Updated and Effective as of September 14, 2020
Categories of Information. We and our third-party service providers (including any third-party content, advertising, and analytics providers) automatically collect certain information from your device or web browser when you interact with the Services to help us understand how our users use the Services and to target advertising to you (which we will refer to in this Privacy Notice collectively as “Usage Data”). For example, each time you visit the Services we and our third-party service providers automatically collect your location, IP address, mobile device identifier or other unique identifier, browser and computer type, Internet service provider used, clickstream information, access time, the Web page you came from, the URL you go to next, the Web page(s) that you access during your visit and your interaction with content or advertising on the Services. We may contract with third parties to collect this information on our behalf for analytics purposes.
Purposes For This Information. We and our third-party service providers use such Usage Data for a variety of purposes including to diagnose problems with our servers and software, to administer the Services, to gather demographic information and to target advertising to you on the Services and elsewhere online. Accordingly, our third-party advertising networks and ad servers will also provide us with information, including reports that will tell us how many ads were presented and clicked on the Services in a manner that does not identify personally any specific individual. The Usage Data we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Data.
We use tracking technologies, such as cookies, local storage, and pixel tags.
Cookies and Local Storage
App Technologies, Customization, and Usage
us to collect information about your installation, use, and updating of our apps as well as information about your device. More specifically, these tracking technologies allow us to collect data about your device and your use of our apps, the pages, videos, other content, or ads you see or click on during your visit and when and for how long you do so, and items you download. These tracking technologies are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include third party SDKs, which is code that sends information about your use to a server, and is in effect the app version of a pixel. These SDKs allow us to track our conversions and communicate with you across devices, bring you advertising both on and off the Sites, customize the app to your interests and preferences and link such across platforms and devices, and provide you with additional functionality, such as the ability to connect our Site with your social media account.
GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect precise location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
In addition, we use a variety of other technologies that collect similar information for security and fraud detection purposes essential to the operation of our sites and business.
You can visit the Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual (which we will refer to in this Privacy Notice collectively as “Personal Data”). If, however, you wish to register to become a member of the Services, you are required to provide certain Personal Data (for example, your name and email address), and you must also provide a username and password. We refer collectively to all information we collect that is not Personal Data, including Usage Data, demographic data and de-identified Personal Data, as “Non-Personal Data”. If we combine Non-Personal Data with Personal Data, we will treat the combined information as Personal Data under this Privacy Notice.
Personal Data, Non-Personal Data, and User Submissions are referred to in this Privacy Notice collectively as “User Information.”
Here are examples of User Information we may collect:
We use the information we collect, including Personal Data and Usage Data:
We share Non-Personal Data, including Usage Data, de-identified Personal Data and aggregated user statistics, with third parties in our discretion. Information collected via the Sites is shared among our affiliates. For example, we may share your information with our related entities including our parent and sister companies for customer support, marketing, and technical operations. We share User Information, including Personal Data, as otherwise described in this Policy, and under the following circumstances.
From time to time, we enter into relationships with third parties who provide services to us (for example, analytics and research companies, advertisers and ad agencies, data management and storage services, credit card processing services, merchandise sales facilitators, sweepstakes or contest prize fulfillment). We share your information with third parties for the purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Sites) and in connection with tailoring advertisements, measuring and improving our Sites and advertising effectiveness, and other enabling enhancements. We share aggregate information about our visitors with our advertisers, sponsors, and promotional partners, such as how many persons visited a particular page or activity, the average age of our visitors on the Site(s) or page(s), or the likes and dislikes of our visitors, but this information is not specific to any individual visitor. We obtain geographic information such as zip code clustering from other sources, but this aggregate information will not reveal the precise location of a specific visitor. We also obtain other demographic information from third parties to improve our products and services, for marketing purposes or to display more relevant advertising. In those circumstances, we disclose User Information so that such service providers perform those services. These service providers are only permitted to use your Personal Data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your Personal Data. And our sites use certain Google analytics and other services, and certain pages use the Google AMP Client ID API, each of which enable collection and sharing of your information (including Personal Data) with Google for further use. For specific information on Google usage and how to control it, please see How Google uses data when you use our partners’ sites or apps and Google’s Privacy Notice.
If you identify any User Information as public, you are authorizing us to share such information publicly. For example, you can elect to make certain of your User Submissions (such as your alias, bio, email or photos) publicly available. Also, there are areas of the Services (for example, message boards, discussion rooms, and other online forums) in which you are able to post information that automatically will be available to all other users of the Services. By choosing to use these areas, you understand and agree that anyone can access, use, and disclose any information that you post to those areas.
The Services are operated in the United States. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to, stored and processed in the United States. By using the Services or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws are not as comprehensive as those in the country where you reside or are a citizen such as the European Union. You understand that the U.S. government can obtain access to the Personal Data you submit if necessary for investigative purposes (e.g., terrorism investigation). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. We use appropriate and suitable safeguards for transferring your Personal Data to the U.S. (e.g., standard contractual clauses issued by the European Commission).
These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise those rights. The words used in this section have the meanings given to them in the CCPA, which may be broader than their common meaning. For example, the definition of “personal information” under the CCPA includes your name, but also more general information such as age.
Notice of Collection
Although the information we collect is described in greater detail in Sections 1-6 above, the categories of personal information that we have collected – as described by the CCPA – in the past 12 months are:
We do not generally “sell” personal information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in the Advertising as a “sale,” we provide you the option to request that we not “sell” your personal information. We do not sell the personal information of minors known to be under the age of 16 without affirmative authorization.
Right to Know and Delete
If you are a California resident, you have the right to delete the personal information we have collected from you and the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
We have a duty as the holder of certain personal information to verify your identity when making requests to know or delete personal information and to ensure that dissemination of that information would not cause harm to you if it were distributed to another person. To verify your identity, we will request and collect additional personal information from you to match it against our records. We may ask for additional information or documentation if we feel it is necessary to confirm your identity with the necessary degree of certainty. We may communicate with you through email, a secure message center, or other reasonably necessary and appropriate means. We do have the right to deny requests under certain circumstances. In such cases, we will notify you of the reasons for denial. We will not provide you with specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that personal information, your account with us, or the security of our systems or networks. In no event will we disclose, if we have collected it, your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.
Right to Opt-Out
To the extent we sell your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out of by clicking Do Not Sell My Personal Information. You may also submit a request to opt-out by emailing us at firstname.lastname@example.org
Right to Non-Discrimination
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
Shine the Light
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt out of this type of sharing.
To exercise a Shine the Light request, please contact us at email@example.com. You must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. Please note that we will not accept inquiries via email, and we are not responsible for notices that are not labelled or sent properly, or that do not have complete information.
We use other companies under agreements with us to serve third-party advertisements when you visit and use the Services. These companies collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Services and other Web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies, not this one. In addition, we share with these third parties any personal information you voluntarily provide, such as an email address, in response to an advertisement or sponsored content link.
In order to serve offers and advertisements that may be of interest to our users, we display targeted advertisements on the Services, or other digital properties or applications in conjunction with our content, based on information provided to us by our users and information provided to us by third parties that they have independently collected.
We offer you the opportunity to manage your communications from us. Even after subscribing to one or more newsletters and/or opting in to one or more offers to receive marketing and/or promotional communications from us or our third-party partners, users may elect to modify their preferences by following the “Communications Preferences” and/or “Unsubscribe” link provided in an email or communication received. You may also be able to change your preferences by updating your profile or account, depending on which of our Services you are using. Please be aware that if you wish to remove yourself from a newsletter and/or other marketing emails from third parties that you consented to through the Services, you must do so by contacting the relevant third-party. Even if you do opt-out of marketing emails, we reserve the right to send you transactional and administrative emails including those related to the Services, service announcements, notices of changes to this Privacy Notice or other Services policies, and to contact you regarding any goods or services you have ordered.
You may request access to the information you have provided to us. If you wish to make a request, please contact us using the details in the Contact Us section below. If you would like to update, correct, modify or delete from our database any Personal Data you previously submitted to us, please let us know by logging in and updating your profile. If you delete certain information you may not be able to order services in the future without re-submitting such information. We will comply with your request as soon as reasonably practicable. Also, please note that we will maintain Personal Data in our database whenever we are required to do so by law, for necessary operational reasons, or to maintain uniform business practices.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (for example, when you enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such promotion). We will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
If you are a resident of the European Economic Area (EEA), you have the right to: (a) request access to your Personal Data and rectification of inaccurate Personal Data; (b) request erasure of your Personal Data; (c) request restrictions on the processing of your Personal Data; (d) object to processing your Personal Data; and/or (e) the right to data portability (collectively, “EU Requests”).
We can only process EU Requests from a user whose identity has been verified. To verify your identity, please provide your email address or [URL] when you make an EU Request. For more information about how to get access to Personal Data and for exercising your rights, you can submit a request here by selecting the “I am an EU resident and would like to exercise my individual rights” option. You also have the right to lodge a complaint with a supervisory authority.
We have implemented commercially reasonable and appropriate technical and organizational security measures to help protect your Personal Data from accidental or unlawful destruction, loss, alteration, misuse, or unauthorized access or disclosure; unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your User Information, we cannot guarantee its security. You use the Services and provide us with information at your own initiative and risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Us section below.
The Services contain links to other websites that we do not control, and the Services contain videos, advertising and other content hosted and served by third parties. We are not responsible for the privacy practices of any third-party. We may also integrate with third parties who will interact with you under their terms of service.
The Services are intended for a general audience and are not intended for and should not be used by children under the age of 18. We do not knowingly collect information from children under the age of 18 and we do not target the Services to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Us section below. We will delete such information from our files as soon as reasonably practicable.
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive Personal Data as this term is defined under applicable data protection and privacy laws (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
If you send or disclose any sensitive Personal Data to us, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Notice. If you do not consent to our processing and use of such sensitive Personal Data, you must not submit such content to our Services.
We update this Privacy Notice from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Data by posting a notice on relevant areas of the Services. We will also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Privacy Notice will be effective immediately upon the posting of the revised Privacy Notice unless otherwise specified. Your continued use of the Services after the effective date of the revised Privacy Notice will constitute your consent to those changes. However, we will not, without your consent, use your Personal Data in a manner materially different than what was stated at the time your Personal Data was collected.
If you have any questions about this Privacy Notice, please feel free to contact us by email at: firstname.lastname@example.org.