What Types of Information We Collect
While not all information that you provide or that we collect is personally identifiable information, this policy includes all information that we collect, that you provide, or that is provided to us by a third party, including personally identifiable information. Personally identifiable information includes, but is not limited to, your name, address, phone number, email address, user name and password for restricted access portions of our sites and those of our partners, and information about your devices used to access the sites. While providing some requested information on our sites is completely voluntary (for example, participating in surveys), certain parts of our sites require your personally identifiable information to either access the site or to permit the site to process correctly. This policy covers both mandatory information that you provide, as well as any voluntary information that you provide.
Additional examples of information that we collect include:
- User content, created by you during your use of a site
- Payment information, when purchasing a product or service from us
- Device information, such as your type of device, your IP address, and your service provider
- Usage information and browsing history while you are accessing any of our sites
- Location data
- Demographic information
How We Collect Information
We receive and store any information you knowingly enter on a site, whether via computer, mobile phone, other wireless device, or that you provide to us in any other way. We also receive and store information that is automatically collected through the technology. In addition, we receive and store information that is provided by third parties. We explain each method for collecting information and the types of information collected through each method in greater detail below.
This policy does not apply to websites, services or practices of companies that we do not own or control, which are subject to their own terms and conditions, even if they help us operate our sites or even if you interact with us. However, this policy does apply to information that is collected by us through third-party websites, social media sites, or services.
Information That You Provide
You may choose to voluntarily provide us with information about you at various places on the sites. Information, including personal information, may be collected at any point on our sites. You may provide information to us when you engage in any of the following activities:
- Purchase, order, return, exchange, or request information about our products or the sites;
- Create an account;
- Contact customer service;
- Participate in interactive features on the sites;
- Connect, discuss, tag, tweet, post, pin, or otherwise mention us or the sites through a social media service;
- Sign up for emails, mobile messages or social media notifications;
- Enter a contest or sweepstakes;
- Participate in a survey or a focus group;
- Provide a review, an image, an opinion, or similar content;
- Apply for employment; and
- Make comments, suggestions or provide other input on any of the sites.
YOU ARE SOLELY RESPONSIBLE FOR THE CONTENT OF THE INFORMATION YOU PROVIDE ON THE SITES AND AGREE TO PERMIT US TO ACCESS, USE OR REUSE SUCH CONTENT AS PERMITTED IN THIS POLICY AND IN OUR USER GENERATED CONTENT POLICY, IF APPLICABLE.
Automatically Collected Information
The sites automatically log information about you from your browser or mobile device when you visit the sites. The sites may use tracking pixels, web beacons, cookies and other technology to get and store information like your IP addresses, clickstream data, date and time of visits, and browser, Operating System and Internet Service Provider information, as well as other information.
Cookies enable us to offer secure pages to you without asking you to sign in repeatedly. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, and you can also set how you wish the browser to delete cookies. Disabling cookies may affect the functionality of a site or may require that you reenter data each time you visit a site, however.
Web beacons and other technologies like pixels allow us and our authorized third parties to monitor and collect certain information about users of the sites, web-based documents, e-mail messages or other communications, such as the type of browser requesting the web beacon, the device identifier of the device that the web beacon is sent to and the time the web beacon was viewed.
Information Provided By Third Parties
We engage with service providers that we use, data management or analytics companies, advertising networks, demographics companies, third parties that provide us information about you and your devices, and other collaborative third parties. We also receive information about you from our family of companies, including subsidiaries, affiliates, and parent, that you have interacted with.
How We Use the Information That We Collect and Store
We and authorized third parties engaged by us to provide services may use the information on the basis of various legal grounds, which are more fully explained in this section. We may use the information for compliance purposes, in situations where you provide consent for its use, as might be required to perform a contract with you, or for legitimate business purposes. More specifically, legitimate business purposes may include the following:
- Authenticate your identity,
- Associate your data with a unique identifier,
- Send you information,
- Deliver promotional material, including coupons, mobile coupons, newsletters and marketing communications, receipt messages, emails mobile messages, and other electronic forms of communication,
- Process and respond to requests for products, information or services,
- Fulfill and manage purchases, orders, payments, returns, or exchanges,
- Administer contests, sweepstakes and promotions,
- Conduct research and analysis,
- Manage customer service,
- Create aggregate reports that do not identify you personally,
- Customize or tailor your experience on any of our sites,
- Combine the various pieces of information that we have about you,
- Improve the sites,
- Improve or inspire our products,
- Market our products;
- Improve our internal operations (including troubleshooting, testing and analyzing usage),
- Count unique users/browsers, visits and page views;
- Monitor traffic and conversion patterns through our various product and service offerings on the sites,
- Determine whether messages were opened, links were clicked or notifications/offers were acted upon,
- Other uses consistent with our legitimate business purposes;
- Help prevent fraudulent transactions, and
- Assist law enforcement, monitor against theft or other crime or breach, and respond to subpoenas (Such disclosures may be carried out without notice to you.)
How We Share Information
We are not in the business of selling or renting your personally identifiable information. We may share information about you with third parties under the following circumstances; however, these third parties are not permitted to share or use the information for any purposes, except providing services to us:
- to help us market our products (for example, special offers) and some third party marketing or advertising purposes, though we do not share personally identifiable information about you with third parties for third party marketing or advertising purposes not consistent with the terms of this policy and applicable law;
- to provide data analysis and strategy services;
- when you consent to disclosure;
- with our parent, subsidiaries, divisions, and affiliates; and
- to enforce or apply our agreements or protect our rights.
We may disclose personally identifiable information under special circumstances, such as to comply with subpoenas, court orders, legal process or other valid law enforcement measures; to comply with a legal obligation; at the request of governmental authorities conducting an investigation; to verify or enforce compliance with the policies governing the sites and applicable laws; to protect the legal rights, interests, or safety of the sites, our users or others; or when your actions violate our terms. Such disclosures may be carried out without notice to you.
We may transfer personally identifiable information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control.
How We Secure Information
The sites take appropriate organizational, technical, administrative, and physical precautions to protect your personally identifiable information in compliance with applicable laws. We have in place a team that is responsible for implementing information security controls that are appropriate for the nature of the data involved. Our information security procedures are reviewed regularly and updated as necessary to meet the sensitivity of the information we handle, our legitimate business needs, and regulatory changes, as well as to respond to changing technology. While we believe our measures reduce the likelihood of security problems to a level consistent with the type of data involved, we cannot guarantee the security of your personal information.
How We Retain Information
Social Media Platforms
You may have rights under various United States and other laws. We will honor your rights under applicable data protection laws. Your rights may vary under the laws of each country. Please contact us using the information in the “Contact Information” Section below to make a request to access your information for a permitted purpose under applicable law. If you are not satisfied with our handling of your access request, you may have the ability to lodge a complaint with the appropriate supervisory authority if you live, work, or were infringed upon within the European Economic Area.
We provide mechanisms for updating and correcting your personal information on the sites. If you have registered for an online account, you may access and update certain personal information that you have provided to us by logging into your online account and using the features and functionalities available there.
In addition, you may also make a request for access to, to rectify or remove, or to restrict use of your personal information by sending an email at email@example.com. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Please contact us at firstname.lastname@example.org to make a request.
We may request additional information from you in order to verify your identity before accommodating an access request. If we are unable to honor a request, we will explain why.
Opting Out of Certain Contact
We may contact you if you have opted in to receive messages from us. If you no longer wish to receive messages, you may opt out of receiving these communications by changing your notification settings in your account or by opting out of a mobile messaging campaign or by unsubscribing via the opt-out link included in each e-mail or by otherwise following the instructions in the applicable technology. You may also opt out at any time by emailing email@example.com. You may also manage some third-party advertising preferences through third party opt-out and do-not-call programs. In addition, you may choose not to provide your location to us in connection with your use of our mobile applications by declining any prompt requesting location information and by customizing your mobile device settings to prevent sharing of location information. If you turn off ad tracking or location tracking, we will no longer use information collected from your device’s advertising identifier for the purposes of advertising.
ADDITIONAL NOTICE FOR CALIFORNIA RESIDENTS
If you are a California resident, the following provisions apply to our processing of any information that identifies, relates to, describes, is capable of being associated with you, your device, or your household (“California personal information”).
a. California Personal Information We Collect
We set forth the personal information we collect in the above section titled “Information Collection.” This information may contain the following categories of California personal information collected in the last 12 months:
(A) Identifiers such as a name, postal address, online identifier, unique personal or device identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
(B) Personal information described in Cal. Civ. Code Section 1798.80(e) (California Customer Records statute). This means any information that identifies, relates to, describes, or is capable of being associated with a particular individual, including, the “identifiers” listed in the preceding bullet point A.
(C) Commercial information, including (1) records of products or services purchased from us, (2) information on actions taken on our sites, including information about our products or services you considered via our sites or otherwise, (3) username, password, or other account information used to gain access to our online services; or (4) information about preferences and behavior that we collect on our sites or purchase from third parties in order to target consumers for digital advertisements or to personalize content we deliver on our sites; or (5) or other purchasing or consuming histories or tendencies.
(D) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our sites, applications, or advertisements. This includes (1) logs of your visits to and use of our sites; (2) data collected by automated means like cookies, web beacons, and similar technologies; (3) data about online activity we may receive from third parties; and (4) connection information associated with calls, text messages, and other communications with you.
(E) Geolocation data – If you use our mobile app, the app may ask for permission to use your location. If you consent, we may collect geolocation data. You can turn off our ability to collect location information in your mobile device settings at any time.
(F) Audio information from calls you place to customer service which may be recorded, and electronic information in the form of Internet or other electronic network activity information as described above may also be collected.
(G) Inferences drawn from the information listed in points (A) through (F) above, as well as any other information described in the above section titled “Information Collection,” in order to create a profile about a consumer reflecting the consumer’s preferences or characteristics.
b. How We Use California Personal Information
We use the personal information we collect for our operational purposes, including all purposes notified to you in the above section titled “How We Use the Information We Collect and Store.”
In addition to the purposes described above for which we use personal information, we may use personal information for the following business purposes:
(1) Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
(2) Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
(3) Debugging to identify and repair errors in our systems;
(4) Short-term, transient use including contextual customization of ads;
(5) Providing services on our behalf or on behalf of others, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
(6) Conducting internal research to develop and demonstrate technology; and
(7) Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide, or to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for us, or controlled by us.
We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which personal information was collected.
c. Disclosure of California Personal Information
Within the last 12 months, we have disclosed the categories of personal information identified in the above categories (A)-(G) for our business purposes. We list the categories of third parties to whom we may disclose personal information in the above section titled “How We Share Information.”
d. California Privacy Rights
If you are a California resident, you may have certain rights related to your personal information. You may exercise these rights free of charge except as otherwise provided under applicable law.
• Right to Know and Access Rights. You may request that we disclose to you:
o the categories of personal information we have collected about you;
o the categories of sources from which the personal information is collected;
o our business or commercial purpose for collecting or selling personal information;
o the categories of third parties with whom we share personal information; and
o the specific pieces of information we have collected about you.
• Deletion Rights. You have the right to request that we delete personal information about you which we have collected from you.
Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights, or any other rights under the California Consumer Privacy Act, including by (a) denying you goods or services; (b) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; or (c) providing you a different level or quality of goods or services.
As required or permitted under applicable law, please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may limit our response to your exercise of the above rights as permitted under applicable law.
To exercise any of these rights, contact us as set forth in the below section titled “Contact Information.”
If you are not 16 or older, you are not authorized to use the sites. We do not solicit or knowingly collect any personal information from children, and we will delete any information later determined to be from a user younger than 16.
Notification of Changes
This Policy is effective June 15, 2018