IPE Privacy Policy

Effective Date: June 11, 2021

Last Updated: June 11, 2021

IPE is a Division of NBI

NBI, Inc., a Wisconsin non-stock corporation, and its affiliates, subsidiaries, divisions and brands (collectively, "NBI," "we ," "us," or "our," as the context may require) provides practical, skill-based CLE and continuing education seminars and online courses. NBI also operates and provides the websites www.nbi-sems.com and ipe.nbi-sems.com (each a " Site"), including all content, functionality, mobile websites, microsites, applications and services offered on or through a Site (together with each Site, the "Services").

We respect the privacy of individuals who visit or use the Services (" you" or "your," as the context may require) and are committed to protecting your privacy through compliance with this Privacy Policy (this "Policy"). This Policy describes:

  • The types of information we may collect via or that you may provide when you visit, access, use or otherwise interact with the Services, or communicate with us regarding the Services.

  • Our practices for collecting, using, maintaining, protecting, disclosing and processing that information.

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. By accessing or using the Services, or by communicating with us regarding the Services, you agree to this Policy, our Cookie Policy, our Terms of Use, and, if applicable, our Subscription Agreement (collectively the "User Terms"). If you do not agree with our policies, practices, or terms and conditions contained in the User Terms, please do not use or access this Site.

This Policy may change from time to time (see Section 13). Your continued use of the Services after we revise this Policy or the User Terms means you accept this Policy and the User Terms as amended, so please check this Policy and the User Terms periodically for updates.

If you need to access this Policy in an alternative format, please contact us by any of the methods listed in Section 14.

1. What this Policy Covers

This Policy governs our collection, use, maintenance, protection, disclosure and processing of personal information (as defined below), including personal information we collect on or through the Services, and in email, text, and other communications relating to the Services.

Except as otherwise provided in this Policy, "personal information" is information by which you may be personally identified, or that relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you, such as name, email address or identification number. "Personal information" does not include information which is generally not considered "personal information" or "personal data" under applicable law, such as information which is publicly available or subject to special data privacy laws and/or regulations, such as "protected health information" covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

This Policy DOES NOT apply to information that:

  • except with respect to Section11 or as required by applicable law, we collect offline;

  • is collected through any applications or websites other than those included in the Services, including websites you may access through or may be linked to by the Services; and

  • except as expressly provided in this Policy (see Section 4.C), which you provide to or which is collected by any third party.

Other websites, applications, and other third parties generally have their own privacy policies, which we encourage you to read before providing information on, to, or through them.

2. Children's Privacy

The Services are not directed to nor intended for use by anyone under eighteen (18) years of age ("Prohibited Users"). We do not knowingly collect personal information from Prohibited Users. No Prohibited Users may use the Services. If you are a Prohibited User, do not use or provide any personal information to, on, or through the Services.

If we learn we have collected or received personal information from a Prohibited User, we will delete that information. If you believe we might have any information from or about a Prohibited User, please contact us by any of the methods listed in Section 14.

3. Information We Collect

We collect several types of information from and about you as a result of your use of or registration with the Services, and as a result of your communication with us. This information may include:

  • Personal information, such as your:
    • Name;
    • Postal address;
    • Email address;
    • Telephone number;
    • Bar ID;
    • Billing information such as credit card information, billing address or shipping address (however, see our note below about payment information); or
    • Any other categories of personal information which you otherwise provide to us on or through the Services or in communications with us regarding the Services;

  • Information which is about you but does not identify you, such as traffic data, location data, logs of the date and time of your Site visits, click-stream data, and other information which has been de-identified or aggregated in the manner where it can no longer be used to identify you ("non-personal information");

  • Information about your internet connection, the equipment you use to access the Services, and usage details ("Usage Information"); and/or

  • Any other form or category of information, including personal information, which you publicly disclose or share on or through the Services, or disclose to or share with us in any manner.

Payment Information

NBI accepts but does not directly collect credit card or other payment information via the Services. If you make a purchase through the Services, your payment and payment information will be processed by our payment processor (PayPal). Purchases made on or through the Services, as well as any payment information provided in connection with purchases made on or through the Services will also be subject to PayPal's privacy policy and other terms. For more information on PayPal and how payment information processed by PayPal will be treated, please see: https://www.paypal.com/myaccount/privacy/privacyhub

4. How We Collect Information

We collect information, including personal information, from and about you:

  • Directly from you when you provide it to us.

  • Automatically when you use or access the Services and navigate the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies, as described below.

  • From third parties.

A. Information You Provide to Us

The information, including personal information, we collect when you register with, or use or access the Services, may include:

We may link some of the information we receive directly from you with information we obtain through other methods and vice versa. This allows us to better understand your interests, needs, and objectives such that we may better serve you and offer you better services. Any such information so linked or combined which meets the definition of personal information will be treated as such under this Policy.

From time to time, the Services may allow you to provide information to be published or displayed (hereinafter, "posted") on public areas of the Services, or transmitted to other users of the Services or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

B. Information We Collect Automatically

When you navigate, access, or use the Services, we may use automatic data collection technologies to collect certain information, including:

  • Usage Details - When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services. We may also collect the webpage from which you came immediately before reaching the Services and the webpage to which you went immediately after leaving the Services. We may use this information for system administration and to report aggregate information to our advertisers and business partners.

  • Device Information - We may collect information about your device and internet connection, including the device's unique device identifier, IP address, operating system, browswer type, network information, and, if applicable, the device's telephone number.

  • Location Information - The Services may collect information about the location of your device. Any such identification is used only in connection with the functionality of the Services and will not be otherwise used, except in the aggregate with the location information from other users.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties.

As further described in our Cookie Policy , we use "cookies," pixels, web beacons, and other technologies to receive and store certain information when you interact with the Services. We also allow third parties to use cookies on the Services as described in our Cookie Policy. You may refuse the use of cookies by selecting the appropriate settings on your browser; however please note that if you do this you may not be able to use the full functionality of the Services. To learn more about how we use cookies, please visit our Cookie Policy . The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies) - A cookie is a small file placed on your smartphone, tablet, computer, or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone, tablet, computer, or other device. However, if you select these setting you may be unable to access certain parts of the Services.

  • Web Beacons - Portions of the Services [and our emails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages [or opened an email] and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). Web beacons can recognize certain types of information, such as cookies, time and date of a page view, and a description of the page where the Web beacon is placed. We may use Web beacons to compile information regarding use of the Services.

  • Analytics - We may utilize third party companies and analytics to help us market, sell, and provide information about our products and services; and we provide your personal information to these third party companies to assist us in conducting business with you. We may use web analytics tools provided by service providers, including, but not limited to, Google Analytics, which is a third party service that transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We may use reports provided by Google Analytics or other similar service providers, to help us understand traffic on the Services, and web page usage. For more information concerning Google Analytics and how it collects and processes data please see "How Google Uses Data When You Use Our Partners Web Sites or Apps" located at www.google.com/policies/privacy/partners. We may use the information provided by these tools to improve our services and our online advertisements. These tools place session and persistent cookies in your browser to identify you as a unique user the next time you visit, access, or use the Services. Each cookie cannot be used by anyone other than the service provider (e.g., Google Analytics).

At this time, the Services do not recognize automated browser signals regarding tracking mechanisms, such as "do-not-track" instructions. All traffic is treated as equal and processed the same in that we will track users' use of the Services as well as the webpage that the user came from before reaching the Services and the webpage to which he or she went after leaving the Services. See Section 8 for information on other mechanisms that enable you to exercise choice about behavioral tracking and other privacy matters.

C. Information We Receive from Third Parties and Other Sources

To the extent permitted by applicable data protection laws, we may also receive information (including personal information) or draw inferences about you from other sources, including but not limited to third party mailing lists, social media platforms and publicly available sources. At this time, we only use mailing lists provided by third parties for direct mail and email purposes. We also may obtain information about your online activities over time and across third-party websites or other online services (behavioral tracking) from third parties. See Section 8 for information on mechanisms that enable consumers to exercise choice about behavioral tracking.

5. Information Collected by Third Parties

When you use the Services, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Advertisers, ad networks, and ad servers.

  • Website analytics

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not directly control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Section 8.

6. How We Use Information

We may use or disclose the information we collect, including personal information, for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

  • To create, maintain, customize, and secure your account with us.

  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  • To understand and anticipate your needs and preferences.

  • To ensure the Services are of interest to you (including, customization of advertising and content) and help us better understand your use of the Services.

  • To provide you with promotional offers and materials, newsletters, offers, invitations to events and personalized information.

  • To personalize your experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Services, third-party sites, and via email or text message (with your consent, where required by law).

  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • Notify you when updates to the Services and of changes to any products or services we offer or provide though the Services.

  • To verify individual attendance of our live or web produced events, upon request from authorized accreditation agencies.

  • To help maintain the safety, security, and integrity of the Services, as well as our products, services, databases, other technology assets, and business.

  • For testing, research, analysis, support and product development, including to develop, support and improve the Services and our products and services.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users and/or customers is among the assets transferred.

  • As described to you when collecting your personal information, or for any other purpose with your consent.

The Usage Information we collect helps us to improve the Services and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.

  • Store information about your preferences, allowing us to customize the Services according to your individual interests.

  • Speed up your searches.

  • Provide customized offers.

  • Recognize you when you use the Services.

7. How We Disclose Information

We may disclose non-personal information, information derived from personal information which has been sufficiently aggregated or de-identified such that it is no longer capable of identifying individuals, without restriction.

Except as otherwise provided in this Policy, we may disclose personal information that we collect or you provide:

  • To our affiliates.

  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.

  • To fulfill the purpose for which you provide it.

  • For any other purpose disclosed by us when you provide the information.

  • With your consent.

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • To enforce our rights arising from any contracts entered into between you and us, and for billing and collection.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of NBI, our customers or others.

8. Privacy Choices

We strive to provide you with and inform you of choices regarding your information, including personal information. This Section 8 describes mechanisms for you to control certain uses and disclosures of your information.

  • Tracking Technologies โ€” You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.

  • Location Information โ€” You can choose whether or not to allow the Services to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the Services may become inaccessible or not function properly.

  • Promotion by NBI โ€” If you do not want us to use your email address to promote our products or services, you can opt-out here: https://ipe.nbi-sems.com/Unsubscribe. You can also always opt-out by logging into the Services and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to ipecustomerservice@nbi-sems.com

For information on accessing or correcting your personal information which we hold, please see Section 9.

If you are a resident of the state of California, you may have additional rights and choices regarding your personal information. Please see Section 11 for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: ipecustomerservice@nbi-sems.com . However, please know we do not sell data triggering that statute's opt-out requirements.

9. Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the Services and visiting your account profile page.

You may also send us an email at ipecustomerservice@nbi-sems.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you are an individual who is located in the European Economic Area (EEA), please see Section 10 for more information about your rights and choices regarding your personal information.

If you are a resident of the state of California, you may have additional rights and choices regarding your personal information. Please see Section 11 for more information.

10. Notices for Individuals Located in the EEA

A. Scope

This Section 10 applies exclusively to visitors and users of the Services who are located in the EEA ("Data Subjects").

B. Rights of Data Subjects

If you are a Data Subject, you have the following rights:

  • The right to request copies of your personal information. If you require more than one copy, we may charge you a reasonable fee.

  • The right to request that we correct any personal information that you believe is inaccurate, or complete any personal information which you believe is incomplete.

  • The right to request that we erase your personal information, under certain circumstances.

  • The right to request that we restrict the processing of your personal information, under certain circumstances.

  • The right to object to our processing of your personal information, under certain circumstances.

  • The right to request we transfer data that we have collected to you or directly to another organization, under certain circumstances.

  • The right to withdraw your consent, explicit or otherwise, at any time. If we rely on your consent as the legal basis for our processing of your personal information, we will refrain from processing your data.

For the purposes of European data protection laws, NBI is the data controller (i.e., responsible for controlling the processing of personal information covered by this Policy). If you are a Data Subject and would like to exercise any of the foregoing rights, please contact us as provided in Section 14.

C. Transfer of Personal Information

The Services are operated and managed on servers located and operated within the United States . Any information collected through the Services as described in this Policy may be stored in the United States or any other country in which NBI or its service providers maintain facilities. The United States is not recognized as having adequate safeguards under European law. If you are located outside of the United States, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the United States.

11. Privacy Notice for California Residents

A. Scope; Definitions

This Section 11 applies exclusively to visitors and users of the Services who are residents of the state of California (as defined in California Consumer Privacy Act, Cal. Civil Code §§ 1798.100 to 1798.199, as amended, and including all regulations promulgated thereunder (the " CCPA")) (such residents of California "Consumers" and each a "Consumer"). As used in this Section 11, the term "you" and "your" shall only refer to a Consumer. For purposes of this Section 11, "personal information" has the meaning set forth in the CCPA.

If you are a Consumer, the CCPA provides you with certain rights regarding your personal information. This Section 11 includes additional notices with respect to and describes those rights and provides you with additional information regarding our practices regarding the collection, use, disclosure, and sale of personal information.

This Section 11 supplements the information contained elsewhere in this Policy with respect to (but only with respect to) Consumers, and notifies Consumers of certain rights they have under the CCPA.

B. Personal Information We Collect

We may collect, and in the last twelve (12) months have collected, the following categories of personal information from Consumers:



A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

F. Geolocation data.

Physical location or movements.

G. Professional or employment-related information.

Current or past job history or performance evaluations.

H. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

I. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

C. Sources of Personal Information

We may collect your personal information from the categories of sources of personal information identified in Section 4. For the sake of clarity, these categories may include: you directly, advertising networks, internet service providers, data analytics providers, credit boards, operating systems and platforms, social networks and data brokers .

D. Use of Personal Information

We may collect, use, maintain, disclose, and otherwise process your personal information for the business and/or commercial purposes identified in Sections 6 and 7.

E. Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. We may disclose, and in the preceding twelve (12) months have disclosed, personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information.

F. Notice of Rights and Choices under the CCPA

The CCPA provides Consumers with certain rights regarding their personal information. This Section 11.F describes these rights and explains how Consumers may exercise them.

I. Right to Opt-out of the Sale of Personal Information

We do not sell personal information

II. Right to Know; Data Access and Portability Requests

You have the right to request that we disclose certain information (the " Right to Know") to you about our collection, use, disclosure, of your personal information over the past twelve (12) months (a " Request to Know").

Once we receive and verify your Request to Know (see Section 11.G), we will disclose to you each of the following items which you include in your Request to Know:

  • The categories of personal information we have collected about you;

  • The categories of sources for the personal information we have collected about you;

  • Our business or commercial purpose for collecting or selling that personal information;

  • The categories of third parties with whom we have shared that personal information;

  • The specific pieces of personal information we have collected about you; (if delivered to you electronically in a portable format, a "Data Portability Request," if delivered to you by other means, a "Data Access Request");

  • If we have 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.

For information on how to submit a Request to Know, Data Access Request, or Data Portability Request, see Section 11.G.

The CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B Information") from some of its requirements. To the extent permitted by the CCPA, we may deny a Request to Know, Data Access Request, or Data Portability Request relating to B2B Information.

III. Right to Request Deletion

You have the right to request that we delete any of your personal information that we have collected from you or have maintained or retained, subject to certain exceptions (a "Request to Delete"). Once we receive your request and confirm your identity (see Section 11.G), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 ยง 1546 et. 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 the extent permitted by the CCPA, we may deny a Request to Delete relating to B2B Information.

IV. Right to Non-Discrimination

You have the right to not receive discriminatory treatment for your exercise of privacy rights under the CCPA, by, for example, being denied goods or services or being charged different prices for goods or services because of your exercise of CCPA rights.

Unless permitted by the CCPA, we will not do any of the following based upon your exercise of privacy rights under the CCPA: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

V. Authorized Agents

You may authorize another person (an "Authorized Agent") to exercise any of your rights under the CCPA. To designate an Authorized Agent to make a request with us, (i) provide the authorized agent signed permission to submit a request under this Section 11 with us, and (ii) confirm with us that you provided the Authorized Agent permission to submit the request by submitting such signed permission to us by email at customerservice@nbi-sems.com. Please note that you may be required to verify your identity prior before your confirmation of permission for the Authorized Agent is effective under this Section 11.

G. Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described inSection 11.F, please submit a verifiable consumer request to us by either:

Calling us at 1-800-793-5274

Emailing us at ipecustomerservice@nbi-sems.com

Only you or your Authorized Agent may make a verifiable consumer request related to your personal information. You may only make a Request to Know, Data Access Request, or Data Portability Request twice within a twelve (12) month period. Your Request to Know, Data Access Request, or Data Portability 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 of such person, which may include:
    • Information which we already maintain; or
    • If we cannot verify your identity based on information already maintained by us, such information that we or our representatives request from you.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within this timeframe, please contact us as provided in Section 14.

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. If we cannot verify your request within forty-five (45) days from the date that we receive your request, we may deny your request.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

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 only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising your right to opt-out of the sale of your personal information, see Section 11.F.I.

H. Other California Privacy Rights

California's "Shine the Light" law (Cal. Civil Code § 1798.83) permits Consumers to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not currently disclose personal information to third parties for their direct marketing purposes.

12. Data Retention and Data Security

Except as provided elsewhere in this Policy, we typically keep personally identifiable and non-personally identifiable information for at least two (2) years after you last used the Site or Services. Users who have created an account may close their account by sending a request to ipecustomerservice@nbi-sems.com . Upon request, we will work with the user in terminating their account and to remove select information we have collected about the user. However, please note that we may disassociate posted content and information from the user in lieu of removing the same. Further, not all information can be deleted such as information which has been aggregated or is archived. We may also retain select information to prevent, investigate or identify any wrongdoing in connection with the Services or to satisfy other legal obligations.

We have implemented reasonable technical, physical and administrative safeguards designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services. The information you share in public areas may be viewed by any user of the Services.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

13. Changes to this Policy

We may update this Policy and/or the User Terms from time to time. If we make changes to this Policy, we will post the updated Policy on this page with a notice showing the date that this Policy was last updated. The dates this Policy was last reviewed and last modified are identified at the top of the page. You are responsible for periodically visiting this Policy and the User Terms to check for any changes. Your continued use of the Services after we revise this Policy and/or the User Terms means you accept this Policy and/or such User Terms as amended.

14. How to Contact Us

To ask questions or comment about this Policy and our privacy practices, you may contact us at:

Phone: 1-800-793-5274

Email: ipecustomerservice@nbi-sems.com

Postal Address:

NBI, Inc
Attn: Customer Service
1218 McCann Drive
Altoona, WI 54720

If you need to access this Policy in an alternative format, please contact us by one of the methods described above.

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