Last Update: 06/29/23
- INFORMATION WE COLLECT.
We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (collectively “Personal Information”), including:
- Identifiers, which includes your name, physical address, email address, phone number, mobile number, and identity information relating to data used to identify an individual.
- Characteristics of protected classifications under applicable laws, such as your age and date of birth.
- Commercial information, such as profile information relating to your interests, feedback information, communication preferences, social media activities, or your actions online when opening or clicking through your email.
- Geolocation data, which includes only your general geographic location when viewing our website.
- Inferences drawn from other Personal Information or data, includes using your Personal Information to draw an inference about interests and preferences you would like us to use based on our and third-party’s analysis of your trends.
- HOW WE COLLECT INFORMATION.
Generally, we collect Personal Information, directly from you when you fill out our registration form or contact us directly. We also collect your information automatically when you visit our website through technology on our website. Lastly, we collect information about you from third-parties, contractors, and service providers.
Information You Provide To Us. We may collect Personal Information directly from you when you provide it to us through the Websites. This may include the information you provide in response to our request or prompt. We may also receive information from you when you contact us with questions or concerns.
- Computer or Device Information: We automatically collect your Internet Protocol (“IP”) address or other unique identifier or information from the computer, mobile device, or tablet you use to access the Websites, including but not limited to your browser type, device type, system type, and the domain name from which you accessed the Websites.
- Usage Information: We may collect information about your use of our email promotions, including the date and time you opened, and if you visited the website that was the subject of an ad, as well the page or app you visit after leaving our services, the amount of time you spend viewing or using the websites, the number of times you return to the websites, as well as other click-stream or usage data, and whether you open, forward, or click-through an email or display ad to the Websites. For legal compliance purposes, we may also capture or record your interactions with the Website to confirm that your information was submitted through us.
- Third-party Service Providers: We use third-party service providers to support our marketing services. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or HTML5 cookies to receive, collect, and store information on your computer for later access and usage.
- Information from Third-Party Websites or Services: If you link to us through a third-party website, email, or service, such as a social media account, we may automatically receive certain information about you based on your registration and privacy settings on those third-party websites or services. This may include, but may not be limited to, your name, username, demographic information, updated address or contact information, location, interests, and online activity.
Information Collected From Third-Party Sources. We may acquire Personal Information from other sources as follows:
- Service Providers: We use third-party service providers to support our Websites, services, and business processes including without limitation, services which confirm your identity, determine the truthfulness of the information you submitted, and determine which of our client’s we will submit your information to in order to provide you with the products and services you are seeking by your registration.
- Third-parties: We collect Personal Information about you from third-party sources, including commercially available sources, such as data aggregators and public databases. This information may include your name, demographic information, utility usage information and provider, interests, and publicly-observed data.
Combining Information. We may combine the Personal Information we receive from you, third-parties, and information we automatically collect through the Websites and/or Services, as well as information collected from other online or offline sources, including from third-party sources. This will provide us with a profile of you which we may be able to use for provision of our Services to you as well as identify other products and services that may interest you.
- HOW WE USE YOUR INFORMATION.
We use the Personal Information we collect from and about you for any of the following business purposes:
- To provide our Websites and/or Services to you.
- To analyze, improve, operate, and maintain our Websites, Services, and systems, or develop new products, services, or marketing.
- To obtain on your behalf the information, products, or services that you request from us, and this includes passing it on to our clients who provide the products and services to communicate with you directly.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you, us, our clients, or other service providers or third-parties, involving the services or products you have requested.
- To provide you and other users with customized content, targeted offers, and advertising on the Websites, or across other websites, mobile applications, social media, or online services, or via direct mail, email, and/or telemarketing regarding offers, contests, events, news, programs, and other related and unrelated services and products that we believe may be of interest to you.
- To determine the effectiveness of our marketing programs including use of your data in an aggregated non-specific format for analytical and demographic purposes.
- Additionally, you have authorized us to use your Personal Information from any source to interact with our clients to provide the services and products you have requested as a result of your registration with us or during any customer services communications.
We also may display interest-based ads through social media platforms or websites. These tools allow us to personalize our ads based on your shopping experience, without having to share your Personal Information with these social media platforms.
- WHO WE DISCLOSE, SHARE, AND SELL YOUR PERSONAL INFORMATION TO.
We may disclose, share, and sell your Personal Information as described below.
Third-party Product and Service Providers. We disclose, share, and sell your Personal Information to third-party product and service providers to provide you with the products and services you have requested through your registration on our Website and Services.
Parent and Affiliated Companies. We may disclose and share your information with our parent company and its subsidiaries for business and operational purposes.
Service Providers. We disclose and share your information to third-party contractors and other service providers that we use to support our business, Websites, and Services.
Sale or Transfer of Business or Assets. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. If we file for bankruptcy or reorganization, information we have collected about you may be considered our asset and may be included in the assets transferred.
Marketing Vendors, Service Providers, and Other Third-parties. We may disclose, share, or sell your information to third-parties who provide display and/or email services or other third-party vendors we use who provide cookies, pixel tags, web beacons, clear GIFs, or other similar technologies for our and third-parties use on and to manage and improve our advertising campaigns.
Compliance with Laws. We may disclose your Personal Information to comply with any court order, law, or legal process, including responding to any subpoenas, judicial processes, or government or regulatory requests and investigations. We may disclose and share your Personal Information to third-parties to assist us in compliance with Laws.
Enforcing Our Rights. We may disclose and share your information to enforce or apply our terms of service or other agreements, including for billing and collection purposes, with clients, third-party service provides and other third-parties or contractors who provide you with the product or service which you have requested or to protect the security of our Websites, servers, network systems, and databases and enforce our contractual rights with these parties.
Aggregate or Anonymous Non-Personal Information. We may disclose, share, or sell aggregate, anonymous, or de-identified non-personal information to third-parties for their marketing or analytics uses.
- YOUR CHOICES AND OPTING OUT.
Cookies and Tracking Technology. We, third-parties, and service providers place Cookies and Tracking Technology on parts of our Website. You may decline or adjust these technologies through your device or Internet browser settings to limit certain tracking or to decline cookies. Please note that by doing so, you may not be able to use certain features on our Websites or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable cookies or to control your tracking preferences. Please note that our Websites may not recognize “do not track” requests or headers from some or all browsers.
Interest-Based Advertising. You have choices for receiving more relevant advertising on the Websites or across other websites and online services, to learn more about these choice please see relevant articles at: http://www.aboutads.info/choices/, http://www.networkadvertising.org/choices/ or for your mobile device, please see: http://www.aboutads.info/appchoices. If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout/. Your browser or mobile device may also allow you to adjust your privacy and advertising settings to control advertising. Even if you opt-out, you still may receive advertising from us that is not customized based on your Service or usage information, or advertising from other third-parties.
Unsubscribing from Our Marketing Communications. We provide our customers, as well as individuals referred by our customers, with the opportunity to opt-out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service. You may simply click the opt-out link in each email.
If you receive marketing communications from one or more of our affiliates or subsidiaries, you must opt-out individually from each of the brands from which you are receiving brand-specific marketing communications.
Third-Party Communications. Any third-parties to whom we have disclosed, shared, or sold your information may have their own privacy policies which describe how they use and disclose your information and your choices. We encourage you to visit the websites of those third-parties.
- DATA SECURITY.
We use reasonable industry-accepted technology and controls to protect your information and data from disclosure to unauthorized third-parties. This includes firewalls, secured facilities, and logged and limited access. Although mostly effective to prevent disclosure, no guarantee can be given that all information you provide to us will not be accessed by unauthorized persons. Thus, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Any transmission of information, communications, and data to us or through our Website is at your own risk.
- CALIFORNIA RESIDENT RIGHTS.
California “Shine the Light” Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of Personal Information (as defined in the Shine the Light law) to third-parties for their direct marketing purposes. To opt-out of this type of disclosure, Email us at [email protected].
Additional Personal Information Disclosures.
- Third-party Business (clients) and Marketing Companies: Identifiers, Commercial information, Internet, or other electronic network activity information, Geolocation data.
- Online Advertising Networks, Social Networks, and Analytics Providers: Identifiers, Commercial information, Internet, or other electronic network activity information, Geolocation data.
- De-identified Information. We may receive or process Personal Information to create, de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain de-identified data, we maintain and use the data in de-identified form and not attempt to reidentify the data except as required or permitted by law.
California Privacy Choices. If you are a resident of California, and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
- RIGHT TO KNOW. The right to confirm whether we are processing Personal Information about you and to obtain certain personalized details about the Personal Information we collected about you, including:
- The categories of Personal Information collected;
- The categories of sources of the Personal Information;
- The purposes for which we collected the Personal Information;
- The categories of Personal Information disclosed to third-parties, and the categories of recipients to whom we disclosed the Personal Information;
- The categories of Personal Information shared for cross-context behavioral or targeted advertising purposes, and the categories of recipients to whom we disclosed the Personal Information for those purposes; and
- The categories of Personal Information sold, and the categories of third-parties to whom we sold the Personal Information.
- RIGHT TO CORRECT. The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information, and the purposes of processing the Personal Information.
- RIGHT TO DELETE. The right to have us delete the Personal Information we maintain about you, subject to additional exemptions.
- RIGHT TO CONTROL SENSITIVE PERSONAL INFORMATION. You have the right to exercise control collection and processing of Sensitive Personal Information. We do not collect, store or use Sensitive Personal Information.
- RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION. The right to direct us not to “sell” your Personal Information to third-parties for monetary or other valuable consideration. You also have the right to direct us not to use your Personal Information for automated decision-making or profiling for certain purposes. The exception to this Right is our ability to disclose, share, and sell your Personal Information to the third-parties who provide to you the services and products you requested at registration.
- RIGHT TO PORTABILITY. The right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
- RIGHT AGAINST DISCRIMINATION OR RETALIATION. You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.
How to Exercise Your Rights. Submit your request to exercise one of the privacy rights identified above, as follows:
Before processing your request, we will need to verify your identity and confirm you are a resident of California. In order to verify your identity, we will generally either require the successful authentication of your email, or the matching of sufficient information you provide us to the information we maintain about you in our system. As a result, we require requests to include first and last name, phone number, email, street address, city, state, and zip code. We may at times need to request additional Personal Information from you, taking into consideration our relationship with you and the sensitivity of your request.
We will process requests to opt-out of sales within ten (10) business days, subject to any applicable exceptions and extensions permitted by law. We will process all other privacy requests within forty-five (45) days, subject to any applicable exceptions and extensions permitted by law.
In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of California, or where we are unable to verify your identity.
Submitting Authorized Agent Requests. In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either: (i) a valid power of attorney; or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you or the California Resident to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
Retention of Personal Information. We retain Personal Information as long as is reasonably necessary to fulfill the purpose for which it was collected, as required by an applicable law, rule, regulation, or contractual provision. We will retain your Personal Information for the purposes of commercial marketing to you until you request we cease further efforts to provide you such offers or in the event you request deletion of your Personal Information. To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations. In addition, we will retain Personal Information provided, including complaints, claims, and any other Personal Information provided during the duration of your agreement with us for the Services until the statutory limitation periods have expired and the necessary for the establishment, exercise, or defense of legal claims.
Once retention of the Personal Information is no longer necessary for the purposes outlined above, we will either delete or de-identify the Personal Information or, if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from further processing until deletion or de-identification is possible.