ProStruct360 Privacy Policy

ProStruct360 Privacy Policy

Last updated: November 28, 2023

At ProStruct360, your privacy and data security are our top priority. We strive to be transparent about who we are, as well as how and why we collect, store, use, and share information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). This policy explains your rights regarding your Personal Information and how to contact us or certain supervisory authorities in the event you have a complaint.

When we collect, use, and take responsibility for certain Personal Information about you, we are subject to various state laws in the United States, such as the California Consumer Privacy Act (“CCPA”), amended by the California Privacy Rights Act (“CPRA”).

By collecting Personal Information, we may be responsible as a “business” or “service provider” for purposes of the CCPA. Any reference to “ProStruct360”, “Koppr”, “we”, “us”, “our”, or the “Company” is a reference to ProStruct360, LLC, its affiliates, and its subsidiaries. Please see the “Contacting Us” section below for our contact information.

1. What Personal Information do we collect?

We require certain Personal Information to provide the Services (as defined in the ProStruct360 Terms and Conditions) to you. If you do not provide the Personal Information that we ask for, it may delay or prevent us from providing the Services to you.

The Personal Information that we may collect directly from you includes the following categories of Personal Information:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers	Name, postal address, email address, Internet Protocol address, account name, username, password, and online identifiers
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual and other personal information described in Cal. Civ. Code § 1798.89(e).	Signature, telephone number, employment information
Commercial information	Individual purchases, such as products, materials, and services
Internet or other electronic network activity information	Browsing history and information regarding interaction with social media profiles, advertisements, and the ProStruct360 services
Geolocation data	ProStruct360 does not collect this
Biometric data	ProStruct360 does not collect this
Characteristics of protected classifications under California or federal law	ProStruct360 does not collect this
Sensory data	Audio, electronic, or visual information
Professional or employment-related information	Company name, company contact information, services provided
Education information	ProStruct360 does not collect this
Inferences drawn from any of the information identified above	Preferences

We may also collect other information that you or others may provide to us, including the content that you or others submit, post to, or create in connection with the Services we provide to you, such as photos, comments, reviews, searches, photo notes, discussions, project details and costs, and style preferences.

We may record, monitor, or otherwise collect details about your communications when you communicate with us (via email, phone, through our platforms, in connection with the Services we provide to you, or otherwise) and when you use our software to communicate with others. If required by applicable law, we will provide you notice or obtain consent before recording or monitoring any of these calls.

2. How do we collect Personal Information?

Most of the Personal Information we collect comes directly from you, either through email, telephone, the ProStruct360.com website, our platforms, or in connection with the Services we provide to you.  However, we may also collect information about you from other sources, including but not limited to third parties from whom we have purchased Personal Information. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. In particular, we collect Personal Information from the following sources:

• ProStruct360 customers who may supply information directly to us, including Personal Information regarding their own business, clients, contacts, or subcontractors;
• From publicly accessible sources, such as property or permit records, corporate websites, trade and business licenses, professional certifications, permits, trade association membership, and e-commerce marketplace profiles (from these sources, we may obtain business information on both business people and companies);
• Directly from third party providers of business information, such as home marketing sources, social media profiles, or customer due diligence providers;
• From a third party with your consent, such as a financial providers;
• From cookies on our website; and
• From market research surveys and/or interviews conducted by our own employees or by third-party vendors. 

3. How and why do we use your Personal Information?

We collect and process Personal Information for the purposes and on the legal bases identified in the following:

Providing our websites and services	To perform our contracts with you for the use of our websites and services and to fulfill our obligations under applicable terms and conditions or terms of use; where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to operate and administer our websites and to provide you with the content you access and request (e.g., to interact with content from our websites).
Promoting the security of our websites and services	In order to promote the safety and security of the services, systems, and applications, and to protect our rights and the rights of others, we track the use of our websites and services, verify accounts and activity, investigate suspicious activity, and enforce our terms and policies.
Providing necessary functionality	To perform our contract with you for the use of our websites and services; where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to provide you with the necessary functionality required during your use of our websites and services.
Managing user registrations	If you have registered for an account with us, we process your Personal Information by managing your user account for the purpose of performing our contract with you according to applicable terms and conditions.
Handling contact and user support requests	If you fill out a web form or request customer support, or if you contact us by other means including via a phone call, we process your Personal Information to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you.
Managing payments	If you have provided financial information to us, we process your Personal Information to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you.
Developing and improving our websites and services	To analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your valid consent.
Reviewing compliance with applicable usage terms	To review compliance with the applicable usage terms in our customer’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms.
Identifying customer opportunities	To assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the interests of our customers and their users’ experiences.
Legitimate business opportunities	To supply commercial data about businesses to other businesses; to license and sell business contact information for marketing and other purposes; to supply data about ProStruct360 customer’s business, clients, contacts, or subcontractors to other businesses for business opportunities.
Displaying personalized advertisements	To conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our websites or, where necessary, to the extent you have provided your prior consent.
Sending marketing communications	To send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent; this may include device and usage data.
Complying with legal obligations	To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.

4. Who do we share Personal Information with?

We may share your Personal Information with:

• Our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support, data enrichment, fraud prevention and fraud detection for the purposes and pursuant to the legal bases described above; for fraud protection purposes only, these contracted service providers may [1] collect your Battery Usage, Device Identifier, Device Storage, MAC Address, and SIM information; (2) collect enough information to determine if you are trying to fake your current location by using a VPN, VPN apps with location spoofing, or other related tools.
• If you use our services as an Authorized User (as defined in the ProStruct360 Terms and Conditions), with the affiliated customer responsible for your access to the services to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies;
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by third party, with such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Information to an unaffiliated third party;
• Law enforcement, public, and government authorities, and other entities as we deem reasonably necessary to comply with law, support investigations, and protect the rights and property of you, us, and others.

We may also collect, process, and use non-personal, aggregated, or anonymized data in any way, including by disclosing, sharing, or otherwise making it available to third parties for various research, marketing, analytics, and measurement purposes. Additionally, ProStruct360 may share such anonymous usage on an aggregate basis in the normal course of operating our business. This may include, but is not limited to, sharing information publicly to show the general use of our services.

Any Personal Information or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and used by others who visit these forums.

We only allow our service providers and joint marketing partners to handle your Personal Information if we are satisfied that they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers and joint marketing partners to ensure they can only use your personal information for the purposes outlined in our contracts.

5. Children

Our websites and services are not created for nor directed at children. We do not knowingly, collect, share, or sell Personal Information from children under the age of 18. If you are a parent or guardian and believe we have information about your child or that your child has provided us with Personal Information without your consent, please email support@ProStruct360.com.

6. How long do we keep your Personal Information?

We may retain your Personal Information for a period of time consistent with the original purpose of collection. We determine the appropriate retention period for Personal Information on the basis of the amount, nature, and sensitivity of your Personal Information processed, the potential risk of harm from unauthorized use or disclosure of your Personal Information, and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitations). We will only retain your data for a period of time that is reasonably required for legal or business purposes.

7. California Resident Rights

California residents have the right under the CCPA and the CPRA to exercise free of charge certain rights:

Right to Know/Access	Residents of California have the right to know the Personal Information ProStruct360 collects, uses, discloses, or sells.  Specifically, you have the right to know: The categories of Personal Information we have collected about you; The categories of sources from which the Personal Information is collected; Our business or commercial purpose for collecting, selling, or sharing Personal Information; The categories of third parties with whom we share Personal Information, if any; and The specific pieces of Personal Information we have collected about you. In connection with any Personal Information we may sell or disclose to a third party for a business purpose, residents of California have the right to know: The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and The categories of Personal Information that we disclosed about you for a business purpose. Please note that we are not required to: Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or Provide the Personal Information to you more than twice in a 12-month period.
Right of Correction	You have the right to request that we correct inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.
Right of Portability	You have the right, upon request, to obtain your Personal Information by mail or electronically without charge and in a readily usable format that allows you to transmit the information from one entity to another entity without hindrance.
Right to Opt Out	You have the right under CCPA and CPRA, and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your Personal Information. If you exercise your right to opt out of the sale or disclosure of your Personal Information, we will refrain from selling your Personal Information, unless you subsequently provide express authorization for the sale of your Personal Information. To opt out of the sale or disclosure of your personal information, please email us at support@ProStruct360.com with the subject: “Opt Out of the Disclosure of Your Personal Information” and we will supply you with the proper forms to complete Opting Out.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your Personal Information from our records; and Direct any service providers to delete your Personal Information from their records. Please note that we may not delete your Personal Information if it is necessary to: Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Limit Use and Disclosure	You have the right to direct a business that collects sensitive personal information to limit its use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, necessary for business purposes, or authorized by certain regulations. We do disclose sensitive information only to the extent necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, necessary for business purposes, or authorized by certain regulations.
Right to Non-Discriminatory Treatment	You have the right to not be retaliated or discriminated against by a business for exercising a privacy right under CCPA or CPRA.

Instructions for making a request under CCPA/CPRA:

In order to make a request under CCPA/CPRA, please email us at support@ProStruct360.com to receive the proper forms necessary. Alternatively, you may email a request to support@ProStruct360.com, or send us a physical letter at:

ProStruct360, LLC
ATTN: Privacy Team
570 Colonial Park Dr, STE 316
Roswell, GA 30075, USA

Verification of Request:

If you make a request to correct, delete or know the personal information we collect, disclose, or sell, and if California law applies to you, ProStruct360 is required by California state law to first verify your identity to ensure your data is not being disclosed to someone other than you.  Any follow-ups or responses will be made via email. We may ask for additional information which we can cross-reference with data we already have on file to verify you are who you claim to be.  Once your identity has been verified, we will process your request as quickly as possible.

Timing of Responses:

If you make a Request to Know or Delete the personal information under CCPA, ProStruct360 will confirm receipt of your request within 10 business days. For requests where we are required to first verify your identity, we will process the request as quickly as possible; however, we may take up to 45 calendar days from the date of your original request to confirm your identity and process your request. 

 Authorized Agents:

Residents of California may also utilize a third party to exercise their rights under CCPA.  Authorized agents will be required to provide proof they have the legal authority to act on behalf of the California resident, such as a signed statement from the California resident, valid Power of Attorney, or other evidence of authority.  We may contact the California resident directly if we are unable to reasonably confirm the identity or authority of the authorized agent.

10. Colorado, Connecticut, and Virginia Resident Rights

Colorado, Connecticut, and Virginia each provide certain state residents with specific rights in relation to their Personal Information. Colorado residents may have rights under the Colorado Privacy Act (“CPA”), Connecticut residents may have rights under the Connecticut Data Privacy Act “CTDPA”), and Virginia residents may have rights under the Virginia Consumer Data Protection Act (“VCDPA”). Certain residents in these states have the following rights:

Right to Know/Access	You have the right to confirm whether a controller is processing your Personal Information and to access such data.
Right of Correction	You have the right to correct inaccuracies in your Personal Information, considering the nature of the Personal Information and the purposes of the processing of your Personal Information.
Right of Deletion	You have the right to delete Personal Information provided by or obtained about you.
Right of Portability	You have the right to obtain a copy of the Personal Information that you previously provided to ProStruct360 in a portable way and, to the extent technically feasible, readily usable format that allows you to easily transmit the data to another controller or business.
Right to Opt Out	You have the right to opt out of the processing of Personal Information for purposes of targeted advertising, sale of personal data, and certain profiling.
Right to Appeal	You have the right to appeal a refusal to act on a request within a reasonable period of time after your receipt of the decision. If your request is rejected, you will receive a notification with the reason for rejection and instructions about how to make an appeal. Appeal requests can by emailing support@ProStruct360.com and must be submitted within 15 days of receipt of the rejection notice. We will respond to you within 45 days of your appeal submission.

Instructions for making a request under CPA, CTDPA, or VCDPA:

In order to make a request under CPA, CTDPA, or VCDPA, please utilize the form at the bottom of this webpage. Alternatively, you may email a request to support@ProStruct360.com, or send us a physical letter at:

ProStruct360, LLC
ATTN: Privacy Team
570 Colonial Park Dr, STE 316
Roswell, GA 30075, USA

Verification of Request:

If you make a request to correct, delete or know the personal information we collect, disclose, or sell, ProStruct360 is required by state law to first verify your identity to ensure your data is not being disclosed to someone other than you. Any follow-ups or responses will be made via email. We may ask for additional information which we can cross-reference with data we already have on file to verify you are who you claim to be. Once your identity has been verified, we will process your request as quickly as possible.

Timing of Responses:

When you make a Request to Know or Delete under CPA, CTDPA, or VCDPA, ProStruct360 will confirm receipt of your request within 10 business days. For requests where we are required to first verify your identity, we will process the request as quickly as possible; however, we may take up to 45 calendar days from the date of your original request to confirm your identity and process your request.

Authorized Agents:

Residents of Colorado, Connecticut, and Virginia may also utilize a third party to exercise their rights under CPA, CTDPA, or VCDPA. Authorized agents may submit requests through the methods described above. Authorized agents will be required to provide proof they have the legal authority to act on behalf of the resident, such as a signed statement from the resident, valid Power of Attorney, or other evidence of authority. We may contact the resident directly if we are unable to reasonably confirm the identity of authority of the authorized agent.

11. A2P 10DLC Compliance Statement

• User Consent: We adhere to the principle of informed consent for all A2P 10DLC messaging. Users must explicitly opt-in to receive messages from our platform. Consent can be obtained through various means, including web forms, SMS confirmations, or verbal agreements, and will be documented and stored in compliance with relevant laws and regulations.

• Message Content: All messages sent via our platform will comply with applicable laws and regulations. We prohibit the transmission of harmful, fraudulent, or illegal content. Messages will be monitored for compliance, and we reserve the right to suspend or terminate services for any user found to be in violation of these standards.

• Opt-Out Mechanisms: Every message sent via our platform will include a clear and easy-to-use opt-out mechanism. Users can opt-out at any time, and such requests will be processed promptly. Opt-out preferences will be respected and adhered to without exception.

• Carrier Compliance: We will comply with all carrier guidelines and requirements related to A2P 10DLC messaging. This includes adherence to message throughput limits, content restrictions, and any other carrier-imposed guidelines.

• Data Privacy and Security: We are committed to protecting the privacy and security of user data. All personal information will be handled in accordance with our Privacy Policy, and we will take appropriate measures to ensure the security of our messaging platform.

• Compliance Updates: Our A2P 10DLC compliance practices may be updated periodically to reflect changes in laws, regulations, or carrier policies. We will communicate any significant changes to our users in a timely manner.

• Contact and Grievances: For any questions or concerns regarding our A2P 10DLC practices, or to report a compliance issue, users can contact us at support@prostruct360.com.

12. Security of Information

As stated above, your privacy and data security are our top priority. We take precautions including organizational, technical, and physical measures to help safeguard against the accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Information we process or use.

When you submit a payment or purchase a service on our websites or through our mobile applications, all of your order information, including your credit card number and delivery address, is transmitted through the Internet using Secure Sockets Layer (SSL) technology. SSL technology causes your browser to encrypt your order information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent someone other than operators of our websites from capturing and viewing your personal information.

While we use industry standard means to protect our websites and your information, the Internet is not 100% secure. The measures we use are appropriate for the type of information we collect. We cannot promise that your use of our websites or mobile applications will be completely safe. We encourage you to use caution when using the Internet. Online access to your personal information is protected with a password you select. We strongly recommend that you do not share your password and that you use unique passwords for all of your online accounts. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in the “Contacting Us” section, below.

12. Global Privacy Control

We recognize the “Global Privacy Control” (“GPC”) to allow you to opt out of the sale of your Personal Information and the sharing of your personal information for targeted advertising on our public facing websites. The GPC is a proposed specification designed to allow Internet users to notify businesses of their privacy preferences, such as whether or not they want their Personal Information to be sold or shared. To learn more about the GPC and how you can use it to opt out of the sale or sharing of your Personal Information you can visit their website here. If you visit our public facing websites with a browser transmitting GPC, we will not share your information for targeted advertising or sell your personal information associated with your visit.

13. Changes to this Privacy Policy

We will update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “Last updated” at the top of this Privacy Policy. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.

We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing, and sharing of your Personal Information.

14. Contacting Us

To exercise your legal rights regarding your Personal Information, or if you have questions regarding this Privacy Policy or our privacy practices please contact us directly, please email support@ProStruct360.com, or mail us to:

ProStruct360, LLC
ATTN: Privacy Team
570 Colonial Park Dr, STE 315
Roswell, GA 30075, USA

We are committed to working with you to obtain a fair resolution of any request or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to lodge a complaint with the competent supervisory authority.