Privacy Policy
Privacy Policy
Effective Date: July 16, 2025
This Privacy Policy explains how Essential Marketing Systems, Inc. (“EMS,” “we,” “our,” or “us”) collects, uses, discloses, and safeguards your personal information when you visit or use our websites https://bestlocalreviews.com and https://fivestarreviewsystem.com, or use our associated services (collectively, the “Services”). This Policy applies to users in both the United States and Canada.
1. Information We Collect
We may collect the following types of personal information:
From Subscribers (Member Accounts):
• Name, email address, phone number
• Business name, address, website URL, and logo
• System usernames and passwords
• Employee information, including:
• Name
• Title
• Photo
• Email address
• Review site links and preferences
• Marketing materials (e.g., coupons, flyers, thank-you messages)
• Redirect URLs
• Any additional information you voluntarily provide
From Affiliates and Partners:
• Contact details
• Commission tracking identifiers
• Performance and referral data
From Reviewers:
• Star ratings
• Review content or testimonials
• URLs clicked
• Name, photo (if submitted)
• Any additional information you provide voluntarily
Automatically Collected Data:
• IP address, browser type, device data
• Page views, referring URLs, and session activity
• Mobile device identifiers and approximate location (based on IP)
• Workflow usage and system logs for support and debugging purposes, including:
• Timestamps and logs of user actions
• System events (e.g., API calls, delivery failures)
• Interactions between EMS subscribers and their customers (e.g., when a reviewer clicks a link, opens a message, or submits a review)
We may collect and store system usage data, diagnostic logs, and workflow-related information to help us monitor performance, debug issues, resolve service disruptions, and improve the functionality of our Services.
This data may include, but is not limited to:
• Logs of user actions and system interactions
• Timestamps and event metadata
• API requests, message delivery records, and error reports
• Interactions between EMS subscribers and their customers (e.g., when a reviewer submits a review, clicks a link, or responds to a message)
In some cases, certain debugging or usage data may be made available to EMS subscribers to help them troubleshoot or optimize their own workflows.
We reserve the right to delete or purge any such data at any time for reasons including, but not limited to, performance optimization, security, legal compliance, or business operations.
Subscribers are responsible for exporting or backing up any workflow or debugging data they wish to retain.
We use cookies, web beacons, pixel tags, and similar tracking technologies to collect this information. You can manage cookies through your browser settings.
2. How We Use Your Information
We use personal information to:
• Provide and manage our Services
• Respond to inquiries and support requests
• Customize user experience
• Send updates to subscribers about our services
• Monitor performance, security, and usage trends
• Comply with legal obligations
• Administer our Trusted Partner Program, including sharing subscriber account identifiers and relevant business information with participating Affiliates for commission tracking, payout, and partner relationship management, subject to contractual privacy protections
We do not sell or share reviewer information for marketing purposes. We only share it with the EMS subscriber who requested the review.
3. Consent
By using our Services or submitting personal information, you consent to our collection, use, and storage of your information in the United States.
For reviewers, the following notice appears before you submit a review:
“By clicking ‘Publish’ you agree that your testimonial or feedback may be published on the Internet, including websites and social media, and may be used for marketing purposes. Your name and/or likeness may be used as designated by you.”
Subscribers are required to obtain your consent before sending requests for reviews or testimonials.
4. Sharing of Information
We may share information:
• With trusted service providers who help us operate (e.g., AWS, Twilio, Rackspace)
• With resellers and partners for commission tracking
• If required by law, subpoena, or legal process
• To protect EMS’s legal rights or prevent fraud
• As part of a merger, sale, or acquisition
All service providers are contractually restricted from using data except to perform services for EMS.
5. Security
We use industry-standard technical and organizational measures, including:
• SSL encryption
• Access controls (usernames/passwords)
• Encrypted backups (e.g., BorgBase, Code42)
• Infrastructure hosted in the U.S. (AWS, DigitalOcean)
While we strive to protect your data, no system is 100% secure. You share information at your own risk.
6. Your Rights
Data Retention and Deletion
We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
For subscriber accounts, data may be archived or purged after account cancellation. In some cases, personal data may be permanently deleted one year after account closure, though this may vary depending on our internal practices and applicable laws.
Please note that once data is purged, it cannot be recovered. You are responsible for exporting or backing up any data you may need before your account is closed.
While we honor valid deletion requests from users, some information may be retained in archived backups that are not in active use and are maintained for security, legal, and operational continuity purposes. If and when such backups are restored, we will ensure the deletion request is honored at that time.
Authorized Agent Requests
You may authorize an agent to submit requests to access, delete, or correct your data on your behalf. To do so, we may require the agent to provide signed permission and verify your identity directly.
Appeals Process
If we deny your request to access, delete, or correct personal information, you may appeal our decision by replying to our response or emailing [[email protected]](mailto:[email protected]) with the subject line “Privacy Request Appeal.”
For All Users
You may:
• Request access to or correction of your data
• Delete your account or stop using our Services
• Contact us at [email protected] or Contact Form
Summary of Regional Privacy Rights
California Residents (CPRA):
• Right to know what personal data is collected
• Right to delete personal information (subject to EMS’s data retention policy; data may be purged 1 year after account closure)
• Right to correct inaccurate personal information
• Right to opt out of the sale or sharing of personal data (EMS does not sell personal data or share it for cross-context behavioral advertising. Limited data is shared with Affiliates for commission purposes under strict contractual use limitations)
• Right to limit use of sensitive personal data
• Right to non-discrimination for exercising privacy rights
Colorado Residents (CPA):
• Right to access, correct, or delete your personal data
• Right to obtain a portable copy of your data
• Right to opt out of targeted advertising, sale of personal data, and profiling
• Right to appeal a refusal to act on a privacy request
Virginia Residents (VCDPA):
• Right to access, correct, delete, and obtain a copy of personal data
• Right to opt out of targeted advertising, sale of data, and profiling
• Right to appeal decisions regarding your privacy requests
Connecticut Residents (CTDPA):
• Right to access, correct, delete, and move your personal data
• Right to opt out of targeted ads, sale of data, and profiling
• Right to file a complaint with the Connecticut Attorney General
Utah Residents (UCPA):
• Right to access and delete personal data
• Right to opt out of the sale of data and targeted advertising
• Right to data portability
Texas, Florida, Oregon, and Other U.S. State Residents:
• While not every U.S. state currently has its own comprehensive data privacy law, we strive to honor comparable privacy rights for all users, including access, correction, deletion, and opt-out rights, regardless of location.
Canadian Residents (PIPEDA):
• Right to access and correct your personal information
• Right to be informed of data collection and purposes
• Right to withdraw consent at any time
• Right to file a complaint with the Office of the Privacy Commissioner of Canada, if you believe we have mishandled your personal data or failed to respond to a request appropriately
• Right to request deletion (subject to EMS’s data retention policy; data may be purged 1 year after account closure)
Alberta, British Columbia, and Quebec:
• These provinces have their own privacy laws in addition to PIPEDA
• Similar rights to access, correct, and control personal information
• Quebec’s Law 25 (Bill 64) expands rights to include:
• Right to data portability
• Right to be informed of automated decision-making
• Right to restrict or object to processing in certain cases
Automated Decision-Making and Profiling
We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on users. If this changes, you will be notified and provided opt-out rights as required by law.
Non-Discrimination
You will not receive discriminatory treatment for exercising your privacy rights under applicable state or federal laws. This includes denial of service, different pricing, or reduced service levels.
7. Children’s Privacy
Our Services are not directed to children under 13 (U.S.) or 14 (Canada/Quebec). We do not knowingly collect personal data from children. If you believe we have, please contact us immediately.
8. International Transfers
Your data is processed and stored in the United States. If you are accessing the Services from outside the U.S., you consent to the transfer of your information across borders, subject to appropriate safeguards under applicable law.
9. Changes to This Policy
We may update this Privacy Policy from time to time. The “Effective Date” at the top reflects when the most recent version was published. Continued use of our Services after changes constitutes acceptance.
10. Contact Us
Essential Marketing Systems, Inc.
Attn: Susan Sommers
821 Kumulani Drive
Kihei, HI 96753
[email protected]
Last updated: July 16, 2025