General Privacy Policy: RECENTLY UPDATED – PLEASE REVIEW

Updated: May of 2024

We are DecisionWise, LLC, a Utah (USA) limited liability company. In addition, we use the name Spectiv to identify and brand our online software platform. Spectiv is a registered business name (d/b/a) of DecisionWise and is a registered trademark. Any reference in this document to DecisionWise shall also be deemed to include Spectiv.

DecisionWise is headquartered at 815 W. 450 S., Springville, Utah, 84663, U.S.A. (“DecisionWise,” “Spectiv,” “We,” “Our.” or “Us”). We provide a software platform for our Platform Users to gather employee feedback and to analyze the results. We also provide consulting and professional services to our software customers on a project-by-project basis.

In this privacy policy (this “Policy”), anyone accessing our software platform for the purpose of running feedback capture campaigns through our software platform is called a “Platform User.” An individual who accesses our software to respond to a survey or answer our questions is called a “Respondent.” Anyone who visits our publicly facing websites, such as www.decision-wise.com, www.spectiv. com, etc., is called a “Visitor.”

At DecisionWise, the privacy and security of Platform Users, Respondents, and Visitors is critical. DecisionWise is committed to protecting the data you share with us. This Policy explains how DecisionWise collects and processes information that can be used to directly, or indirectly, identify an individual’s Personal Data (as defined blow).

Data, including Personal Data, collected by DecisionWise is stored on locked and secure servers in DecisionWise’s headquarters or on secure, hosted servers provided by Amazon Web Services (AWS) or on secure Rackspace servers located in Texas, USA. There is no public access to the servers located in DecisionWise’s headquarters. All local servers can be accessed only by appropriate DecisionWise personnel onsite or through a secure virtual private network, which is secured by multi-factor authentication and other security measures. DecisionWise implements and maintains appropriate technical, security, and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure. DecisionWise is SOC 2 compliant.

Sensitive Data may be provided by a Platform User to DecisionWise, such as employee demographic or hierarchical data. In addition, DecisionWise may ask a question on a survey that might ask a Respondent for Sensitive Data. By answering a survey question, a Respondent agrees to the collection and use of the data being provided by the Respondent.

In this Policy, “Sensitive Data” means Personal Data that discloses a Respondent’s race or ethnicity, sexual orientation, sex at birth, gender identity, or trade/union membership.

In this Policy, “Personal Data” includes the following:

• Under the laws of the United States, Personal Data shall include any “non-public personal information” as that term is defined in the Gramm-Leach-Bliley Act found at 15 USC Subchapter 1 §6809(4), and “protected health information” as defined in the Health Insurance Portability and Accountability Act found at 45 CFR §160.103.
• Under the laws of the countries in the European Economic Area (“EEA”), Personal Data shall have the meaning given to it in Directive 95/46/EC (the “EU Directive”) and in the General Data Protection Regulation (“GDPR”). “EU” means the European Union.
• Under the laws of Australia, Personal Data shall include information or an opinion about an identified individual or an individual who is reasonably identifiable: (a) whether the information is true or not; and (b) whether the information or opinion is recorded in a material form or not.
• Under the laws of the state of California, U.S.A., Personal Data includes any specific information that is described in the attached California Addendum.

“Data Controller” means the party that determines the purposes or means of the processing of any Personal Data, which are DecisionWise’s clients.

“Data Processor” means the party that processes the Personal Data on behalf of the Data Controller, which is DecisionWise.

The following sections cover the specifics of each of the three groups from which data is collected: Platform Users, Respondents, and Visitors.

In addition, here is our policy as it relates to short message services (SMS) (a/k/a “text messaging”). We are committed to the protection of your personal information.

Text Messaging: As a Visitor, Respondent, or Platform User, you may engage with us through text messages (SMS). We collect and use your mobile number solely to enhance your experience with our services, such as allowing our sales representatives to contact you by text if you provide your number to us.

Opt-Out Instructions: You have the right to opt out of receiving text messages from us at any time. To do so, simply text “STOP” to the last message your received. Additionally, you can unsubscribe by calling us at +1 801.515.6500 or emailing us a privacy@decisionwise.com. If you are Respondent and you reply with “STOP,” you will receive a link to verify your identity and then you can change your text messaging settings.

Non-Disclosure Commitment: Your mobile number is kept confidential. We will not share, sell, rent, or otherwise disclose your personal information to third parties or affiliates for marketing purposes.

If you are a Visitor to our website, and not a Respondent or Platform User, then this Section 2.2 is relevant for you.

By visiting our public websites, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit our public websites. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or Personal Data that is volunteered by you. Please note that any consent will be entirely voluntary. However, if you do not grant consent to the processing of your Personal Data, the use of our public websites may not be possible.

DecisionWise may collect, record, and analyze information of Visitors to its public websites. We may record your IP address and implement the use of cookies. DecisionWise may also look at information collected by way of page-view activity. Furthermore, DecisionWise may collect and process any Personal Data that you give to us in a website form, such as when you register for events or sign up for information, pricing, whitepapers, or newsletters. If you provide DecisionWise with your social media details, DecisionWise may retrieve publicly available information about you from social media outlets.

Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data from social networks, your areas of interest, interest in DecisionWise products, and certain information about the company you are working for (company name and address), as well as information as to the type of relationship that exists between DecisionWise and yourself.

DecisionWise gathers data about visits to its public websites, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or from where Visitors have come.

DecisionWise uses collected data from Visitors to communicate with Visitors, to customize content for Visitors, to show ads on other websites and search engines, and to improve its websites by analyzing how Visitors navigate and use its websites.

We may process Personal Data if we have your consent or for legitimate business purposes, which such legitimate purposes include the following:

• To identify and prevent fraud.
• To enhance the security of our network and information systems.
• To better understand how people interact with our websites.
• To provide postal communications, which we think will be of interest to you.
• To determine the effectiveness of promotional campaigns and advertising.
• Where the processing enables us to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of Visitors and customers.

Whenever we process data for these business purposes, we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. If you object to this processing, please do not use our public websites.

DecisionWise may also share Personal Data with service vendors or contractors to provide a requested service or to analyze the Visitor behavior on its websites. DecisionWise does not transfer your Personal Data to anyone other than to these limited third parties (vendors to DecisionWise) who are specifically using your Personal Data to help DecisionWise improve its website experiences or to use the data to inform and improve DecisionWise’s marketing efforts.

DecisionWise will never sell your Personal Data to anyone. DecisionWise will never transfer your Personal Data to a third party who will use your Personal Data for any purpose other than to help DecisionWise with its marketing efforts.

DecisionWise may transfer data to third-party affiliates listed in its Data Processing Agreement (DPA), which uses the EU-U.S. Data Privacy Framework (DPF) as the governing data transfer mechanism. DecisionWise shall remain liable under the DPF Principles if the third-party processes such personal information in a manner inconsistent with the DPF Principles, unless proved that it is not responsible for the event giving rise to the damage. For more information on DPF Principles, please visit: https://www.dataprivacyframework.gov/s/

Cookies are small pieces of information sent by a website to a computer or smart device’s internet browser. As intended, cookies cannot be used to run programs or deliver viruses to your computer. By visiting or continuing to visit our websites, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes. Please note that the use of cookies is widespread on the internet and often benefits a Visitor.

For additional information refer to our cookie policy.

Please be aware that while visiting our websites, Visitors can follow links to other websites that are beyond our sphere of influence. DecisionWise is not responsible for the content or privacy policies of these other websites.

If you are a Respondent, and not a Visitor or Platform User, then this Section 2.3 is relevant for you.

DecisionWise collects Personal Data from Respondents when they respond to a survey invitation or answer questions from DecisionWise. WHEN YOU RESPOND TO AN ONLINE SURVEY FROM DECISIONWISE YOU ARE CONSENTING TO THE COLLECTION OF YOUR PERSONAL DATA. YOU ARE NOT REQUIRED TO ANSWER ANY SURVEY OR ANSWER A PARTICULAR SURVEY QUESTION. AN EMPLOYER MAY NOT PENALIZE ANYONE FOR FAILING TO ANSWER A SURVEY OR SURVEY QUESTION.

Respondents should be aware that in responding to surveys or survey invitations, they will be disclosing information that may make them personally identifiable to DecisionWise. In addition, Personal Data about the Respondent may be provided to DecisionWise by a Platform User who is using our software platform to solicit employee feedback responses.

As a general matter, DecisionWise often, but not always, collects the following types of Personal Data from its Platform Users (DecisionWise’s clients) and associated Respondents:

• Employee Name
• Employee Date of Hire (Tenure)
• Employee Date of Birth
• Employee Compensation
• Employee Department and Classification
• Employee Contact Information for the Employer, such as work e-mail, work phone numbers, etc.

When a Platform User or a Respondent uses our services, we may collect their IP address and browser type. We may associate IP address and browser type with a specific person. We also may collect Personal Data from persons who contact us through our websites to request additional information; in such a situation, we may collect contact information (as discussed above) and any other information that the person chooses to submit through our websites.

In our capacity as a service provider/Data Processor, we will receive, store, and/or process Personal Data that is owned and/or controlled by our Platform Users and Respondents associated with the Platform Users (e.g., a Platform User’s employees), including information about the Platform User’s employees, agents, contractors, or other individuals. In such cases, we will process the Personal Data on behalf of and under the direction of the Platform User pursuant to a written contract with the Platform User. The information we collect from Platform Users and Respondents in this capacity is used for preparing reports, tabulating data, gathering survey responses, managing transactions, invoicing, renewals, and other operations related to providing our services to Platform Users, and as otherwise requested by Platform Users.

DecisionWise uses Personal Data that it collects from the Respondents and Platform Users in its role as a software service provider for the following business purposes, without limitation: (1) to gather and process survey feedback from Respondents (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to a Platform User); (2) satisfying governmental reporting, tax, and other requirements (e.g., import/export); (3) storing and processing data, including Personal Data, in computer databases and servers located in the United States and elsewhere; (4) verifying identity (e.g., for online access to accounts); (5) as requested by the Employer or a Respondent; (6) for other business-related purposes permitted or required under applicable local law and regulation; and (7) as otherwise required by law.

All data collected online is collected through encrypted (SSL) channels following industry best practices.

If you wish to inquire about your Personal Data that may have been collected by DecisionWise, you may contact us as explained below, and we will respond as soon as is reasonable or as required by law.

If you are a Platform User, and not a Visitor or Respondent, then this Section 2.4 is relevant for you.

We act on Platform User’s instructions within our software platform to process and collect Personal Data based on our written contract. To provide services and data reports to a Platform User, DecisionWise collects certain types of data from the Platform Users, such as passwords, logins, IP addresses, security tokens (for single-sign-on functionality, SSO), etc.

During a Platform User’s registration on our platform, they provide information such as name, company name, email, address, telephone, and other relevant data. This information is used by DecisionWise to identify the Platform User and provide the Platform User with secure access to DecisionWise’s platforms. DecisionWise Platform Users can at any time access and edit, update or delete their contact details by contacting the DecisionWise representative that has been assigned to their account.

All data collected online is collected through encrypted (SSL) channels following industry best practices.

The purpose of collecting Personal Data from Respondents as part of a survey will vary depending on the survey set up by a Platform User within the DecisionWise software platform. For Respondents in the EEA, DecisionWise will be the Data Processor, as defined in the EU Directive and the GDPR.

DecisionWise may store Personal Data in secure servers located in the United States. DecisionWise complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  DecisionWise has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  DecisionWise has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) about the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Alternatively, upon a client request, we may adopt the EU Standard Contractual Clauses as part of our client contracts as an accepted data transfer mechanism.

In addition to other data protection authorities, the United States Federal Trade Commission has jurisdiction over DecisionWise’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

Only those third parties listed on our Data Processing Agreement (DPA) have access to any data or Personal Data. A copy of our DPA may be found with our legal notices on our public website and can be found here.

DecisionWise processes Personal Data as a Data Processor, as defined in the EU Directive and the GDPR. DecisionWise adheres to the EU Directive and the GDPR from May 25, 2018, onward.

DecisionWise will not retain Personal Data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Personal Data provided by Platform Users and Respondents, it will be stored with DecisionWise for 5 years (with deletion or archiving taking place approximately around each calendar year-end). Schedule deletions or archiving may be delayed or skipped upon a request by an employer. After this 5-year retention period, portions of the Personal Data (in DecisionWise’s sole discretion) may be archived and stored in an offline mode for additional years as (“Archived Data”).

Archived Data will not be accessible by any network or accessible by any person other than DecisionWise’s highest ranking technology officer or DecisionWise’s Data Privacy/Protection Officer. All Archived Data will be locked and stored in backup disks or other similar backup medium, with access limited to physical inspection by DecisionWise’s Director of Technology or DecisionWise’s Data Privacy/Protection Officer. There will never be online access to Archived Data. Archived Data, except for Research Data (defined below), may be permanently and physically destroyed at DecisionWise’s discretion.

The term “Research Data” means Personal Data that has been transformed into strictly anonymized data for research and trending purposes and which may be kept indefinitely. Research Data will not retain any characteristic whereby it could be reverse engineered to make it personally identifiable. Anonymized data will have all identifiable information permanently deleted, and not merely rendered anonymous by having the data encrypted or hashed.

Personal Data obtained from Visitors shall be permanently deleted by DecisionWise after 5 years if there is no activity between DecisionWise and the Visitor during the 5-year period, or such shorter time of inactivity as may be established in DecisionWise’s discretion. Otherwise, if there is activity between DecisionWise and a Visitor, the Visitor’s personal data will be retained until it is deleted due to inactivity, or the Visitor makes a request under this Policy. Activity between DecisionWise and a Visitor is defined as the transmission and receipt of marketing information and/or a visit to DecisionWise’s public websites.

Acceptance of this Policy

We assume that all Visitors to our websites, Respondents to surveys administered by DecisionWise, and Platform Users have carefully read this Policy and agree to its contents. If someone does not agree with this Policy, they should refrain from using our websites and software platforms. We reserve the right to change this Policy as necessity dictates. Continued use of DecisionWise’s websites and platforms after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy. This Policy is an integral part of DecisionWise’s terms of use.

We may update this Policy to reflect changes to our information practices. If we make any material changes, we will notify you by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this General Privacy Policy for the latest information on our privacy practices.

Disclosure

We may also disclose your Personal Data as required by law such as to comply with a subpoena or other legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If DecisionWise is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email or a prominent notice on our website of any change in ownership, changes to the use of your Personal Data, and choices you may have regarding your Personal Data.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We will reveal a Platform User’s Personal Data without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to DecisionWise or to others who could be harmed by the Platform User’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose Personal Data when we have good reason to believe that this is legally required. We may also disclose Personal Data to Platform Users who are bound contractually to protect your data in a manner no less stringent than is provided for in this Policy.

Data Protection Officer; EU/UK Representative

DecisionWise has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. Our Data Protection Officer can be reached as follows:

DecisionWise
Attn: Data Protection/Privacy Officer
815 W. 450 S.
Springville, Utah 84653
+1 801-515-6500×130
privacy@decision-wise.com

You may also contact our GDPR Article 27 outside representatives here:

EU Representative:

Osano International Compliance Services Limited
ATTN: CX98
3 Dublin Landings
North Wall Quay
Dublin 1
D01C4E0

UK Representative:

Osano UK Compliance LTD
ATTN: CX98
42-46 Fountain Street
Belfast
Antrim
BT1 – 5EF

If you have any questions about how we use your personal data or about this Policy, you may send an email to privacy@decisionwise.com.com. If you would like to reach our Data Protection Officer (as defined under the GDPR) you can contact that person at privacy@decisionwise.com or at +1 801-515-6500×130

If you have an unresolved privacy or Personal Data use concern that we have not addressed satisfactorily, please contact us for a list of the EU data protection authorities (DPA) that you may contact for further, independent resolution.

Upon request, DecisionWise, will provide you with information about whether we control any of your Personal Data on our own behalf. If you wish to obtain a copy of particular information you provided to DecisionWise, if you become aware that the information is incorrect and you would like us to correct it, update it, or delete it, if you would like to exercise any of your legal rights such as those in relation to updating your preferences regarding how we use your personal data, or to withdraw consent, contact us at privacy@decisionwise.com. We will respond to your access request within a reasonable timeframe and within the timelines prescribed by applicable law. Before DecisionWise can assist you, provide you with any information, or correct any inaccuracies, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavor to respond within an appropriate timeframe.

Should you want to report an incident relating to our security, confidentiality, or privacy, you are welcome to file a report by contacting us or emailing us at privacy@decisionwise.com.

Dispute Resolution:

In compliance with the Data Privacy Framework Principles, DecisionWise commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Frameworks. European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact DecisionWise by email at privacy@decisionwise.com

DecisionWise has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to a U.S.-based independent dispute resolution mechanism, which is BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF 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 https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf

Privacy Notice For California Residents | Effective: September 2023

This is a PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“CCPA Notice”), and it supplements the information contained in the General Privacy Policy of DecisionWise as listed above. This CCPA Notice section applies solely to Visitors, Platform Users, and Respondents and others who reside in the State of California (“consumers” or “you”).

We adopt this CCPA Notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”), and other California privacy laws including the California Privacy Rights Act (CPRA). Any terms defined in the CCPA or CPRA have the same meaning when used in this CPPA Notice, and capitalized terms have the meanings given them our General Privacy Policy listed above. In this CCPA Notice, we refer to “personal information,” which is the same thing as Personal Data in our General Privacy Policy.

WE WILL NOT USE, GATHER, OR SHARE YOUR PERSONAL INFORMATION EXCEPT AS OUTLINED IN OUR GENERAL PRIVACY POLICY, AND FOR CALIFORNIA RESIDENTS, AS OUTLINED IN THIS CCPA NOTICE.

When exercising your additional rights under the CPRA, please direct all inquiries to privacy@decisionwise.com, where you may request in writing for us to correct inaccurate information that we have about you, or you can direct us to only use your sensitive personal information for limited purposes, such as providing you with specific services that you may request.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

In particular, we have collected the following categories of personal information from Platform Users, Visitors, and Respondents within the last twelve (12) months:

*A Platform User may provide us some of the information listed below, and they are the party that is collecting this information. All other information we collect directly from a Visitor or survey Respondent. OTHER THAN IP ADDRESSES AND ASSOCIATED METADATA FROM THOSE IP ADDRESSES THAT WE COLLECT WHEN SENDING A SURVEY REQUEST, WE ONLY COLLECT THE INFORMATION THAT WE SPECIFICALLY ASK FOR IN THE SURVEY. YOU DO NOT HAVE TO RESPOND TO A SURVEY OR ANY PARTICULAR SURVEY QUESTION. YOU WILL NOT BE PENALIZED OR PUNISHED FOR NOT RESPONDING TO A SURVEY REQUEST OR SURVEY QUESTION.

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following sources:

• Directly from our Platform Users and survey Respondents.
• Directly and indirectly from Visitors using our website (www.decisionwise.com).

We will use personal information as described in our General Privacy Policy as set forth above. 

We may disclose or share your personal information described in our General Privacy Policy as set forth above.

In the preceding twelve (12) months, we have disclosed the following categories (from the chart above) of personal information for a business purpose to our Platform Users, but in a confidential manner (see General Privacy Policy set forth above):

We may disclose, but never sell, your personal information for a business purpose to the third parties listed in our DPA but strictly for the purposes outlined in the DPA.

IN THE PRECEDING TWELVE (12) MONTHS, WE HAVE NOT SOLD ANY PERSONAL INFORMATION.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: 

• The categories of personal information we collected about you. 
• The categories of sources for the personal information we collected about you. 
• Our business or commercial purpose for collecting or selling that personal information. 
• The categories of third parties with whom we share that personal information. 
• The specific pieces of personal information we collected about you (also called a data portability request). 
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: 
  • sales, identifying the personal information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to: 

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
• Debug products to identify and repair errors that impair existing intended functionality. 
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). 
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. 
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 
• Comply with a legal obligation. 
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us using the following contact information:

DecisionWise (DecisionWise)
Attn: Data Protection Officer
815 W. 450 S.
Springville, Utah 84653
+1 801-515-6500×130
privacy@decisionwise.com

 Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

 You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: 

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. 
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 
• We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures will cover those periods required by law. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: 

• Deny you goods or services. 
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. 
• Provide you a different level or quality of goods or services. 
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this CCPA Notice or our General Privacy Policy, we will notify you by email or through a notice on our website homepage.

If you have any questions or comments about this CCPA notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

DecisionWise (DecisionWise)
Attn: Data Protection/Privacy Officer
815 W. 450 S.
Springville, Utah 84653
+1 801-515-6500×130
privacy@decisionwise.com