Last Updated: October 15, 2021
important to us, and we respect and protect the privacy of Our online
visitors. Listed below is information regarding the collection, management,
use, and disclosure of Your information given to Us or gathered by Your use
of the Service. By using the Service, You agree to all that is set forth in
Note: These words have the same meaning regardless of whether they appear
in singular or plural form.
1.1. “Account” shall mean a unique profile created for You to
access our Service.
1.2. “Company” shall mean Valmont Telecommunications, Inc.,
located at 1525 Pidco Drive, Plymouth, IN 46563, and may be referred to as
1.3. “Consumer”, for the purpose of the California Consumer
Privacy Act (CCPA) shall mean a natural person who is a California
resident, as defined in Section 17014 of Title 18 of the California Code of
Regulations. Section 17014 of Title 18 of the California Code of
Regulations, defines the term “resident” as the following:
“The term “resident,” as defined in the law, includes (1)
every individual who is in the State for other than a temporary or
transitory purpose, and (2) every individual who is domiciled in the State
who is outside the State for a temporary or transitory purpose. All other
individuals are nonresidents.” 18 CRR § 17014.
1.4. “Cookies” shall mean the text files containing small
pieces of information and data that are used by websites to identify You
and Your Device.
1.5. “Device” shall mean any device that can access the Service
such as a computer, laptop, cellular device, or an electronic tablet.
1.6. “Do Not Track” or “DNT” is a concept promoted
by U.S. regulatory authorities to encourage and assist in the development
and implementation of a mechanism that allows those who use the internet to
control websites tracking their online activities.
1.7. “Personal Data” shall mean any information that relates to
an identified or identifiable individual.
For the purposes for General Data Protection Regulation (GDPR), Personal
Data means any information relating to You such as Your name, ID numbers,
information regarding your location, online identifiers or to one or more
factors specific to Your physical, physiological, genetic, mental,
economic, cultural, or social identity.
For the purposes of the California Consumer Privacy Act (CCPA), as set
forth in Section 1789.140 of CCPA, Personal Data means “means
information that identifies, relates to, describes, is capable of being
associated with, or could reasonably be linked, directly or indirectly,
with a particular consumer or household.” CCPA § 1789.140.
1.8. “Service” shall refer to the Website, and any related
1.9. “Service Provider” shall mean any legal personal or
natural person who processes data on Our behalf such as third-party
companies or individuals, who are employed by Us, to help in the running
and management of the Service, performance of services, and analysis of the
use of Our Service.
1.10. “Usage Data” shall mean data that is automatically
collected by using the Service or from the Service itself (i.e., how long a
particular webpage is visited).
1.11. “Website” shall refer to the SP1 Data website,
which can be accessed at: https://www.sp1data.com/
1.12. “You” shall mean the individual, company or other legal
entity accessing the Service on the individual’s behalf if
applicable, who is accessing the Service.
2. COLLECTION AND USAGE OF PERSONAL DATA
2.1. Types of Data Collected
When You use the Service, You may be asked to provide Us with information that can identify You personally.This information may include, but is not limited to the following:
- Email Address
- First Name and Last Name
- Phone Number
- Address, State, Province, ZIP/Postal Code, City, Country
- Usage Data
Usage Data may include information such as Your IP address, the type of
internet browser You are using and its current version, the webpages of our
Service that You visit, the time and date of Your visit to the Service, the
time You spend on those pages of our Service, any unique device
identifiers, and other diagnostic data.
Note that when Our Service is accessed on a mobile device, certain
information may be collected automatically from you, including, but not
limited to the following: the type of mobile device You used to access the
Service, Your mobile device’s unique ID, the IP address of Your
mobile device, Your mobile operating system (e.g., iOS, Android), the type
of mobile Internet browser used to accessed, any unique device identifiers,
and other diagnostic data.
The Company may also collect information sent by Your browser when visiting
our Service or accessing Our Service on a mobile device.
Tracking Technologies and Cookies
The Service uses a variety of Cookies and other tracking technologies to
track the activity of users, including You, and certain collected
information is stored. We use the tracking technologies of beacons, tags,
and scripts to track and collect information, as well as for the
improvement and analytics of the Service. Please note that if You do not
accept Cookies, You may not be able to use some parts of our Service. If
2.2. Use of Personal Data
Using Your Personal Data
We may use Your Personal Data for the following purposes:
- Providing the Service
- Maintaining the Service
- Monitoring usage of the Service
- For contract performance, namely, for the development, compliance
and undertaking of the purchase contract for the products, items, or
services You have purchased or of any other contract with Us through the
- To manage and attend to requests from You.
- To manage user Accounts.
- To contact You, which can be done via email, telephone calls, SMS,
or other equivalent forms of electronic communication, such as push
notifications informing You about updates or other informative
communications related to the functionalities, products, or contracted
services, including the security updates, when necessary or reasonable for
- Unless You opt out of receiving the following, to provide You and
other users with news, offers, and info about other goods, services, and
events which the Company offers similar to those that You have shown
interest in or have purchased.
- For advertising and targeted advertising, both physical and
digital, which may be sent to You. We may use Your information for the
development of tailored advertising specifically for You and/or Your
physical location. We may also work with third-party vendors for the
development of these tailored and targeted advertisements. This information
can also be used to measure advertising effectiveness.
- To determine the feasibility and possible successes of a business
transfer, namely, We may use Your information in analyzing or going through
a merger, divestiture, restructuring, reorganization, dissolution, or some
other sale or transfer of Our assets, whether in part or in full, due to
bankruptcy or liquidation, or other similar process, in which your Personal
Data may be part of assets transferred during that process.
- We may use Your information for other purposes, such as for
analysis and identification purposes, such as for analyzing usage trends,
analyzing the success of our promotional and advertising campaigns and to
analyze, evolve, and improve our Service, products, services, marketing and
Sharing Personal Data
We may share Your personal information with the following people, groups of
people, and companies:
- Service Providers. We may share Your personal information with
third-party Service Providers to assist us in general business practices,
the management and upkeep of our Service, for marketing and advertising
purposes, assist in our efforts to advertise on third party websites to You
after You visited our Service, to monitor and analyze the use of our
Service, for payment processing, and to contact You.
- Business Opportunities/Transfers. We may share or transfer Your
personal information in connection with, or during negotiations of, any
merger, sale of Company assets, financing, or acquisition of all or a
portion of Our business to another company.
- Affiliates and Business Partners. We may share Your information
with Our affiliates. If we do, Our affiliates are instructed to follow Our
under Our control other than the Company, Our parent company, and any other
subsidiaries. Further, We may share Your information with Company’s
business partners to offer You certain products, services, or promotions.
- Other Users. When You share personal information or otherwise
interact in the public areas, including on the Service, with other users,
such information may be viewed by all users and may be publicly distributed
- To Others With Your Consent: We may disclose Your personal
information to any others for any other purpose with Your consent.
2.3. Retaining Your Personal Data
Your Personal Data is retained by the Company only for as long as is
require the retention of data. We will retain and use Your Personal Data to
the extent necessary to comply with legal obligations and for internal
2.4. Transfer of Personal Data
Your information, including Personal Data, is processed at the Company's
operating offices and also may be processed at the locations of third-party
Service Providers, and in any other places where the parties involved in
the processing are located. Note that it is impossible for us to completely
guarantee the safety of user data, including your Personal Data, and by
using the Service You acknowledge that any transmission of their personal
data is at Your own risk.
2.5. Disclosure of Personal Data
We may disclose personal information, usage data, message data, and any
other information about you, if we deem that it is reasonably necessary to:
(a) satisfy any applicable law, regulation, legal process (such as a
subpoena or court order), or enforceable governmental request; (b) enforce
(c) detect, prevent, or otherwise address fraud, security or technical
issues; (d) protect against harm to the rights, property or safety of the
Company, its users or the public, as required or permitted by law; (e) if
the company is involved in a merger, acquisition, or asset sale; or (f) in
the good faith belief that such action is necessary to comply with a legal
obligation, to Protect and defend Our rights or property, to prevent or
investigate possible wrongdoing in connection with the use of Our Service,
to protect the personal safety of users of Our Service or the public, and
to protect Us from legal liability.
3. PERSONAL DATA PROCESSING DETAILS
We use third-party Service Providers for the processing and analysis of
Your Personal Data. Because of this, these Service Providers may have
access to Your Personal Data. Our Service Providers collect, store, use,
process, and transfer data and information about You, specifically Your
activity on Our Service. They collect, store, use, process, and transfer
Your Personal Data in accordance with their own privacy policies.
To monitor and analyze the use of Our Service, We may use third-party
Service Providers to better understand our users and those who use Our
Service. These third-party Service Providers track and report website
traffic; this collected analytical data is then used to analyze the use of
Our Service. The data that is collected may be shared with other services
operated by the third-party Service Providers, and may use this collected
data for targeted advertisements and marketing on their own services.
3.2. Email Marketing
We may use Your Personal Data to send You newsletters, marketing,
advertisements, or other promotional materials, as well as other
information You may be interested in receiving. To opt-out of some or all
communications of this sort, You can follow the unsubscribe link found at
the bottom of any email We send to You, or emailing us via the contact
use Email Marketing Service Providers for the sending and management of
emails, to be sent to Our users, including You.
3.3. Behavioral Remarketing
Remarketing services aid in the identification of user behavior on a
website, and assist in identifying what advertisements would be of interest
to a user based on their browsing behavior. We may use these remarketing
services and work with third-party vendors to help us understand how You
use our Service, and help us to recognize the Device or Devices you have
used in the past to improve our ability to show You more uniquely tailored
advertisements after You leave Our Service. Use of behavioral remarketing
enables Us to analyze traffic to our Service and user activity while using
the Service, show advertisements of our goods and/or services to You on
other websites or applications after You leave Our Service, and to measure
the success of Our advertising campaigns.
non-cookie technology to accomplish these goals. They collect, store, use,
process, and transfer information about Your use and activity on the
Service in accordance with their own privacy policies.
Note that we may share specific information such as email addresses or
other online identifiers collected by Us or by these third-party behavioral
remarketing vendors, which allows personalized ads to be displayed to you
across multiple browsers and devices.
4. GENERAL DATA PROTECTION REGULATION (GDPR)
“Data Controller”, for the purposes of the General Data
Protection Regulation (GDPR), shall refer to the Company as the legal
person which alone or jointly with others decides reasons for and means of
processing Personal Data. For purposes of the General Data Protection
Regulation, the Company is the Data Controller.
“Service Provider” shall be defined as set forth in Section 1.9
Regulation (GDPR), Service Providers are considered Data Processors.
“You” shall be defined as set forth in Section 1.12 of this
Protection Regulation (GDPR), You can be referred to as the Data Subject,
or as the User since you are the individual using the Service.
4.1. GDPR Rights
have the right to the following rights:
Right to Be Informed. You have the right to be informed of what data is
being collected on You. This information is located throughout this Privacy
- Right of Access. You have the right to access the information We have
about/on/regarding You. In many instances, You can access Your Personal
Data directly within the Settings section of Your account. If you are
unable to perform these actions yourself, please contact Us as set forth in
Data We have on You through Your Account settings page.
- Right to Object & Right to Restrict Processing. You have the right
to limit the way We use Your Personal Data, and You have the right to
challenge and object to the way We use your Personal Data for direct
marketing purposes. You also have this right when We are relying on a
legitimate interest as the legal basis for Our processing of Your Personal
Data, and You are in a particular and special situation that causes You to
object because of this situation.
- Right of Rectification. You have the right to update and correct the
incomplete or inaccurate information We have on You. When possible, You can
update Your Personal Data directly within the settings section of Your
Account. If you are unable to perform these actions yourself, please
contact Us to assist You at the contact information set forth in Section 9
have on You through Your Account settings page.
- Right to Be Forgotten. You have the right to delete the information We
have on You when there is no longer a good reason for Us to continue
processing it. When possible, You can delete Your Personal Data directly
within the settings section of Your Account. If you are unable to perform
these actions yourself, please contact Us to assist You at the contact
find a copy of the Personal Data We have on You through Your Account
- Right of Portability. You can request that We transfer any information
we have on You to another organization or company. This information will be
in a structured, commonly used, and machine-readable format. Note: this
right only applies to automated information that You initially consented
for Us to use or when We used Your information for the performance of a
contract We have with You.
- Other Rights Related to Automated Decision-Making. You have the right to
ask Us for a copy of Our automated processing activities if You believe
Your data and information is being processed unlawfully.
- Right to Withdraw Consent. You have the right to withdraw the consent
You gave regarding the use of Your Personal Data. However, if you withdraw
this consent, some features of Our Service may be inaccessible by you.
4.2. Exercising These GDPR Rights
You can exercise the Rights of Access, Rectification, Objection, and
Deletion by contacting Us at the contact information set forth in Section 9
verified before We can process Your requests. We will respond to Your
requests promptly to the best of our ability.
5. CALIFORNIA RESIDENTS
users, and others who are residents of the State of California, and
5.1. California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act requires that We make specific
disclosures for residents of the State of California.
“Business”, for the purposes of the California Consumer Privacy
Act (CCPA), shall refer to the Company “legal entity that is
organized or operated for the profit or financial benefit of its
shareholders or other owners, that collects consumers’ personal
information, or on the behalf of which such information is collected and
that alone, or jointly with others, determines the purposes and means of
the processing of consumers’ personal information, that does business
in the State of California.” See CCPA § 1789.140(c) for more
information on the definition of “Business.”
Rights under the CCPA
The California Consumer Privacy Act provides residents of the State of
California specific rights regarding personal information. Residents of
California, You have the following rights:
- You have the right to know the purposes Your Personal Data are
- You have the right to request that We tell you about Our
collection, use, disclosure for business purposes, sale, and sharing of
personal information. When We receive Your request, We will disclose to You
to the following regarding personal information about You:
- Categories of personal information We collected
- The specific pieces of personal information we collected
- Categories of sources from which We collected the personal
- Categories of third parties with whom we have shared Your personal
- Our business purposes/commercial purposes for collecting/selling
Your personal information. If We sold personal information about You, or
disclosed personal information about You for a business purpose, We will
disclose the categories of personal information We sold, and/or the
categories of personal information We disclosed.
- You have the right to opt-out of the sale of Your personal
information. If you want to exercise this right, please contact Us by
following the contact information set forth in Section 9 of this Privacy
- You have the right to delete Personal Data We have on You. However,
there are certain exceptions to this right. Upon receiving your request for
deletion of Your Personal Data, We will delete Your personal information
and We will also instruct Our Service Providers to delete Your personal
information from our records, unless an exception applies. Please note that
We may deny Your request to delete Your Personal Data from our Records if
We or Our Service Providers still require the Personal Data to do any or
all of the following:
- To complete the transaction that was the very purpose We collected
the personal information, such as to provide a good or service that You
requested from Us, to take actions anticipated within the context the
business relationship between You and Company, or to otherwise perform our
contractual obligations to and with You.
- To prevent malicious, fraudulent, deceptive, or illegal activity,
to detect security incidents, or for other legal purposes.
- To debug Our products, services, or Service in order to identify
and repair errors that impair the functionality intended of our products,
services, or Service.
- To exercise our or another consumer’s rights under the law,
including the right of free speech.
- For public or peer-reviewed scientific, historical, or statistical
research in the public interest.
- To allow for internal uses that are reasonably aligned with
consumer expectations based on Your relationship with Us.
- To comply with a legal obligation by which we are obliged to
fulfill., including compliance with the California Electronic
Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Other lawful and internal uses.
- You have the right to not be discriminated against for the
exercising of Your rights as a consumer.
Sources of Personal Information
The Company is able to collect the information listed in section i. above
from the following sources:
- Directly From You. For example, You input information into Our
Service by filling out a form.
- Indirectly From You. For example, information We are able to gather
from observing Your activity on Our Service.
- From Service Providers. For example, information about
advertisement success from our third-party vendors.
Use of Personal Information for “Business Purposes” or
Some information may be used or disclosed for “business
purposes” or “commercial purposes” as set forth and
defined in the CCPA. The following is a list of examples of “business
purposes” and “commercial purposes”. This list is just a
list of examples to help illustrate “business purposes” and
“commercial purposes”. This list is not exhaustive, and We
encourage you to refer to the “Use of Your Personal Data”
- Operation of our Service and providing You with our Service.
- Responding to inquiries We receive from You and other support.
- Fulfillment of or meeting the reason You provided the information.
- Responding to requests from law enforcement, and responding to
other requests and inquiries required by applicable law, court order, or
other governmental regulations.
- When You provide information to Us, and We describe a business or
commercial purpose, or as otherwise set forth in the California Consumer
- Internal auditing purposes.
- Internal administrative purposes.
- Security incident detection, protection, and prosecution against
fraud, deception, malicious, or other illegal activity.
Sale of Personal Information
“Sell” or “sale” within the context of the CCPA is
defined as the following: “selling, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise communicating
orally, in writing, or by electronic or other means, a consumer’s
personal information by the business to another business or a third party
for monetary or other valuable consideration.” CCPA § 1789.140
The following is a list of the categories of personal information that may
have been, is being, or will be sold by Us. This list does not mean that
all of the following information has been, is being, or will be sold by us,
but is rather a list set forth by the CCPA, and this is our good faith
effort to let you know what could be or could have been sold:
- Category A: Identifiers
- Category B: Personal Information Categories set forth in Cal. Civ.
Code § 1798.80(e)
- Category D: Commercial Information
- Category F: Internet Activity
Sharing of Personal Information
Payment processors, Service Providers, Our business partners and affiliates, and third-party vendors in connection with providing our goods and services are the third parties with whom We may share Your personal information.
Sharing of Personal Information
Payment processors, Service Providers, Our business partners and
affiliates, and third-party vendors in connection with providing our goods
and services are the third parties with whom We may share Your personal
Sale of Personal Information of Minors Under 16 Years of Age.
We do not knowingly collect the personal information of minors under
sixteen (16) years of age through Our Service. However, Our Service may
contain links to third-party websites that are not under Our control, and
those third-party websites may collect the personal information of minors
under the age of 16. Each of these third parties have privacy policies of
their own that describe their policies regarding such information. Parents
and guardians, We encourage You to monitor You minor child’s use of
and activity on the internet, and instruct them to never provide personal
information without first obtaining parental or guardian permission.
We do not sell the personal information of Consumers that We know are less
than 16 years old.
Parents and Legal Guardians: If You believe that a child under the age of
13 or 16 provided personal information about them to Us through Our
Service, please contact Us by following the contact details set forth in
us with sufficient detail to enable Us to delete the personal information.
Exercising the Data Protection Rights Granted by CCPA
To exercise Your rights under the CCPA as a resident of the State of
California, and You are in fact a California Resident, You can contact us
at the following:
Mail: 1545 Pidco Drive, Plymouth, IN 46563
To be able process and fulfill your request, Your request must provide Us with information sufficient enough for us to reasonably confirm that You are in fact the person that We have collected information on, or to confirm an authorized representative authorized by You to act on Your behalf. Further, Your request must describe Your request with sufficient detail that allows Us to be able to properly understand what You are asking of Us, to evaluate Your request, to process it, and properly respond to it. Please note that if we cannot verify Your identity or Your position as an authorized representative, and We cannot confirm that the personal information We collected relates to You, we cannot provide you with a response of the required information You have requested.
Within forty-five (45) days of receiving Your verified request, We will disclose and deliver the information required free of charge. This time period may be reasonably extended once for an additional 45 days if it is reasonable and necessary with prior notice We will give to You. Note that, as set forth in the CCPA, the information We will gather to disclose only covers the preceding 12-month period before receipt of Your verified request. For data portability requests, We will select the format by which We will provide You with Your personal information. This format will be readily usable, and should allow You to easily transmit the information from entity to entity without issue.
Right to Opt-Out of the Sale of Personal Information
We use Service Providers for targeted and direct advertising. Our Service
Providers may use certain technologies on Our Service that sell Your
personal information as defined by the CCPA. The Company may sell your
personal information as defined by the CCPA. To opt-out of the use of your
personal information for internet-based advertising endeavors, such as for
direct advertising, and these “sales'' of personal information as set
forth and defined by the CCPA, You can opt out by following the
instructions set forth below depending on the device(s) you are using and
- Internet Browsers. On each internet browser You use, You will have
to go into the settings of that browser and opt-out.
Websites. To opt out of receiving personalized advertisements, such
as those provided to Us by Our Service Providers, follow the instructions
on Our Service and on the following:
When you opt out, a cookie will be placed signaling that you have opted
out. However, if You ever change browsers or delete Your browser’s
cookies, you will have to go through this process again to opt out again.
- NAI opt-out information: http://www.networkadvertising.org/choices/
- EDAA opt-out information: http://www.youronlinechoices.com/
- DAA opt-out information: http://optout.aboutads.info/?c=2&lang=EN
Mobile Devices. Some mobile devices grant the ability to opt out of
the use of information about mobile applications You use which are used for
the purposes of personalized advertisements.
Also, You can change the preferences on the settings of Your mobile device
to stop Your device from collecting information on your geographic
- Android: "Opt out of Interest-Based Ads" and/or "Opt out of Ads
- iOS: “Limit Ad Tracking”
- Contact Us. To opt out of our “sale” of your personal
information as defined by the CCPA, please contact us using the information
set forth in Section 9 of this Agreement.
Our Service does not respond to “Do Not Track” (DNT) signals.
However, We may use various technologies, which in some circumstances are
administered by third parties, to track your online activity in order to
enhance user experience, deliver targeted advertisements across third party
websites and/or to collect statistical data. Some of these third parties
respond to “Do Not Track” (DNT) signals sent from your web
browser. If you would like to opt-out of this type of tracking, you can
enable this in your web browser preferences to stop future tracking.
However, we may still use data collected prior to your enabling of the DNT
feature of your browser.
Under California Civil Code Section 1798, California residents with an
established business relationship with Company can request information from
Us one (1) time per year about sharing their Personal Data with third
parties for the third parties’ direct marketing purposes. If you are
a California resident and would like more information on California’s
Shine the Light Law (California Civil Code Section 1798), please contact Us
Under California Business and Professions Code Section 22581, California
residents under the age of 18 who are registered users of online websites,
applications, or services are allowed to request and obtain the removal of
content or information they have posted publicly. If you want to remove
such data, You are a California resident, and you are under the age of 18,
You can contact Us using the contact information listed in Section 9 of
on the Internet, Your request to remove information or content You publicly
posted does not guarantee complete or comprehensive removal of said
information or content, and that the law sometimes does not require or
permit the removal of information or content under certain circumstances.
In compliance with the Children’s Online Privacy Protection Act
(COPPA), Our Service does not knowingly address anyone under the age of 13,
and our Website is directed to individuals who are at least 13 years old or
older. If we discover that such Personal Data or other information has been
collected from someone under the age of 13, we will take the steps to
remove that data from Our servers. If You are a parent/guardian, and You
become aware that Your child has provided Company with Personal Data,
please contact Us using the contact information listed in Section 9 of this
our databases, You may need to provide us with information necessary for us
to find the information in our databases to be deleted.
If Company needs consent as a legal basis for processing Your information,
and You are located in a country that requires consent from a parent or
guardian, We may require Your parent’s or guardian’s consent
before We collect and use that information.
Our Service may contain URLs and links to other third-party websites that,
by clicking on said links, will take you to a third-party website that is
visiting to answer any inquiries about how that third party handles your
personal data. We have absolutely no control over the content, privacy
policies or practices of any third-party sites or services, and we assume
absolutely no responsibility for the privacy policies, privacy practices,
practices or content on or of any third party sites or services.
Further, please note the “Last Updated” date at the top of this
become effective when they are posted on this webpage.