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5) Handling of Advocate, Client, or Corporate InformationUpdated 3 months ago

5) Handling of Advocate, Client, or Corporate Information

5.1 USE OF INFORMATION: An Advocate’s database of their Clients, or of other Advocates, is confidential and is to be used solely for the purpose of running their Crunchi business. It may not be sold, copied, or distributed to any third party for any reason. Crunchi may use an Advocate’s database in connection with marketing, and sales promotions, related to the busi- ness or to Crunchi.

5.2 CRUNCHI CORPORATE INFORMATION: Advocates may not act on, or benefit in any way from, any non-public information about Crunchi, or its future plans, to pursue any aspect of the Advocate’s business prior to the public announcement of such information by Crunchi. This includes but is not limited to, information about potential or upcoming events, sales, products, promotions, discounts, hiring, corporate planning, advertising campaigns, marketing, or other business plans relating to Crunchi, its Advocates, staff, or Clients. This non-public information may include, but is not limited to, information gained through relationships, conversations, and communications, with Crunchi employees, owners, or the corporate team. Any actions taken prior to public announcement will be deemed a violation of the Agreement.

5.3 HANDLING PERSONAL AND CONFIDENTIAL INFORMATION: Advocates may receive personal and confidential information (“Client information”) from, or about, Clients, future Advocates, or other Advocates. Client information is information that identifies, or permits an Advocate to contact, an individual. It includes an individual’s name, address, email address, phone number, credit card information, and other information associated with these details, such as purchases. Advocates have a responsibility to carefully safeguard all Client information in their care. Keeping this information secure not only helps to ensure compliance with the law but also protects Crunchi Clients.

5.4 STRATEGIES REGARDING COLLECTING, USING, OR STORING CLIENT INFORMATION:

a. Give the Client notice: Tell Clients what information is being collected, why, and with whom it will be shared. Advocates should use and share information only as indicated to the Client.

b. Sales through the website: Handle your Client sales through your secure replicated website.

c. Collect only what is needed: Collect only the necessary information. For example, do not collect a credit or debit card number unless the Client actually makes a purchase.

d. Give the Client control: Give Clients a choice about how to communicate with them. For instance, find out if a Client wants to receive promotions and other marketing messages and, if so, whether they would prefer to receive them by email, phone, or another method of communication. Respect the Client’s wishes: If a Client does not want to receive texts, for example, then find another way to communicate.

e. Stay up-to-date: Keep the Client’s information up-to-date. Keeping contacts current helps Advocates to stay in touch with Clients.

f. Share only if necessary: Do not share Client information unless there is a valid business reason to do so. Then, share only what is necessary and ensure the information will be protected.

g. Be careful: A Client’s information is a valuable asset and is protected by Crunchi’s confidentiality provisions. Do not share it publicly or communicate it to anyone unless there is a legitimate need. Protect it from unauthorized access or disclosure. If Client information falls into the wrong hands, Clients could become the victim of fraud or identity theft.

h. Pay attention: Pay attention to the surroundings when collecting Client information and use good judgment whenever you need to discuss or transmit Client information.

i. Storage: Keep Client information in a secure place, such as a locked drawer, file cabinet, or box. Do not leave it lying around where someone could see or take it. Use similar safeguards to keep Client information on a computer, tablet, or phone. For example, use passwords that are complex to guess, install virus protections, and password-protect documents that contain Client information. Avoid storing Client information on a laptop, phone, or another portable device that could be lost or stolen, unless the device is encrypted.

j. Disposal: When a Client’s information is no longer needed it should no longer be used. Client information should be disposed of in a way that makes it unreadable, such as by shredding paper documents or deleting or encrypting computer data. Do not keep Client information any longer than necessary for the business to help avoid unnecessary risk.


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