Effective & last modified May 28, 2019
Information We Collect
We may collect personally identifiable information (“Personal Information”) when you request information from us, apply for or enroll in our programs, enter in or participate in our contests, sweepstakes or other promotions, vote in polls or otherwise express an opinion, subscribe to one of our services, participate in one of our online surveys, forums, or communities, register on a site, and at other times when we give you the opportunity to provide us Personal Information. Further, you will provide Personal Information when you search for a product, place an order through the Site, provide information on any account you have with us, communicate with us by phone, e-mail or otherwise. As a result of those actions, you might supply us with such information as your name, address and phone numbers; credit card information; people to whom purchases have been shipped; email addresses of you and other people; content of reviews and e-mails to us; personal description and photographs; and financial information.
The decision to provide this information is optional. However, if you choose not to provide the requested information, you may not be able to purchase our products or enroll in our programs or use some or all of the features of our Properties.
Information About Others
The Properties may allow you to (i) submit information about other people, such as their name, e-mail, zip code, address, information about their interest in and use of various content, products, programs and services, and other information, and/or (ii) invite friends to join the Properties and to connect with you through our social media pages associated with Social Networking Sites (as defined below). We may collect any such information submitted or shared by you. The decision to provide such information is optional.
Usage Data and Site Activity
Collection and Sharing of Location Information
In addition to other information described in this policy, we may collect and share precise location information, through methods such as mobile “SDKs”. This location information may be used by itself, aggregated, or combined with mobile identifiers (such as IDFAs and Android IDs), and shared with third parties, for purposes related to advertising, attribution (e.g., measuring ad performance) analytics and research. You can remove your consent to having your location data collected by changing the settings on your device.(Certain services may lose functionality as a result.) You can opt-out from any interest-based advertising through your device settings. When you have opted out using this setting on a device, advertisers will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.
Cookies and Web Beacons
Our Properties may enable the use of the Adobe Flash Player. Adobe’s Flash Player is used by the vast majority of websites that offer video and other interactive content. By default, your use of the Adobe Flash Player generates “flash cookies” (also known as “persistent identification elements” or “local shared objects”). The Adobe Flash Player (and similar applications) use flash cookies to remember user settings, preferences and usage similar to the browser cookies referenced above, but flash cookies can store more information than browser cookies and are managed through a different interface than the one provided by your web browser. You can control the degree to which you accept flash cookies by accessing your Adobe Flash Player management tools directly through the settings manager for Adobe Flash. If you do not allow flash cookies to take any disc space on your computer, you may not be able to take advantage of or participate in certain features of a Property.
Although the Adobe Flash Player is used by the vast majority of websites that offer video content and/or games, it is not the only technology being used in the ever-shifting online and mobile content environment. HTML5 is an increasingly popular web standard used for presenting content, especially content delivered to mobile devices. HTML is the mark-up language used for the World Wide Web. Almost all web pages you visit on the internet are based around HTML code. HTML5 is simply the fifth and latest iteration of this mark-up language that allows for more interactive web pages. One of the real benefits of HTML5 is its potential to standardize the highly fragmented rich-media universe. Some HTML5 code may allow your response to advertising and other activities to be monitored across websites and such information to be stored on your computer or mobile device. Technology solutions that allow users to opt-out of or block this sort of tracking are being developed through browser add-ons and other tools.
How We Use Information and When We May Share and Disclose Information Generally
Use of Information
We use Personal Information for internal purposes, such as to improve the Properties, to fulfill requests for products and services, to notify you of new products or services, and to otherwise communicate with you about Company, our products and our affiliated companies.
We may use Usage Data for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit the use of the Properties. We may associate your Usage Data with the Personal Information you provide. We may disclose to third parties certain Usage Data regarding the Properties. However, in such cases, your Usage Data will be aggregated with the Usage Data of others and will not identify you individually or include your Personal Information.
Disclosure of Information
Third-Party Providers. From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Third-Party Providers”). For example, we contract with Third-Party Providers to provide certain services, such as hosting and maintenance, data storage and management, marketing and promotions, fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. We generally only provide our Third-Party Providers with the information necessary for them to perform these services on our behalf.
Joint Offerings. We may provide services jointly with other companies such as booking an appointment, scheduling a delivery, or ordering a product. In some cases, in order to facilitate such services, it may be necessary to share your Personal Information with such other companies. In these cases, the service provider will be identified to you and you will have the option to not participate in the service or transaction.
Sweepstakes, Contests and Other Promotions. If you choose to enter a contest, sweepstakes or other promotion (each, a “Promotion”), your Personal Information may be disclosed to third parties in connection with such Promotion, including without limitation, for purposes of posting your entry with attribution or otherwise as permitted in the official rules for the Promotion in question, fulfilling your prize or including your name on a winners list. Also, by entering a Promotion, we may require you to consent to the use of your Personal Information or other information, such as name, voice or likeness, in advertising, promotional and marketing materials. In addition, we may offer a Promotion sponsored by or co-branded with a third party, who may obtain the Personal Information that you submit.
Affiliated Entities and Successors. We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with Company. If Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
Legal Disclosures. Company cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information (and any other information about you or content posted or transmitted by you through the Properties) to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property or rights of Company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
Location Information. To help us improve our service we collect the following information on an anonymous basis: Operating System, Date & time, Latitude, Longitude, Accuracy (GPS), SSID (network), BSSID (network), Internal MAC address (network), Bundle ID, Device Model, Device Manufacturer, Carrier Code (Android only), Carrier Name, Sim Code, Country, and Locale. In addition to helping us to measure the usage of our app this anonymous information is shared with third parties for their business purposes, including the creation of reports, market research and trend analysis. One of these third parties is Huq, data shared does not contain information from which users can be identified and we will not provide additional information to such third parties that enables such third parties to identify you. You can find a full description of Huq and what it does with the information collected via our app here.
Managing Your Information Preferences
If you want to opt out of having your Personal Information disclosed to third parties for their direct marketing purposes, please let us know by sending us an email at email@example.com. Please be sure to include your full name, email address, mailing address, and specifically state that you do not want your personal information shared with third parties for their direct marketing purposes.
Additionally, you will have an opportunity to unsubscribe from receiving promotional material from Company by sending us an email at firstname.lastname@example.org.
Third Party Services and Applications
The Properties may enable you to access third-party services, social media sites, plug-ins and applications, such as Facebook, Twitter and other social networks (each a “Social Networking Site”) and/or connect your accounts from such Social Networking Sites with the Properties by an application programming interface (API) or other software. When you do so, you may be able to import information from and share content, including Personal Information, with those Social Networking Sites. Some of those Social Networking Sites may also provide us with information from your accounts (e.g., photographs, gender, birthday, location, your “friends” list, people you follow and/or who follow you, your posts and “likes” and Usage Data), which may enable us to enhance and personalize your use of the Properties. By allowing us to connect with your accounts on Social Networking Sites, you consent to our accessing the information in those accounts. You likewise consent to our publishing on the Properties any such information or actions you take on other such Social Networking Sites. If you elect to access such Social Networking Sites through the Properties or connect your accounts from such Social Networking Sites with the Properties, the information you share with such Social Networking Sites will be subject to their privacy policies and your privacy settings for such services. You also may be able to control or block such sharing by changing your privacy settings in such Social Networking Sites.
Sharing Information with Others
Please be aware that whenever you share information on a publicly available page or via comments, discussion boards, or any other public forum on the Properties, or when you interact with our Properties through any Social Networking Site, that information may be accessed by others. In addition, please remember that when you share information in any other communications with third parties, including information in direct messages to other users, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending you unsolicited communications. We reserve the right to monitor your communications with others conducted through the Properties, as well as the right to monitor and respond to your communications on our social media pages associated with any Social Networking Site. We may disclose such communications in our discretion for legal enforcement and compliance purposes as described above. Company assumes no responsibility for any action or policies of any third parties who collect any information users may disclose in user forums or other public areas, if any, of a Property or our social media pages associated with any Social Networking Site.
Company recognizes the importance of safeguarding the confidentiality of your Personal Information. Accordingly, we employ commercially reasonable measures designed to protect your information from unauthorized access, disclosure and use. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Properties, we cannot and do not guarantee the security of any information you transmit on or through the Properties, and you do so at your own risk.
The Properties are not intended for children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records. In addition, we recommend that minors 13 years of age or older ask their parents for permission before sending any information about themselves to anyone over the Internet. You hereby agree that all information you provide, including but not limited to age, shall be truthful and correct.
If and to the extent that we offer any program open to children under 13 years of age, we will collect Personal Information about them from parents and guardians for purposes of considering their admission, enrollment and other administrative purposes. We will not share the Personal Information of anyone under 13 years of age with any third party without the consent of a parent or legal guardian.
If and to the extent that we knowingly collect, use or disclose Personal Information from children under the age of 13, we will comply with the Children’s Online Privacy Protection Act (“COPPA”) (and other applicable laws) and obtain parental consent.
Processing in the United States
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