State Specific Consumer Privacy Rights
Last updated: July 5th, 2023
NOTICE AT COLLECTION
DATA WE COLLECT
We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Data”), including:
First name, last name, telephone/mobile number, email address, physical or postal address, unique personal identifier, birthdate, online identifier, IP address, , or other unique identifiable Information such as a signature, username or social media handle, or other similar identifiers.
|Characteristics of Protected Classifications Under California or Federal Law
Age, mental and physical disability, sex, sexual orientation, gender identity, medical information, marital status, or military status.
|Internet or Other Electronic Network Activity Information
Device identifier, internet protocol (IP) address, browsing history, information about interactions with Our website, application or advertisements.
Location data generated by a consumer device capable of connecting to the Internet that directly identifies the precise physical location of the identified individual at particular times.
Records of personal property, financial information, products or services purchased, or purchasing or consuming histories, monthly income range, estimated debt, status of payments, or credit rating range.
|Professional or Employment Information
Employment status, education, employment history, job description, or business information.
|Inferences Drawn From Other Personal Data
Profiling a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
|Personal information as described in Cal. Civ. Code § 1798.80(e)
To the extent collected under another category of Personal Data above.
Some of the Personal Data listed above may be considered Sensitive Personal Data under relevant privacy laws. This includes health information, precise geolocation information, and sex life or sexual orientation. Each type of Sensitive Personal Data may overlap with a category of Personal data listed above.
The type of Personal Data We collect about you may vary based on how you use Our Sites and/or Services and your relationship with Us.
Usage Data and Site Activity
We automatically collect information in connection with the actions you take on Our Site (“Usage Data”). For example, each time you use this Site, We may collect internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, and HTTP headers from your browser. Among other things, this data helps Us estimate Our audience size and usage patterns, recognize you when you return to Our Site, store information about your preferences, customize Our Site according to your interests, and speed up your searches. If the data We automatically collect is capable of being associated with you, directly or indirectly, We treat it as Personal data under the categories of Identifiers or Internet or other electronic network information, as appropriate. If this information is not capable of being individually associated with you, We treat it as Usage Data.
We may record and retain calls and the contents of your interactions with us, including web forms, chat transcripts, session use, or other written/electronic communications between you and us. By communicating with us, you consent to Our recording and retention of communications.
We may anonymize or aggregate Personal Data so that it is no longer capable of being associated with you in which case it will be considered “Deidentified Data”. We will not attempt to reidentify you or any other person from Deidentified Data. We may use and disclose Deidentified Data for any purpose without restriction.
USE OF PERSONAL DATA
We may use Personal Data, including Sensitive Personal Data, for general business purposes, including:
||Categories of Personal Data Processed
|To provide and maintain Our Service, including monitoring the usage of Our Service. This is required to offer Services and for Our everyday business operations. You cannot limit sharing unless you revoke your consent for these Services.
||All categories of Personal Data.
|For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service. This is required to offer Services and for Our everyday business operations. You cannot limit sharing unless you revoke your consent for these Services.
||All categories of Personal Data.
Sensitive Personal Data.
|For Website use and analytics: To provide you with access to and use of Our Site and Services, analyze consumers’ use of Our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data.
|To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products enquired about or contracted services. This is required to process your enquiry and consent. You cannot limit sharing unless you revoke your consent for these Services including the security updates, when necessary or reasonable for their implementation.
|To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that you have already purchased or enquired about, this is implemented for a commercial purpose and you may limit sharing by opting-out of Services HERE.
||All categories of Personal Data.
|To manage Your requests: To attend and manage your requests to Us. This is required to offer Services and for Our everyday business operations. You cannot limit sharing unless you revoke your consent for these Services.
||All categories of Personal Data.
|Compliance: To comply with applicable legal requirements, industry standards, contractual obligations, Our policies, and take actions that We deem necessary to preserve and enforce Our rights and the rights of others.
||All categories of Personal Data.
We may also use Personal Data and/or Sensitive Personal Data as described to you at the point of collection, with your consent, or as otherwise required or permitted by applicable laws. We do not
Third-Party Selling and Sharing
We may sell or share (for targeted or cross-context behavioral advertising purposes) your Personal Data with other companies who do not provide services to Us (“Third Parties”), These companies may use your Personal Data for their everyday business purposes, including marketing, customer service, fulfillment, and related purposes. In the past 12 months We sold and shared Personal Data as follows:
- Network Partners –we sold and shared Identifiers, Characteristics of Protected Classifications Under California or Federal Law, Geolocation Information, Commercial Information, Internet or Other Electronic Network Activity Information, Professional or Employment Information and Consumer Inferences
- Advertising, social media, and analytics companies – We sold and shared Identifiers, Characteristics of Protected Classifications Under California or Federal Law, Geolocation Information, Commercial Information, Internet or Other Electronic Network Activity Information, Professional or Employment Information and Consumer Inferences for the purposes described above. These companies may use your Personal Data for additional purposes outlined in their privacy policies.
RETENTION OF YOUR PERSONAL DATA
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
OTHER PRIVACY DISCLOSURES
HOW WE COLLECT DATA
Directly From You
We may ask you to provide Us with Personal Data when you communicate with Us online or offline, including web forms, marketing or promotional programs, and in connection with a product/service offered by Our Affiliates (an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for the election of directors or other managing authority) or Network Partners We may also capture your contact information, such as phone numbers and email addresses, when you contact us.
Third-Party Data Sources
We may collect Personal data from third-party data sources such as Network Partners, Marketing & Data Analytic Partners, and Service Providers that interact with Us in connection with the Website function or Services We perform.
Tracking Technologies and Cookies
We use the following types of cookies:
- Strictly Necessary: These cookies are essential to operate the Sites and provide you with services you have requested.
- Functional: These cookies enable certain features or non-essential functionality on Our Sites. For example, We might use these cookies to recognize you and remember your preferences or settings when you return to Our Sites so We can provide you with a more personalized experience.
- Advertising Cookies: These cookies allow Us and third parties to learn more about you, including your use of Our Sites and other websites, and advertise products or services that might interest you as further indicated below.
- Analytics Cookies: These cookies help Us and third parties understand how Our Sites are working and who is visiting Our Sites.
We and third parties also use tools that enables Us to track certain aspects of a user’s visit to Our Sites. This technology helps Us better manage content on Our Sites by informing Us what content is effective, how consumers engage with Our Sites, and how consumers arrive at and/or depart from Our Sites. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether a user views a web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.
We do not use technology that recognizes “do-not-track” signals or global privacy settings from your web browser because this Service relies on sharing your information to function and we do not track users other than for aggregate statistical purposes.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Trusted Form and Jornaya
We or authorized third parties acting on Our behalf may use your Personal Data to contact you via email with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or by contacting Us.
DISCLOSURE OF DATA
We may provide your Personal Data to other businesses to provide services to Us or on Our behalf (“Service Providers”). Categories of Service Providers We use include:
- Fulfillment and account servicing vendors, which help Us provide products, services and information to you, service your account or benefits, and collect past due balances;
- Payment processors, which help Us to accept and process the payments for Our products/services to you;
- Marketing and communications vendors, which help Us market Our products/services to you, conduct promotions, surveys, and other outreach campaigns;
- Research and development vendors, which help Us develop and improve Our products and services;
- Data and business analytics vendors, which help Us collect, analyze, and improve the accuracy of Our data (including Personal Information), and the activities of visitors to Our Site;
- IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;
- Professional service firms, which provide accounting, legal, auditing, and other professional services; and
- General service providers, which help Us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.
We require each Service Provider to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Data from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Data We provide to them other than as specified by us.
In the past twelve months We may have disclosed each category of Personal Data that We collect (listed above) to Service Providers.
Other Third-Party Disclosures
We may occasionally disclose your Personal Data to Third Parties, for purposes such as:
- To comply with the law;
- To respond to legal requests (including court orders, investigative demands and subpoenas) if, in Our discretion, We believe it is necessary or appropriate;
- To prevent or stop any illegal, unethical, or legally actionable activity;
- To protect the safety, property, or rights of ourselves, consumers, or any other third party;
- If We are merged, acquired, or sold, or in the event of a divestiture, restructuring, reorganization, or transfer of some or all of Our assets and the disclosure is necessary to complete the transaction;
- To businesses controlling, controlled by, or under common control with us; and
- For additional purposes with your consent where such consent is required by law.
In the past twelve months, We disclosed Identifiers to third parties in connection with proposed or finalized corporate transactions.
PERSONAL DATA WE COLLECT AS A SERVICE PROVIDER FOR OUR CLIENTS
When acting for companies on whose behalf we perform work as a service provider (“Clients”), we may collect, use, and disclose Personal Data for the purpose of servicing those Clients. The specific categories of Personal Data collected and how that Personal Data is used or disclosed is determined by our Clients and will vary.
The Personal Data collected, used, and disclosed on our Clients’ behalf is governed by their privacy policies. When acting on behalf of a Client, we supply that Client with all information requested by them or consistent with their contract. This information is usually what is required to facilitate a specific transaction but can vary depending on the Client. If you request information about the Personal Information we collect, use, and disclose on our Clients’ behalf, we will direct you to contact the Client(s).
TRANSFER OF YOUR PERSONAL DATA
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
SECURITY OF YOUR PERSONAL DATA
The security of your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, We cannot guarantee its absolute security.
State Specific Consumer Privacy Rights
If you are a resident of California, Colorado Connecticut, Nevada, or Virginia, you may have additional rights to access and control your Personal Data. Exemptions may apply. Consumer privacy rights for residents of these states include:
Right to Opt-Out from the Sale or Sharing of Personal Data
You have the right to direct Us not to sell or share (for targeted or cross-context behavioral advertising purposes) your Personal Data to Third Parties. We will process requests within 15 business days, subject to any applicable exceptions and extensions permitted by law.
To opt-out of the sale of Personal Data you can contact Us or fill Our this FORM HERE. Additionally, Service Providers We partner with (for example, Our marketing and data analytic partners) may use technology on the Service that “sells” Personal Data as defined by applicable law.
If you wish to opt out of the use of your Personal Data for interest-based advertising purposes and these potential sales as defined under applicable law, you may do so by following the instructions below. Please note that any opt out is specific to the browser you use. You may need to opt-out of every browser that you use.
Your mobile device may give you the ability to opt-out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
Right to Know
You have the right to request twice per 12-month period that We provide you (i) the categories or specific pieces of Personal Data We collected about you; (ii) the categories of sources from which We collected your Personal Data; (iii) the business or commercial purpose for which We collected your Personal Data; and (iv) the categories of Third Parties with whom We sold, shared, or disclosed your Personal Data. including the categories of Personal Data sold, shared, or disclosed to each and the purposes for doing so. We are not permitted to provide access to specific pieces of Personal Data that creates a high risk of potential harm from disclosure to an unauthorized person such as social security numbers and driver’s license numbers. To protect consumers’ Personal Data, you must provide required information and/or documentation to verify your identity. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law.
Right to Delete
You have the right to request that We delete any Personal Data We have collected about you. Please understand that We are not required to honor a deletion request if a legal exemption applies such as if We need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. To prevent unauthorized individuals from making deletion requests, you must provide required information and/or documentation to verify your identity. We will retain a copy of your deletion request for at least two years as required by law.
Right to Correct
You have the right to request that We correct inaccurate Personal Data We maintain about you. After you request to correct inaccurate Personal Data, We will provide instructions for you to provide Us with optional documentation to support your request and We will consider it. We may decline to correct your Personal Data if a legal exemption applies such as if We determine that your request is fraudulent or abusive or if We determine, based on the totality of the circumstances, that your correction is more likely inaccurate than accurate. We may decide to delete your allegedly inaccurate Personal Data instead of correcting it. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law.
Right to Appeal
You have the right to appeal Our decision to deny, in full or in part, one or more of your privacy requests. We will process appeal requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law. If We deny your appeal, We will provide you with a written explanation of the reasons for Our decision. If you are not satisfied with Our explanation for the denial of your appeal, you may have an additional right under certain laws to contact your state Attorney General to submit a complaint about the appeal results. In such case, We will provide you with instructions for doing so.
Submitting a Request
If you are a California, Colorado, Connecticut, Nevada or Virginia resident and would like to exercise your rights, you may submit a request through our online privacy request form.
If you are an authorized agent submitting a request for another consumer, you must provide a copy of a lawful power of attorney or written authorization from the Consumer (along with proof of your identity). You will be provided options on how to provide this documentation after submitting the request. We may contact you or the Consumer on whose behalf you claim to act to verify your authorization.
Right to Non-Discrimination
Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We will immediately take steps to remove that information from Our servers.
LINKS TO OTHER WEBSITES
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
CONFLICT BETWEEN THIS POLICY AND LOCAL LAWS AND REGULATIONS