Right to Delete

You have the right to request that We delete any Personal Data We have collected about you. Please understand that We are not required to honor a deletion request if a legal exemption applies such as if We need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. To prevent unauthorized individuals from making deletion requests, you must provide required information and/or documentation to verify your identity. We will retain a copy of your deletion request for at least two years as required by law.

Right to Correct

You have the right to request that We correct inaccurate Personal Data We maintain about you. After you request to correct inaccurate Personal Data, We will provide instructions for you to provide Us with optional documentation to support your request and We will consider it. We may decline to correct your Personal Data if a legal exemption applies such as if We determine that your request is fraudulent or abusive or if We determine, based on the totality of the circumstances, that your correction is more likely inaccurate than accurate. We may decide to delete your allegedly inaccurate Personal Data instead of correcting it. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law.

Right to Appeal

You have the right to appeal Our decision to deny, in full or in part, one or more of your privacy requests. We will process appeal requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law. If We deny your appeal, We will provide you with a written explanation of the reasons for Our decision. If you are not satisfied with Our explanation for the denial of your appeal, you may have an additional right under certain laws to contact your state Attorney General to submit a complaint about the appeal results. In such case, We will provide you with instructions for doing so.

Submitting a Request

If you are a California, Colorado, Connecticut, Nevada or Virginia resident and would like to exercise your rights, you may submit a request through our online privacy request form.

Authorized Agent

If you are an authorized agent submitting a request for another consumer, you must provide a copy of a lawful power of attorney or written authorization from the Consumer (along with proof of your identity). You will be provided options on how to provide this documentation after submitting the request. We may contact you or the Consumer on whose behalf you claim to act to verify your authorization.

Right to Non-Discrimination

We do not discriminate against person who exercise any of their rights described in Our privacy policy.

CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We will immediately take steps to remove that information from Our servers.

LINKS TO OTHER WEBSITES

Our Service may contain links to other websites that are not operated by Us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

CONFLICT BETWEEN THIS POLICY AND LOCAL LAWS AND REGULATIONS

When federal, state, and local laws and regulations require a higher level of protection for your Personal Data, they take precedence over this Privacy Policy. The specific requirements of this Privacy Policy apply unless disallowed by local laws and regulations.

CHANGES TO THIS PRIVACY POLICY

We may update Our Privacy Policy at any time. You are advised to review this Privacy Policy frequently for any revisions. Unless otherwise stated, changes to this Privacy Policy are effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of Our Sites or Services. If We determine that a change to this Privacy Policy will result in using your Personal Data acquired before the change in a materially new way, We will provide you notice before using your Personal Data in the new way. You are responsible for ensuring We have an up-to-date active and deliverable email address for you, and for periodically visiting the Sites and this Privacy Policy to check for any changes. The date the Privacy Policy was last revised is identified at the top of the page.

CONTACT US
If you have any questions about this Privacy Policy, you can contact us!