Privacy Policy

Effective Date: December 18, 2023

Last Updated: January 30, 2024

John Betlem (“Brand”) and our parent company Essential Services Intermediate Holding Corporation (“TurnPoint”, and together, “we”, “our”, or “us”) care about your privacy. Thank you for taking the time to read our privacy policy (“Privacy Policy”). This Privacy Policy covers all Personal Information processed by our website (https://www.johnbetlem.com), and our services (collectively, “Services”). If our privacy practices for certain services differ from those explained in this Privacy Policy, we will let you know at the time we ask for or collect your information.

It is our policy to comply with all applicable privacy and data protection laws, including the California Consumer Privacy Act of 2018 (“CCPA”), the Colorado Privacy Act of 2021 (“CPA”), Connecticut Data Privacy Act of 2022 (“CTDPA”), Nevada Act relating to the Internet Privacy of 2019 (“NAIP”), the Utah Consumer Privacy Act of 2022 (“UCPA”), the Virginia Consumer Data Protection Act of 2021 (“VCDPA”), and all other applicable federal and state privacy laws in the United States. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners, and others who share their data with us.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. We may make changes to the Privacy Policy from time to time. We, therefore, encourage you to check the Privacy Policy periodically for updates.

What is “Personal Information”?

Personal information means any information that’s about you. This information can be your name, your email address, your contact information, and anything else that tells someone something about you. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us from the Contact Us section.

Information We Collect

Through our interactions, we may collect different kinds of Personal Information about you which we have grouped together as follows:

Information You Provide Us:

Personal Identification Data includes your first name and last name, email address, physical address, phone number, Internet Protocol (IP) address.
Transaction Data and Contact Data includes your payment and transaction information, such as your credit/debit card number, your billing address, your first and last name, and billing address.
Employment Related Data includes information about your business, and your title at your business, prior employment information that you provide in your resume.
Communication Data includes your discussion with our customer support, other communications you send us, your communication through our chat message application, and your feedback that you communicate to us via email or social media.
Marketing Data includes names, physical addresses, and email addresses.

Information Automatically Collected by Technology:

In addition, to the information you provide to us, we may automatically collect certain information about your equipment, software, and browser to provide you with an efficient and personalized experience. This information includes:

Device Data which includes the device’s hardware information, operating system, platform information, browser type, language information, and browser plugin types.
Website Usage Data which includes information about how you use our website and our Services.
Website Log Data which includes logs such as pages on our Brand website that you access and the time of the day.

Information Collected from Third Parties:

We may collect personal or anonymized information about you from third party companies that provide products and services that are used in together with our website or our Services. For example, we may collect information from social networking sites, such as Facebook, X (formerly Twitter), Google Maps, LinkedIn and Google Analytics including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect with the TurnPoint or Brand accounts on such social networks.

Aggregated Data:

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Information, but Aggregated Data is not considered Personal Information, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing our websites and Services. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

We do not collect any special categories of sensitive Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data, and precise geolocation data). Nor do we collect any information about criminal convictions and offenses.

Reason for Processing Your Personal Information

Your Personal Information is used by us for the purpose it was collected, such as responding to your inquiry or completing your transaction for our Service. In some cases, Personal Information is required to perform certain functions. You voluntarily decide if you want to provide us with your information. You may be asked to provide your Personal Information to:

Complete a transaction with us for Services, including to process payments and refunds and to deliver Services as requested;
Enter into and manage contractual relationship(s) with you;
Send you marketing materials or special offers you sign up for;
Inform you of new services, products, and other promotions, if you agree to such notifications;
Respond to questions or comments from you;
Provide customer support;
Detect, prevent, and address technical issues on the website;
Gather analysis or valuable information enabling us to monitor the usage of our websites;
Improve our website and Services;
Post your testimonials on our website;
Address legal issues, including (i) complying with our obligations to retain certain business records; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal processes; (iv) detecting and preventing fraud or intellectual property infringement claims, violations of our contracts or agreements, violations of law, or other misuses of our websites or Services; and (v) protecting our rights or property, or yours or others’ health, safety, welfare, rights, or property; and
Allow you to exercise your data privacy rights.

In addition, we may process your personal data for the following reasons:

To carry out our obligations and enforce our rights.
In any other way we may describe when you provide the information.
For any other purpose with your express consent.

We may use information that is not Personal Information for any purpose. For example, we may aggregate usage data from many people in a way that does not identify any individuals to calculate the percentage of users accessing a feature on our website. Such aggregated or anonymized data will not identify you or be traced back to your Personal Information.

How we collect your Personal Information

We use different methods and sources to collect information from and about you including through:

Direct interactions. You may give us information about you by interacting with our website, by communicating with us via email or contact us page, or by interacting with us over social media.
Third party or publicly available sources. We may receive information about you from third parties. The information we receive includes analytics information for improvement of our website and Services.
Technical and Communication Data from the following parties: We may collect information from third party providers such as Facebook, X (formerly Twitter), Google Maps, LinkedIn and Google Analytics (“Third-Party Apps”). The information we may collect includes your feedback about our Services on our Brand pages found on the respective Third-Party Apps.

Disclosure of Your Personal Information

We may disclose your contact information, communication information, usage information, and information from surveys to the following third parties:

Our affiliates. Our affiliates will use your information in a manner consistent with this Privacy Policy and applicable data privacy laws.
Subcontractors. Any subcontractors, who may assist us to operate the website or perform the Services, are required to collect, use, retain, or process information in compliance with applicable data privacy laws.
Regulatory entities. We will disclose your information if we have a good faith belief that the disclosure is necessary to comply with any applicable law or legal process, to prevent fraud or imminent harm, to ensure the security of the websites, and to protect Brand and TurnPoint rights.
Third parties for mergers. We may disclose your information in connection with mergers and reorganization. In such cases, we will take appropriate steps to protect your information.

We may also share your Personal Information with your consent or at your express request. We may share anonymized or Aggregated Data internally, service providers and with third parties for any purpose. Such information will not identify you individually.

Cookies and Automatic Data Collection Technologies

Our website may use automatic data collection technologies to distinguish you from other website users. This helps us deliver a better and more personalized experience when you browse our website. It also allows us to improve our website by enabling us to:

Estimate our audience size and usage patterns.
Store your preferences, so we may customize our website according to your individual interests.
Recognize you when you return to our website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. For information about managing browser settings to refuse cookies, see Your Rights and Choices.
Web Beacons, Pixel Tags, Clear Gifs. Our website pages and emails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording website content popularity or verifying system and server integrity. For information about managing web beacons, see Your Rights and Choices.

Third Party Links

Our websites include links to other websites whose privacy policies may differ from this Privacy Policy. If you submit Personal Information to any of those sites, such information is subject to third party privacy statements. We strongly encourage you to carefully read the privacy statement of any website you visit.

Retention

We will retain your Personal Information as reasonably necessary for the disclosed purpose. The retention periods for each category of Personal Information, including sensitive information, vary depending on compliance with relevant laws, your request for deletion, and our retention policies. For example, we may need to retrain your Personal Information to comply with our legal or reporting obligations in accordance with the laws or to defend against claims or for internal analysis purposes (such analysis purposes are generally subject to shorter retention periods, whenever possible). Consequently, it is not possible for us to provide a definitive length of time. Our retention periods are determined by using and balancing the following criteria:

The volume, nature, and sensitivity of your information;
The potential risk of unauthorized access, use or disclosure, or misappropriation;
The purposes for which we process your Personal Information; and
The retention obligations under applicable legal requirements.

Children

Our website and Services are not intended for children under 13 years of age. We will not knowingly solicit or collect Personal Information from children under 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law. If we learn that we have received information directly from a child under 13 without his or her parent’s or legal guardian’s consent, we will make commercially reasonable efforts to delete such information.

Your Rights and Choices

Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.

Accessing, Updating, and Deleting Your Information. You can contact us as set forth in the Contact Us section below to request access to, correction of, or deletion of Personal Information that you have provided to us. We may also ask you to verify your identity before we respond to your request. Depending on your request, we may not accommodate your request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.
Opt-out from sharing Personal Information for targeted Advertising. Visitors to our website may opt-out from us sharing your Personal Information for targeted advertising or cross-context behavioral advertising. To opt-out, please go to “Your Privacy Choices” link or contact us at [email protected].
Cookies and Automatic Data Collection Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies, please note that some parts of these websites may become inaccessible or not function properly.

California Residents. If you are a California resident, you may have additional personal rights and choices with regard to your Personal Information. Please see Your California Privacy Rights in the California Consumer Protection Act Notice for more information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information in the Contact Us section.
Colorado Residents. This section concerning the CPA applies solely to individuals who are residents of the State of Colorado. Colorado residents have the following consumer rights:
Right to opt-out of targeted advertising, sale of Personal Information or profiling for automated decision purposes
Right to know about Personal Information collected or disclosed
Right to request deletion of your Personal Information
Right to request correction
Right to limit the use of your sensitive personal data

We note that we do not sell your Personal Information.

For the specific details of the rights and the process for submitting consumer rights requests, please submit your consumer request to Brand at [email protected] and write “Request for Colorado Privacy Data” as the subject of the message. We will not discriminate against consumers who exercise their consumer rights.

Connecticut Residents. This section concerning the CTDPA applies solely to individuals who are residents of the State of Connecticut. Connecticut residents have the following consumer rights:
Right to opt-out of targeted advertising, sale of Personal Information or profiling for automated decision purposes Right to know about Personal Information collected or disclosed
Right to request deletion of your Personal Information
Right to request correction
Right to limit the use of your sensitive personal data

We note that we do not sell your Personal Information.

For the specific details of the rights and the process for submitting consumer rights requests, please submit your consumer request to Brand at [email protected] and write “Request for Connecticut Privacy Data” as the subject of the message. We will not discriminate against consumers who exercise their consumer rights.

If we deny your consumer request, consumer shall have the right to appeal the denial of the request. Consumers may appeal their consumer requests by emailing us at [email protected] explaining why the denial of the request should be reconsidered. We will provide a response no later than sixty days after receipt of the appeal informing the consumer in writing if any action was taken or was not taken in response to the appeal and the reasons for the decisions.

Nevada privacy rights
Nevada residents have the right to opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we do not have plans to sell this information.
Utah Residents. This section concerning the UCPA applies solely to individuals who are residents of the State of Utah. Utah residents have the following consumer rights:
Right to opt-out of targeted advertising, sale of Personal Information or profiling for automated decision purposes
Right to know about Personal Information collected or disclosed
Right to request deletion of your Personal Information

We note that we do not sell your Personal Information.

For the specific details of the rights and the process for submitting consumer rights requests, please submit your consumer request to Brand at [email protected] and write “Request for Utah Privacy Data” as the subject of the message. We will not discriminate against consumers who exercise their consumer rights.

Virginia Residents. This section concerning the VCDPA applies solely to individuals who are residents of the State of Virginia. Virginia residents have the following consumer rights:
Right to opt-out of targeted advertising, sale of Personal Information or profiling for automated decision purposes
Right to know about Personal Information collected or disclosed
Right to request deletion of your Personal Information
Right to request correction
Right to limit the use of your sensitive personal data

We note that we do not sell your Personal Information.

For the specific details of the rights and the process for submitting consumer rights requests, please submit your consumer request to Brand at [email protected] and write “Request for Virginia Privacy Data” as the subject of the message. We will not discriminate against consumers who exercise their consumer rights.

Exercising Your Privacy Rights.

To exercise your right to know, right to obtain a copy, or right to delete your Personal Information as described above, please submit your consumer rights request to us by contacting us at: [email protected] or submit your request at Privacy Request Form.

Before fulfilling your request, we take steps to verify that you are who you say you are or you have the authority to act on someone else’s behalf. Therefore, upon receipt of your request, we may request additional information that we need to verify you and, if you are submitting a request on behalf of someone else, to verify that you are permitted to act on that person’s behalf.

When we contact you to request verification information, please respond and provide the information that we have requested. Depending on the nature of your request, we will verify your identity to either a reasonable or high degree of certainty. This may mean that we need to match two or three pieces of information that we hold about you with information that you provide to us.

In addition to providing the information we need to verify you or your authority, you must provide us with enough information so that we can understand, evaluate, and respond to your request. We cannot respond to your request or provide you with Personal Information if we cannot confirm the Personal Information relates to you.

We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request and to locate relevant information. 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 to understand, evaluate, and respond to your request.

We cannot delete Personal Information in those situations where our retention is required for our own internal business purposes or otherwise permitted by applicable laws (such as fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.

We will attempt to respond to your privacy request within forty-five (45) days of receipt. If we require an additional forty-five (45) days to respond to your request. 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 we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. When you request a copy of your Personal Information, 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 easily.

We do not charge a fee to process or respond to your privacy 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 a cost estimate before completing your request.

If we deny your privacy request, you have the right to appeal the denial of the request. You may appeal your request by emailing us at [email protected] explaining why the denial of the request should be reconsidered. We will provide a response no later than sixty (60) days after receipt of the appeal informing the consumer in writing if any action was taken or was not taken in response to the appeal and the reasons for the decisions.

International Transfers

We are a company located in the United States and our Services are provided to individuals residing in the United States. If you are using our website from outside the United States, you should be aware that the information collected on this website may be stored and processed in the United States, or any other country in which Brand, our affiliates or service providers maintain facilities, including hosting services or servers. By providing your information to our website or Services, you are consenting to the transfer of your information (including placing cookies) outside of your country in accordance with this Privacy Policy. You are also consenting to the application of United States law in all matters concerning our website and Services.

Data Security

The security of your Personal Information is very important to us. We use physical, electronic, and administrative safeguards designed to protect your Personal Information from loss, misuse and unauthorized access, use, alteration, or disclosure. We will only retain your Personal Information for as long as reasonably necessary to fulfill the purpose of collecting it.

We also require our service providers and business partners to whom we disclose the information to do the same. When you use certain types of information, for example, when you provide us with your credit card or debit card information on our website, we will encrypt the transmission of that information using industry standard secure socket layer technology (SSL). We will continue to improve our physical, electronic, and administrative safeguards. However, the Internet environment is not 100% secure, and we cannot guarantee that information we collect will never be accessed in an unauthorized way. You may request additional information about our certification by writing to [email protected] with the subject line, “Security Inquiry.”

Changes To This Privacy Policy

Changes to this Privacy Policy will be posted on this site, along with information on any material changes. The Company reserves the right to update or modify this Privacy Policy at any time and without prior notice.