Privacy Policy
Effective Date: January 1, 2020
Last Updated: January 1, 2023
The Privacy Policy describes how Orkin, LLC and its subsidiaries (collectively, “Orkin,” ”us,” “we,” and “our”), collect, store, use and disclose personal information about you. This Privacy Policy applies to information we collect or receive when you visit or use our website (“Site”); contact our customer service team; engage with us on social media; communicate with us; apply to work for us; consider or apply for franchise or ownership opportunities; use, request, purchase, obtain or consider our pest, wildlife, termite, bed bug, or mosquito control services (our “Services"); or otherwise interact with us.
This Privacy Policy does not apply to information collected in the course of, or in connection with, your work for us as an employee or independent contractor.
If you have any questions, please contact us as provided below. If you have a disability and need to receive this Privacy Policy in a different format, please contact us at privacy@orkin.com.
Please read this Privacy Policy carefully to understand our policies and practices. By using the Sites or providing your personal information to us, you signify that you consent to the use of your information in accordance with this Privacy Policy. If you do not agree with any term in this Privacy Policy, you should not access and use the Website or Apps and please do not otherwise provide us with any personal information.
Contents
Categories of Personal Information We Collect
Sources Of Personal Information
Purposes for Collecting Personal Information
How We Disclose Personal Information
We Combine Information
Sensitive Personal Information
How Long We Keep Personal Information
Cookies, Analytics, and Other Tracking Technology
Links to Other Websites
Security
This Website is Not Intended for Minors
Marketing Communications
Processing in the United States
California Privacy Rights
Contact Us
Updates to Our Privacy Policy
Categories of Personal Information We Collect
The type of information that we collect depends on your interaction and relationship with us. We collect, and in the preceding 12 months have collected, the below categories and types of personal information with your consent or as otherwise required or permitted by law.
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Contact Information. We collect full name, email address, current and prior address, telephone number, and business contact information.
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Identifiers. We collect social security number, driver’s license number, passport number, state identification card number, I-9 documentation, internet protocol address, social media handles or IDs (such as your Facebook ID), account usernames and passwords, and signature.
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Personal Characteristics or Traits. We collect date of birth, gender, age, nationality, racial or ethnic origin, religion, marital status, citizenship status, military or veteran status and disability information.
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Financial Information. We collect tax identification number, financial or bank account information, tax-related information, wire instructions, payment card number, payment card expiration date and CVV code, and billing address. If you apply for franchise or ownership opportunities or apply for financing, we may also collect information concerning your credit history, income level, personal wealth, and financial condition.
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Commercial Information. We collect records of products or services purchased, obtained, or considered and purchasing histories.
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Internet or Electronic Usage Data. We collect data related to network and website interaction history, IP address, website cookie information, interaction with advertisements and browsing time.
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Audio/Visual Data. We collect audio, electronic, photographic, visual or similar data including videos, photographs, and audio recordings.
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Geolocation Data. We collect geolocation data including the general region or area from which you access our Sites.
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Professional or Employment Information. If you apply for franchise or ownership opportunities, for financing, or to work for us, we will collect certain professional or employment information. We collect job application details, previous work history, current employment information, and professional memberships and certifications.
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Education Information. If you apply to work for us as an employee or independent contractor, we will collect education history, degrees, transcripts, qualifications and certifications.
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Sensitive Information. Where permitted by law, we may collect social security number, driver’s license number, passport number, state identification card number, racial or ethnic origin, religious or philosophical beliefs, or union membership, health information, and sexual orientation.
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Inferences: We use information from the categories of personal information described above in order to create a profile about you, to reflect your preferences, characters, behavior and attitude.
Sources Of Personal Information
We collect, and in the preceding 12 months have collected, personal information in the following ways:
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Directly from you. We collect contact information, identifiers, personal characteristics or traits, financial information, commercial information, audio/visual data, professional or employment information, education information, and sensitive information that you provide directly to us.
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When you visit our locations. When you visit our offices or facilities, we also collect contact information and audio/visual data.
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Automatically. When you access our Sites, we collect identifiers, geolocation data, and internet or electronic usage data using tools like browser cookies.
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From third parties: We may collect contact information, identifiers, personal characteristics or traits, commercial information, audio/visual data, professional or employment information, education information, and inferences from third-parties including our vendors, clients, recruiters, suppliers, service providers.
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From our employees or job applicants. We collect contact information, identifiers, personal characteristics or traits, financial information, commercial information, audio/visual data, professional or employment information, education information, and sensitive information from our current or former job applicants, contractors and employees.
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Social media platforms. Depending on the information you choose to share and your privacy settings, we may collect contact information, identifiers, audio/visual data, personal characteristics or traits, geolocation data, commercial information, professional or employment information, internet or electronic usage data, and inferences. Based on the way you have set your privacy settings on your social media accounts, most social media platforms, like Facebook and Instagram, analyze data about how you interact with our Sites and combine it with information on other users to provide us information about you. In addition, we may receive information about you if other users interact with us on social media and information about you is visible to us, for example the fact that you are “friends” or other public-facing profile information.
Purposes for Collecting Personal Information
We use personal information for the following business and commercial purposes:
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Providing our Services. We use contact information, identifiers, financial information, commercial information, audio/visual data, professional or employment information to allow customers to contract for and purchase our Services, provide the products and Services we have contracted for, process payments, and provide updates and reports requested by customers.
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Transactional Purposes. We use contact information, identifiers, financial information, professional or employment information, and commercial information to: (i) communicate with you; (ii) provide you with customer assistance; (iii) administer contracts with our vendors, customers, and service providers; and (iv) provide supporting business activities such as billing and collections, procurement, and tax related activities;
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Recruiting and Hiring. We use contact information, identifiers, audio/visual data, professional or employment information, education information, financial information, sensitive personal information, and inferences make informed decisions on recruitment and assess your suitability for the role, communicate with you about your application, respond to your inquiries and schedule interviews, and to reimburse you for any agreed expenses incurred in the application process.
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Background and Credit Checks. We may require our applicants to complete a background check to verify your identity, check for criminal history, check your credit worthiness, and confirm the validity of your application. We use identifiers, personal characteristics or traits, professional or employment information, non-public education information, and sensitive information to enable the completion of the background check.
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Financing. We use contact information, identifiers, financial information, commercial information, professional or employment information, and inferences to evaluate your application to obtain credit or financing from us.
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Franchisee Assessment. We use your contact information, financial information, identifiers, personal characteristics or traits, education information, and inferences in order to assess your suitability to become a franchisee or owner. We may combine the information you provide to us with information we obtain from third parties, such as credit reporting agencies and public records databases. We use this information to conduct due diligence on potential franchisees and owners.
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Business Operations. We use contact information, identifiers, personal characteristics or traits, financial information, audio/visual data, professional or employment information, education information, sensitive information, and inferences for our day-to-day business operations including maintaining records, manage our facilities, planning, budgeting, calibration, headcount, database administration, diversity metrics, surveys, evaluations, reports, compliance, regulatory, audit, investigative and disciplinary purposes and other ethics and compliance reporting tools, and to support our business operations.
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Analytics. We use identifiers, internet or electronic usage data, geolocation data, commercial information, and inferences to analyze preferences, trends and statistics.
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Marketing and Promotional Purposes. We use contact information, identifiers, financial information, professional or employment information, internet or electronic usage data, geolocation data, and inferences to improve our marketing efforts, conduct market research, prospect for new clients or consultants, engage in client relationship management, client engagement, administering promotions, and to provide you with information about us, including personalized marketing communications.
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Maintenance and Improvement of our Sites and Systems. We use contact information, identifiers, geolocation data, internet or electronic usage data to improve our Sites and systems, provide and maintain functionality on our Sites and systems, and help us diagnose technical and service problems and administer our Sites and systems. Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing IT Service Desk / Help Desk Support.
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Develop and Improve Our Services. We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to help us develop new products and services and to improve and analyze our existing service offerings.
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Security and Fraud Prevention. We contact information, identifiers, personal characteristics or traits, financial information, commercial information, internet or electronic usage data, audio/visual data, geolocation data, professional or employment information, education information, sensitive information, and inferences to: (i) protect us, our employees, and our Sites, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
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Legal: We use contact information, identifiers, personal characteristics or traits, financial information, commercial information, internet or electronic usage data, audio/visual data, geolocation data, professional or employment information, education information, sensitive information, and inferences to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
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Other Purposes: We may use contact information, identifiers, personal characteristics or traits, financial information, commercial information, internet or electronic usage data, audio/visual data, geolocation data, professional or employment information, education information, sensitive information, and inferences for other reasons we may describe to you.
How We Disclose Personal Information
We disclose personal information in the following circumstances:
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Service Providers. We may share personal information with vendors and service providers who support the operation of our services, website, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, payment processing, order fulfillment, email delivery, marketing, insurance, operating systems and platforms, transportation, and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf. In the past 12 months, we have disclosed contact information, identifiers, personal characteristics or traits, financial information, commercial information, internet or electronic usage data, audio/visual data, geolocation data, professional or employment information, education information, sensitive information and inferences to our service providers.
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Affiliates. We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns. A list of such companies is available at https://www.rollins.com/businesses. In the past 12 months, we have disclosed contact information, identifiers, personal characteristics or traits, financial information, commercial information, internet or electronic usage data, audio/visual data, geolocation data, professional or employment information, education information, sensitive information and inferences to our affiliates.
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Analytics/Advertising Partners. We may share personal information with third party analytics or advertising partners, including social media platforms and networks, who provide analytics or marketing and advertising services to us. In the past 12 months, we have disclosed identifiers, commercial information, internet or electronic usage data, geolocation data, and inferences to our service providers.
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Professional Advisors. We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us. In the past 12 months, we have disclosed contact information, identifiers, commercial information, financial information, professional or employment information, education information, sensitive information and inferences to our professional advisors.
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Government Entities. We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us. In the past 12 months, we have disclosed contact information, identifiers, personal characteristics or traits, financial information, commercial information, professional or employment information, and sensitive information to government entities.
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Corporate Transaction Recipients. We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments. We have not disclosed any personal information to corporate transaction recipients in the last 12 months.
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Other Reasons. We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.
We Combine Information
We combine information we obtain from different sources with publicly available information, including to create inferences about you. For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.
Sensitive Personal Information
Unless specifically requested, we ask that you not send us, and you not disclose to us, through the Services or otherwise, any Sensitive Personal Information (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).
How Long We Keep Personal Information
We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future. We use the following criteria to determine retention periods:
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how long the information is needed to provide our services, operate our business and assert our legal rights;
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whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
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whether any law, statute, or regulation allows for a specific retention period;
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whether an individual has agreed to a longer retention period;
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whether the data is considered to be sensitive data; and
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what the expectation for retention was at the time the data was provided to us.
Cookies, Analytics, and Other Tracking Technology
Cookies and Tracking Technology
When you access the website, we (and third-party companies we work with) may collect information and store certain information by either placing small data files on your device or using other technologies such as server logs, cookies, web beacons, clear gifs, tags, e-tags, flash cookies, log files, pixels, mobile advertising IDs (such as Facebook cookies or Google's Advertising ID), cross-device linking, and similar technologies. The information collected includes information about your activities on our Sites, IP address, browser or operating system type and version, device IDs, and demographic or inferred-interest information, as well as information or communications you have submitted to us through the Sites.
We use this information to understand general usage and volume statistics, how users navigate to and around our Sites, what content is viewed or accessed, and which services have been obtained. We also use these technologies to keep track of your preferences and profile information. We also use these technologies to allow third-parties to provide analytics and advertising services and serve advertisements on our behalf across the Internet and in mobile applications. For example, our advertising partners may use the fact that you visited our Site to target advertising to you on other websites and mobile apps on your current device or on other devices you use. They may match your browsers or devices if you log into the same online service on multiple devices. These third parties partners may use this information for our and their own advertising, analytics, attribution, and reporting purposes. To learn more about interest-based advertising, tracking technologies, and how to opt out, please visit http://www.aboutads.info/choices. You can disable the sharing of your personal information for cross-contextual behavioral advertising or targeted advertising through online cookies and tracking technology by clicking here or on the Your Privacy Choices link on our Site footer and disabling performance and functional cookies.
Session Replay
We use session replay technology on our Sites. Session replay technology, also referred to as session playback or user experience (UX) replay, collects information regarding, records, and tracks your interactions with a website or application. It then and transforms those logged user events (such as mouse movements, clicks, page visits, scrolling, tapping, etc.) into a reproduction of what you actually did on the website or application. We use session replays for quality control, customer service, fraud prevention and security, and marketing purposes. Our session replay technology is owned and operated by a third-party who acts as our service provider. The information collected by this technology may be collected by, transferred to, and stored by our third-party service provider.
Do Not Track Signals
Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.
Google Analytics
We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides a an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.
Links to Other Websites
Our Sites may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use.
Security
We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.
This Website is Not Intended for Minors
Our Site is not intended for use by individuals under the age of 13. We do not knowingly collect or store any personal information from anyone under the age of 13. If we become aware that we have collected or stored personal information from an individual under age 13, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us by sending an email to privacy@orkin.com.
Marketing Communications
Marketing Emails. You can opt out of marketing or advertising emails by using the "unsubscribe" link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us at privacy@orkin.com. Once we process your request, we will cease using the information for such purposes at no charge to you. If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us where permitted by law.
Phone Calls and Text Messages. If you do not want to receive marketing phone calls or text messages from us, please inform us that you no longer want to receive calls from us when you receive a call from us, or reply STOP to a text message from us. You can also opt-out of telemarketing by contacting us at privacy@orkin.com.
Processing in the United States and Across Canada
Please be aware that information we obtain about you may be processed across Canada and the United States by our service providers or us. By using the Sites or Services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own, including the United States and other jurisdictions, as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other jurisdictions may not afford the same level of protection as the laws in your own jurisdiction. We have taken all reasonable steps to ensure that your information will not be used for purposes not relevant to the object of your file or communicated to service providers without your consent except when required or permitted by law.
California Privacy Rights
If you are a California resident, this section applies to you.
Shine The Light. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at privacy@orkin.com and include “CA Shine the Light” in the subject line of your email.
California Consumer Privacy Act (“CCPA”).
Sale or Sharing of Personal Information. In the preceding 12 months, we have “sold” or “shared” (as those terms are defined in the CCPA) identifiers, commercial information, internet or electronic usage data, geolocation data, and inferences to analytics/advertising partners. We do not knowingly sell or share the personal information of minors under the age of 16.
Use or Disclosure of Sensitive Personal Information. In the preceding 12 months, we have not used or disclosed sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.
Your Rights Under the CCPA. Subject to certain exceptions and limitations, the CCPA affords California consumers the following rights:
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You have the right to request that we tell you (i) what personal information we have collected about you, (ii) the sources of that information, (iii) the business or commercial purposes for collecting, selling or sharing the personal information; and (iv) the categories of third-parties to whom we have disclosed personal information.
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You have the right to request that we provide you with a copy of your personal information.
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You have the right to request that we delete personal information that we have collected from you.
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You have the right to opt-out of the sale of your personal information
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You have the right to opt-out of the sharing of your personal information for cross-contextual behavioral advertising.
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You have the right to direct us to limit the use or disclosure of your sensitive personal information to only the purposes specified in the CCPA.
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You have the right to correct inaccurate personal information that we hold about you.
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You have the right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.
Exercising Your Rights. To exercise any of your rights, please use our webform or call us toll free at 866-462-8040. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request. If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.
In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us at privacy@orkin.com.
Global Privacy Control and Opt-Out Preference Signals. Some browsers or browser extensions also allow you to tell websites not to share your information for cross-contextual behavioral advertising through the “Global Privacy Control” or other opt-out preference signals. If you have enabled Global Privacy Control or an opt-out preference signal on your browser or extension, we will honor such requests that can be recognized by our Site by disabling analytics and advertising technologies. Please note that we may not be readily able to associate an opt-out preference signal with other personal information such as your email address. You will also only be opted out of online sales or sharing of personal information, and will need to turn it on for each browser you use. Refer to the “Exercising Your Rights” above if you would like to extend your opt-out request beyond the online advertising practices described above.
Other Consumer Rights Information. Under California Civil Code Section 1789.3, we are required to provide California residents with the following information:
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Unless otherwise expressly stated, this Site is provided without charge.
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To file a complaint regarding this Site or to receive further information regarding use of this website, please contact us via email at privacy@orkin.com. You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at (916) 445-1254 or (800) 952-5210.
Removal of Content. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacy@orkin.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
Canada Privacy Rights
If you are a resident of Canada, this section applies to you.
The Controller of your personal information is Orkin Canada, LLC.
Your Rights. Subject to certain exemptions, you have the following rights in relation to the personal information we collect about you.
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Your right of access: Upon your written request, subject to certain exceptions, we will inform you of the existence, use, and disclosure of your personal information and will provide you with a copy of that personal information within the timeframes provided for by law. Access requests should be sent to us using the contact information below. We try to respond to all legitimate requests within one month. Occasionally, if required or permitted by law, it could take us longer than one month if your request is particularly complex or you have made a number of requests. In these cases, we will notify you and keep you updated. Depending on the scope of your request, or if you require additional copies, we may need to charge you a reasonable fee where permitted under law.
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Your right to rectification: If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we will let them know about the rectification where possible and where this would not involve disproportionate effort. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
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Your right to be forgotten: If you are a resident of the province of Quebec, you have the right to control the dissemination of your personal information. As such, you may request that we de-index (i.e. delist from search results) any hyperlinks associated with your name and that provide access to your personal information if the underlying dissemination of your personal information contravenes the law or a court order, or if it otherwise causes serious injury to your reputation or privacy. This also includes your right to re-index (i.e. list in search results) any hyperlinks associated with your name where doing so can prevent the perpetuation of a serious injury to your reputation or privacy. You can contact us for assistance in deleting personal information previously provided to us. Please note that we will take a reasonable amount of time to process your request.
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Your right to personal information portability: If you are a resident of the province of Quebec, you have the right, in certain circumstances, to obtain the personal information that you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
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Your rights in relation to automated decision-making and profiling: If you are a resident of the province of Quebec, you have the right to know if we use your personal information to render a decision based exclusively on automated processing of such information. Upon request, you also have the right to know the categories of personal information used to render the decision, the reasons, and the principal factors that led to that decision. You have the right to correct the information used to render the decision, if you notice any inaccuracy. Lastly, you can submit observations in support to a request to review any automated decision reached using your personal information.
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Your right to request information about data processing: You may contact us to request information about our data processing activities, namely what personal information was collected from you and how process it. You may ask us to clarify the categories of persons that have access to your personal information and the applicable retention period for that information.
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Your right to withdraw consent, deactivate your account, or unsubscribe: You have the right to withdraw that your consent to our collection, use, and disclosure of personal information at any time. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Exercising Your Rights. To exercise your rights, please email us at privacy@orkin.com. You may also write us at:
Orkin Canada
Attn: Data Privacy Officer
5840 Falbourne Street,
MISSISSAUGA, ON,
L5R 4B5, Canada
Contact Us
If you have any questions about this Policy or our privacy practices, please email us at privacy@orkin.com.
Updates to Our Privacy Policy
From time to time we may change our privacy policy. We will notify you of any material changes to our privacy policy as required by law. We will also post an updated copy on the website where this appears. Please check our website periodically for updates. The “Last Updated” legend above indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on any of our Sites.