This Policy applies to information we collect:
- on the Sites; and
- in email, text, and other electronic messages between you and the Sites.
This Policy does not apply to information collected by:
- Through any other means, including on any other website operated by Company or any third party or through other forms of communications such as telephone; or
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Sites.
Your Acceptance of this Policy
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using any of the Sites you agree to this Policy. If you do not agree to this Policy, you are directed to discontinue using and accessing the Company’s Sites. The Company reserves the right to change or update this Policy at any time and without prior notice to you. Your continued access or use of the Sites after such changes or updates indicates your acceptance of the Policy as changed or updated. It is your responsibility to review this Policy regularly for any changes or updates. This Policy was last updated on April 17, 2023
Information We Collect About You and How We Collect It
When you use our Sites, the Company and/or our third party service providers collect certain information about you (the “Sites Information”). Among the types of information from and about users of our Sites that we collect are:
- Personal Information. We receive or collect information that identifies you personally if you choose to provide such personal information to us via email or other means. When you sign up to become a user or contact us, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information may include your name, e-mail address, physical address, phone number.
- Third-party Log In. If you register or visit the Sites through Facebook, Apple, Google, or another website or platform, you are authorizing us to collect, store, and use, in accordance with this Policy, any and all information that you agreed that such websites or platforms would provide to us through its Application Programming Interface. Such information may include, without limitation, your first and last name, username, profile picture, headline, unique identifier and access token, and e-mail address. We do not receive or store your passwords for your social media accounts.
- Geolocation Information. Certain features and functionalities of the Sites are based on your location. In order to provide these features and functionalities, we may, with your consent, automatically collect geolocation information from your device(s) or wireless carrier and/or certain third-party service providers (collectively, “Geolocation Information”).
- Other Information. In addition to Personal Information, Payment Information, Geolocation Information, and Third-Party Analytics, we may automatically collect or receive additional information regarding you and your use of the Sites, your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the Sites (collectively, the “Other Information”). Such Other Information may include:
- From You. Information that you may post, submit, transmit, upload or otherwise provide (hereinafter, “Post”), including without limitation photographs, videos, posts, comments and reviews, to be published or displayed on the Sites, or transmitted to other users of the Sites or third parties. Additional information from you may include information you provide when you enter a contest, sweepstakes or other promotion sponsored by us, information when you report a problem with our Sites, and details of transactions you carry out through our Sites, including information you provide at the time of purchasing products or services from our Sites, and of the fulfillment of your orders.
- From and About Your Devices. The Sites, may access metadata and other information associated with other files stored on your devices. This may include, for example, photographs, audio and video clips, personal contacts, and address book information. We may also collect information regarding your mobile device, including: (a) the type of mobile device; (b) advertising Identifier (“IDFA” or “AdID”); (c) operating system and version (e.g., iOS, Android or Windows); (d) carrier; and (e) network type (WiFi, 3G, 4G, 5G, LTE, etc.).
- From Your Activity. We may collect or receive information regarding: (a) IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device; (b) browser type and language; (c) referring and exit pages and URLs; (d) date and time; and (e) details regarding your activity on the Sites, such as searches and other performance and usage data.
- From User Attribution Devices. User Attribution Devices help facilitate and enhance the Sites’ communications and interactions with you. The Company may share use User Attribution Devices to inform, optimize and serve information and content to you. User Attribution Devices include:
- Flash Cookies. Certain features of our Sites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Sites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Our Sites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited certain webpages and for other related statistics (for example, recording the popularity of certain content on the Sites and verifying system and server integrity).
Third-Party Information Collection
When you use the Sites, certain third parties may collect information about you or your devices, including by using their own User Attribution Devices. These third parties may include advertisers, ad networks, and ad servers, analytics companies, your mobile device manufacturer and your mobile service provider. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How and Why We Use Your Information
We may use any information about our users, including without limitation any Sites Information, in aggregated, anonymized and/or non-personally identifiable form, without restriction (except to the extent prohibited by applicable law).
We may use information that we collect about you or that you provide to us as described in this Policy, including without limitation any Sites Information. Under data protection law, we only use your personal information if we have an appropriate reason for doing so, including to comply with our legal and regulatory obligations; for the performance of our contract with you or to take steps at your request before entering into a contract; for our legitimate interests or those of a third party; or where you have given consent. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your Personal Information for and our reasons for doing so:
What we use your Personal Information for Our present our Sites and provide products and/or services to you For the performance of our contract with you or to take steps at your request before entering into a contract To prevent and detect fraud against you For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for your Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price Statistical analysis to help us manage our business, e.g. in relation to customer base, product range or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price Preventing unauthorized access and modifications to systems
To comply with our legal and regulatory obligations Updating and enhancing customer records
To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
- existing and former customers;
previously expressed an interest in our services;
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
Disclosure of Your Information
We may disclose any information about our users, including without limitation any Sites Information, in aggregated, anonymized and/or non-personally identifiable form, without restriction (except to the extent prohibited by applicable law).
We may disclose information that we collect about you or that you provide to us as described in this Policy, including without limitation any Sites Information:
- To contractors, service providers, and other third parties we use to support our business (including but not limited to online service vendors) and who are bound by contractual obligations to keep the information that we disclose about you confidential and use it only for the purposes for which we disclose it to them. These contractors, service providers, and other third parties will have access to your Personal Information only as necessary to perform their functions and to the extent permitted by law. We also impose contractual obligations on contractors, service providers, and other third parties relating to ensure they can only use your Personal Information to provide services to us and to you.
- To a subsidiary, affiliate, buyer or to any other successor in the event of a merger, divestiture, restructuring, consolidation, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, insolvency, liquidation, or similar proceeding, in which information held by the Company about you is among the assets transferred.
- To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
- In an ongoing effort to better understand our users, the Sites, and our products and services, we may analyze certain Sites Information in anonymized and aggregate form to operate, maintain, manage, and improve the Sites and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
- We will use your Payment Information to process your authorized payments through the Sites. We will share your Payment Information with a third-party service provider as necessary to process your payment. The third-party service provider stores your Payment Information; we do not store this information. Storage by the third-party service provider of your Payment Information is subject to the privacy policies and practices of the third-party service provider and is not subject to the terms of this Policy. By providing your Payment Information, you acknowledge and agree to use of such information by the third-party service provider for purposes of processing your payment to us.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the Sites Information.
- Otherwise with your consent.
We may also disclose your information, including without limitation any Sites Information:
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the Sites Information you provide to us. We have created mechanisms to provide you with the following control over your Sites Information:
- Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to email@example.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase or other related transactions.
- Geolocation Information. You can choose whether or not to allow the Sites to collect and use real-time information about your device's location. You may decline to allow us to collect Geolocation Information, in which case we will not be able to provide certain features or functionalities to you.
- Targeted Advertising by the Company. If you do not want us to use Sites Information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an email stating your request to firstname.lastname@example.org.
In any such case of your withdrawal of consent, you acknowledge that there may be a delay before the Company fully implements your request and you may therefore still be contacted by the Company for a period of time thereafter. Notwithstanding your withdrawal of consent, the Company may subsequently contact you for other purposes that are unrelated to marketing and/or selling, including without limitation legal or regulatory purposes. Please be aware that applicable laws, statues, rules and/or regulations may require or permit the collection, processing, retention, use and disclosure of your Sites Information without your consent. Notwithstanding the foregoing, pursuant to applicable laws, statues, rules and/or regulations or other reasons, there may be circumstances in which you may not withdraw your consent to the collection, processing, use, retention and disclosure of your Sites Information.
We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
Accessing and Correcting Your Personal Information
You may send us an email at email@example.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
How Long Your Personal Information Will Be Kept
We will keep your Personal Information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your Personal Information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your Personal Information for longer than necessary for the purposes set out in this Policy. When it is no longer necessary to retain your Personal Information, we will delete or anonymize it.
Where Your Information is Held
The Company’s Social Media Sites
The Sites are not intended for children under the age of thirteen (13). No one under the age of thirteen may provide any personal information to or on the Sites. The Company is committed to the safety of children and to protecting the online privacy of children. The Company does not request or knowingly collect any personal information from children under the age of thirteen. If the Company becomes aware that a child under the age of thirteen has provided personal information to the Sites, the Company shall take reasonable measures to delete all such information from the Company’s records. The Company relies on the parents and guardians of children to monitor their children’s access and use of the Internet, including the Company’s Sites. If you believe we might have any information from or about a child under the age of thirteen, please contact us at firstname.lastname@example.org.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. Annually, California residents may request and obtain personal information that the Company has shared with third parties for such third parties’ direct marketing purposes within the prior calendar year (as defined by California Civil Code § 1798.83, commonly known as California’s “Shine the Light Law”). If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which the Company shared this information in the immediately preceding calendar year. To obtain this information, please send an email message to email@example.com with the words "California Shine the Light Privacy Request" in the subject line as well as in the body of your message. The Company shall then furnish any applicable requested information to your email address.
You acknowledge that you are aware of security and privacy limitations including but not limited to: (1) the global accessibility of the Company’s Sites on the Internet; (2) the technological limitations of security, privacy, and authentication measures and features on Internet sites and specifically on the Company’s Sites; (3) the risk that data or information is transmitted to or from the Company’s Sites may be subject to eavesdropping, sniffing, spoofing, forgery, spamming, “impostering”, tampering, breaking passwords, harassment, fraud, electronic trespassing, hacking, denial of service attacks, nuking, system contamination (including computer viruses, Trojan horses, worms, defects, date bombs, time bombs, malware, ransomware, bugs, executables or other items of a destructive nature or any other malicious computer codes, scripts, applications or programs) causing unauthorized, damaging, or harmful access to and/or retrieval of information and data on your computer or network; (4) the risk that data or information on any of the Company’s Sites may be subject to other security or privacy hazards, may not reach its destination, or may reach an erroneous address or recipient; (5) unauthorized access by third parties; and (6) the content or the privacy policies of other websites, social media websites, platforms, and applications, including without limitation those to which the Company may link or be linked.
The Company considers protecting the security of your Personal Information important. We have implemented commercially reasonable measures to protect your Personal Information from accidental loss, from misuse and from unauthorized access, alteration, disclosure or destruction. All information you provide to us is stored on our secure servers behind firewalls. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share Personal Information, nor can we guarantee that the Personal Information you supply will not be intercepted while being transmitted over the Internet. Any transmission of information, including Personal Information, is at your own risk.
The safety and security of your Personal information also depends on you. Where we have given you (or where you have chosen) a password to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Sites, which may be viewed by others. You must take precautions to protect the security of all Personal Information that you Post or otherwise transmit to or through the Sites, including over any home networks, routers, private wireless (WiFi) networks, public WiFi networks, and all other communication technologies. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites, for the unauthorized acts of others, or for acts or omissions beyond our reasonable control.
Transferring Your Personal Information Out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA) to other countries, for example: with our offices, which are located outside the EEA; with your and our service providers located outside the EEA; if you are based outside the EEA. These transfers are subject to special rules under European and UK data protection law. These countries non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all Personal Information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. If you would like further information, please contact us (see How To Contact Us below).
Your Rights Under the GDPR
If you are an individual physically located in the European Economic Area when you access and/or use the Sites, or if you are otherwise subject to the General Data Protection Regulation 2016/679 (“GDPR”), you may have certain additional rights, including:
Right to Access. The right to be provided with a copy of your personal information.Right to Rectification. The right to require us to correct any mistakes in your personal information.Right to be Forgotten. The right to require us to delete your Personal Information in certain situations.Right to Restriction of Processing. The right to require us to restrict processing of your Personal Information in certain circumstances, e.g. if you contest the accuracy of the data.Right to Data Portability. The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party, in certain situations.Right to Object. The right to object: (i) at any time to your Personal Information being processed for direct marketing (including profiling); and (ii) in certain other situations to our continued processing of your Personal Information, e.g. processing carried out for the purpose of our legitimate interests.Right Not to be Subject to Automated Individual Decision-Making. The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
How to File a GDPR Complaint
We hope that we can resolve any query or concern you raise about our use of your Information. The GDPR also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Do You Need Extra Help?
If you would like this Policy in another format (for example: audio, large print, braille) please contact us (see How to Contact Us below).
How to Contact Us
To ask questions or comment about this Policy and our privacy practices, contact us at:
Alternatively, you may email us at: firstname.lastname@example.org