Privacy Policy

Effective June 2019 (Archived versions)

Facet Interactive LLC's ("Facet", "us", "we" or "our") Privacy Policy describes the privacy and data security principles followed by Facet regarding the personal information of individuals who visit our website, as well information and data of our clients and licensees. Personal information includes any data by which an individual can be identified or located. This Privacy Policy will help you understand how we collect and use your personal information.

This Privacy Policy also describes how we handle information and data we may access as we perform services on behalf of our clients. This Privacy Policy applies to the collection, hosting, storage, security, processing, transfer, use of, and access to personal information, and client information and services data, except where a written contract with a covered individual defines different requirements.

This policy does not apply to third-party websites, products, or services (including our clients’ websites, products or services) even if they link to our services, and you should review and consider the privacy practices of those third parties carefully.

Important Notice to Users Outside the United States – Our website is operated in the United States and our services are provided to individuals and entities within the United States (unless specified otherwise in a customer contract). If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through our website, you consent to this transfer.

By using our services and accessing our website, you are accepting the practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use our website or services.

How We Collect and Use Information

Depending on how you use our website and our services, we may collect the following types of information and use it in the following manner:

Personal Information includes any data by which an individual can be identified or located. We collect and use your personal information to provide our products and services, as well as products and services of our licensors to you, and to operate and improve our site and services. We will only use your personal information in ways outlined in this Privacy Policy. 

Client Information is information that we may collect from your use of our website and your interactions with us off-line. We deal with client information according to the terms of this Privacy Policy.

Accessing our website – Log Files - Like most websites, our site automatically collects and uses the data contained in log files. Information in log files may include your computer's IP (internet protocol) address, your ISP (internet service provider), the web browser you used to visit our site, the time you visited our site, which web pages you visited, and other anonymous site usage data. Every computer with internet capability is given a number that serves as that computer's IP address. When you request a page from our website, our web servers automatically recognize your IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed our site. We may use this information to examine traffic in aggregate, investigate misuse of Facet’s website, detect fraud, or cooperate with law enforcement.

Accessing our website - Information you provide - We offer access to our website without requesting that you provide personal information, however, you may provide us personally identifiable information (such as your name and email address) if you use our "Let’s Talk" service and our online appointment scheduling page. You may also voluntarily provide us personal information if you use our online "chat" function, or email us directly with questions.if you use our online "chat" function or Whatever we conclude, we need to fix the terms so

Services Data - Is information and data that resides on our clients’ or third-party systems to which Facet is provided access to perform services (including test, development and production environments that may be accessed to perform consulting, business analytics, and support services). Facet treats services data in accordance with the terms of this Privacy Policy, except where the confidentiality provisions within a written contract with a client define different requirements.

To illustrate the difference between client information and services data, when a client contracts with us for services, the client provides information about itself, including its name, business and email addresses, billing information, and some employee contact information. When a client uses our website to contact us or learn about our services, our website also collects information about the client. All such information is client information, and is treated according to this Privacy Policy.

In contrast, when a client contracts with us to perform services, that client may provide us with confidential information such as business analytics and related information, together with access to its production, development or test environment, which may include personal information about its employees, customers, partners or suppliers. All such information is services data.

Below are the conditions under which we may access, collect and/or use services data:

To Provide Services and Develop New Ones – We may access and use services data to fulfill our obligations under a contract or statement of work with a client. We may also use services data to help us improve our services or develop new services. 

To Maintain and Upgrade a System - Technical staff may require periodic access to services data to monitor system performance, test systems and develop and implement upgrades to systems, if applicable. Any temporary copies of services data created as a necessary part of this process are only maintained for time periods relevant to those purposes.

To Address Performance and Fix Issues - On occasion, we may need to deploy new versions, patches, updates, and other fixes to our programs (or third-party programs we support) and services. In accordance with the terms of a client’s contract and/or with notice to a client, we may access and/or use a copy of our client’s test, development or production environment, including services data, to test such new versions, patches, updates and fixes and validate that they work in our client’s environment(s).

Subcontractors - If we hire subcontractors to assist in providing our services, their access to services data will be consistent with the terms of this Privacy Policy, except where the confidentiality provisions within a client’s contract define different requirements.

We do not use services data except as stated above or in your services contract. We may process services data but do not control your information collection or use practices for services data. If you provide any services data to us, you are responsible for providing any notices to your employees, customers and other parties impacted and/or obtaining any consents necessary from such individuals or entities for us to access and use your services data as specified in this Policy and your services contract.

How we and others may communicate with you using the information you provide - We communicate with you through email and notices posted on our website. Examples of these email notices include: (1) welcome and engagement messages - when you contract with Facet or contact us through our website, we may send you a series of emails to inform you about how to best use our services, as well as to inform you of new features; (2) service messages – these will cover service availability, security, and other issues about our operations; and (3) promotional email messages, which may contain promotional information about us or our business partners. We may provide your contact information to our business partners for marketing purposes, however, we do not sell, rent or otherwise give your email address to any third party without your consent. You may change your email and contact preferences, or any other personal information, at any time by notifying us as explained in more detail at the end of this policy under the "Your Privacy Rights: Opting Out of Marketing and Transfers; Accessing Updating and Deleting Information" section of this Policy. If we use your information in a manner different than the purpose for which it was collected, we will ask for your consent before engaging in such other use. We provide you with tools to opt out of receiving marketing from us and certain transfers of your information.

       Cookies and Other Technologies - When you visit our website, we may send one or more "cookies" to your computer. Third-party websites you access through our website may also send cookies to your computer. A cookie is a small piece of data that is sent to your browser from a web server and stored on your computer's hard drive. We use cookies to improve the quality of our services and store your user preferences or log-in information, as well as for marketing purposes. Cookies are also used to analyze trends, administer our website, track users’ movements around our website, and gather demographic information about our user base. You can choose whether to accept cookies by changing your browser settings (see below under How can I control cookies).

What types of cookies do we use and how do we use them?


  • Essential website cookies: These cookies are strictly necessary to provide you with services available through our website, and to use some of a website’s features, such as access to secure areas.
  • Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our website but are non-essential to its use. However, without these cookies, certain functionality may become unavailable.
  • Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our website is being used or individually to help us understand how effective our marketing campaigns are.
  • Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.
  • Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our website through third party social networking and other websites. These cookies may also be used for advertising purposes.

How can I control cookies?

You have the right to decide whether to accept or reject some cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links described below.

You can set or amend your web browser controls to accept or refuse certain cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. How you can refuse cookies through your web browser controls vary from browser-to-browser, accordingly, you should visit your browser's help menu for more information.

In addition, most advertising networks offer you a way to opt out of targeted advertising.  If you would like to find out more information, please visit You may also opt out of behaviorally targeted ads by clicking here: (or if located in the European Union, by clicking here: Please note this does not opt you out of being served advertising that is not targeted based on your online behaviors. You will continue to receive generic advertisements.


Other tracking technologies - Web Beacons

Cookies are not the only way to recognize or track visitors to a website. We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage our website by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs or pixels in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our customers' personal information.

      Do Not Track - Our systems do not recognize browser "Do Not Track" signals. We provide you with tools to opt out of marketing from us or certain transfers of your information. You can learn about this under “Your Privacy Rights: Opting Out of Marketing and Transfers; Accessing, Updating and Deleting Information”.

       Links to Other Sites – This Privacy Policy applies only to our website and products and services directly offered by us. Although we may provide links to internet sites or resources administered by third parties, we do not exercise control over any third-party sites, or the third-party products or services offered on such sites. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We cannot protect the privacy of the information you share with any such third party and we suggest that you review their applicable privacy policies. We may present links in a format that enables us to keep track of whether third-party links on our website have been followed. We use this information to determine which sites are being accessed and how often, and to improve our services.

Other Requested Information

We may request your name, e-mail address or mailing address for the purposes of conducting a promotion or survey, or providing additional services (for example, subscriptions to our blog or newsletters, or promotional announcements). When making such a request, we will indicate the purpose of the inquiry. If we use this information in a manner different than the purpose for which it was collected, we will ask for your consent before engaging in such other use.

Potential Disclosure of Your Information

We may disclose personal information and an IP address when we have your consent or have the good-faith belief that such action is reasonably necessary to:

  1. satisfy any applicable law, regulation, legal process or enforceable governmental request;
  2. protect and defend the rights of our website and related properties, or visitors to our website and related properties;
  3. identify persons who may be committing a fraud or otherwise violating the law; and
  4. cooperate with investigations of purported unlawful activities.

Some of our services may be co-branded and offered in conjunction with another company. If you register for or use such services, both Facet and the other company may share information collected in conjunction with the co-branded services.

Security of Your Information

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Other than as set forth in the last sentence in this paragraph, we restrict access to your information and data to our employees, contractors, agents and authorized third parties who need to know the information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations. As noted above in the section entitled “How we and others may communicate with you using the information you provide”, we may provide your contact information to our partners for marketing purposes.

Data Integrity

We process information only for the purposes for which it is collected and in accordance with this Privacy Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the information needed to provide or improve our services or as otherwise permitted under this Privacy Policy.

Shine the Light Law

Under California Civil Code Section 1798.83, California residents who have an established business relationship with us may choose to opt out of our sharing their contact information with third parties for direct marketing purposes. If you are a California resident and you wish to opt out, please follow the instructions below.

Your Privacy Rights: Opting Out of Marketing and Transfers; Accessing, Updating and Deleting Information

We want to communicate with you only if you want to hear from us. If you wish to opt out of receiving our marketing efforts or our sharing information with third parties for their marketing efforts, you may do so, at any time by clicking on the “unsubscribe” link in any email you receive from us and following the instructions on the screen. Please be aware that you cannot opt out of receiving our service messages.

You may also update your information, or opt out of receiving our marketing efforts or our sharing information with third parties by contacting us at: or by phone at 323-909-2005, or mail your request or questions to:

Facet Interactive LLC
840 Apollo Street, Suite 100
El Segundo, CA 90245

Please note that, from time to time, information collected from you may be processed and stored by us or our partners in jurisdictions in which disclosure may be compelled by governments, law enforcement agencies and regulatory bodies of those jurisdictions as required or permitted by the laws and courts of those jurisdictions. Depending on the laws of the applicable jurisdiction, we may not be allowed to provide notice to you of such required disclosure.

We may also share your personal information and other information with entities controlling, controlled by, or under common control with us. If some or all of our business assets are sold or transferred, we would transfer your information to the buyer or transferee and for due diligence purposes to its professional advisors under an obligation of confidentiality. If we are involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information, client data and services data and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

Changes to this Policy

Our Privacy Policy may change from time to time. If we do make changes, we will post any policy changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.  Each version of this Privacy Policy will be identified at the top of the page by its effective date, and we also keep earlier versions of our Privacy Policy archived for your review. We encourage you to check back regularly and review any potential updates. Your continued use of our website will be subject to the terms of the then-current Privacy Policy. Please send any questions about our Privacy Policy to the contact email and address above.