Last Update February 13, 2020.
Sources of Personal Data
We collect Personal Data about you from:
- when you provide such information directly to us
- when Personal Data about you is automatically collected in connection with your use of our Services
- Third parties, when they provide us with Personal Data about you (“Third Parties”). Third Parties that share your Personal Data with us include:
- Service Providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or Third Parties may help us provide you with customer support.
- Social networks connected to the Services. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your Account with us.
- Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
Categories of Third Parties with Whom We Share Personal Data
We disclose your Personal Data to the following categories of service providers and other parties:
- Service providers, including:
- Payment processors
- Name and address verification providers
- Security and fraud prevention providers
- Hosting and other technology and communications providers
- Analytics providers
- Market research providers
- Marketing service providers
- Email distribution companies
- Customer relationship management service providers
- Parties who acquire your Personal Data through an acquisition or other change of control
- Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part)
- Other parties at your direction, including:
- Social media services (if you intentionally interact with them through your use of the Services)
- Third-party business partners who you interact with through the Services
- Other parties authorized by you
Categories of Personal Data That We Collect
|Category of Personal Data||Personal Data Collected||What is the source of this Personal Data?|
|A.||Personal identifiers||-Real name
-Unique personal identifier
-Internet Protocol address
-Account name and password
|B.||Customer records identified by state law(including the California Customer Records statute (Cal. Civ. Code §1798.80(e)))||-Name
-Credit Card number
-Debit Card number
|C.||Protected classification characteristics under state or federal law||-Age (40 years or older)
-Gender identity and gender expression
-Military or veteran status
|D.||Commercial information||-Records of products or services purchased, obtained or considered
-Consuming histories and tendencies
|E.||Biometric Information||We do not collect this category of Personal Data||n/a|
|F.||Internet or other similar network activity information||-Browsing history
-Information on your interaction with our website or advertisements
|G.||Geolocation data||-General location is enabled by cookies and IP address||You /
|H.||Sensory data||We do not collect this category of Personal Data||n/a|
|I.||Professional or employment-related information||-Income
|J.||Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||-Educational Level||You|
|K.||Inferences drawn from other personal information||-Profile reflecting personal preferences||You /
|L.||Age or date of birth||-Age
-Date of birth
|M.||Personal Data about children under the age of 16||-Real name
-Unique personal identifier
-Internet Protocol address
-Account name and password
The following sections provide additional information about how we collect your Personal Data.
Information Collected Automatically
We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you and remember your preferences (for example, your choice of language or region).
- Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
Information about Interest-Based Advertisements
We serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of Third Parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based on a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages.
How We Use Your Personal Data
We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:
- To meet or fulfill the reason you provided the information to us
- To communicate with you about the Services, including Service announcements, updates or offers
- To provide support and assistance for the Services
- To create and manage your Account or other user profiles
- To personalize website content and communications based on your preferences
- To process orders or other transactions
- To respond to user inquiries and fulfill user requests
- To improve and develop the Services, including testing, research, analysis and product development
- To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services
- To comply with our legal or contractual obligations, resolve disputes and enforce our Terms of Service
- To respond to law enforcement requests and as required by applicable law, court order or governmental regulations
- For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”)
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
If you opt to have promotional offers from us sent to your mobile device, we may send you Text Messages regarding such promotional offers to the telephone number you provided to us. To opt out of receiving promotional Text Messages from us, reply “STOP” to any such message.
How We Share Your Personal Data
Disclosures of Personal Data for a Business Purpose
We disclose your Personal Data to service providers and other parties for the following business purposes:
- Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance with this specification and other standards
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction
- Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services or providing similar services on behalf of the business or service provider
- Undertaking internal research for technological development and demonstration
Data Security and Retention
We retain Personal Data about you for as long as you have an open Account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
We will collect Personal Data from individuals under 18 years of age on the same basis as other users, but do not allow individuals under 18 years of age to purchase Services without the consent of their respective parents or legal guardians; if you are an individual under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data without the consent of your parent or legal guardian. If we learn that we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided us with Personal Data, please contact us at email@example.com
California Resident Right Under the CCPA
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. Upon any such request, we will provide you with the following information:
- The categories of Personal Data that we have collected about you
- The categories of sources from which that Personal Data was collected
- The business or commercial purpose for collecting or selling your Personal Data
- The specific pieces of Personal Data that we have collected about you
If we have disclosed your Personal Data to any third parties for a business purpose over the 12 months preceding your inquiry, we will identify the categories of Personal Data sold to each category of third party recipient.
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action that you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Date provided in a Valid Request to verify your identity and complete your request. You do not need an Account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
- Submitting an Access Request Form
- Submitting a Deleting Request Form
- Emailing us at firstname.lastname@example.org
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request to exercise your rights on your behalf.
Personal Data Sales Opt-Out
You have the right to opt out of the sale of your Personal Data. You can opt out using the following methods:
- Submitting an Opt-Out Form
- Emailing us at email@example.com
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
We do not knowingly sell the Personal Data of minors under 16 years of age with or without affirmative authorization.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at firstname.lastname@example.org
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your Account.