Privacy Policy

Date of Posting: 2/14/2024

This Privacy Policy has been designed to set out our consumer information collection and processing practices related to personal information in the course of our business. This policy does not apply to our employees or business associates. Please review fully as this policy effects your rights and our use of your Personal Information and advises you how to access or delete your personal information.

1. INFORMATION COLLECTION.

We collect the following categories of information about you when you visit and use our Website, or participate in our Surveys or other promotions, or when you provide it to third-parties who have shared it with us:

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (collectively “Personal Information”), including:

(a) Personal Information, which may include your name, physical address, email address, phone number, mobile number, and identity information relating to data used to identify an individual.

(b) Commercial information, which may which includes records of your purchases of products or services from us or third-parties; as well as profile information relating to your interests, feedback information, communication preferences, customer service, and communication history, or information related to your interests, history, or tendency toward products and services, articles, and the like.

(c) Your internet or other electronic network activity information, which includes your IP address, log data, analytics data, device ID, and other data collected through pixels, cookies, web beacons, JavaScript, and similar technologies on our and third-party websites. This may also include your browsing history, search history, and your interaction with a website, app, or advertisement.

(d) Your Geographical location, when we collect your IP address, we collect your general geographic location when viewing our Website. If you provide your address in response to a prompt, then we collect your precise geo location.

(e) Recording your Calls to Us and movement through our Website, where permitted by law, we may record phone calls between us or our customer service providers. We may also implement technology on our Website which tracks and captures your browsing and use of Services while on our Website.

(f) Inferences from other Personal Information or data, we use all of the information we and third-parties collect from you 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 and this may include making a profile of you which includes all information we or they have collected, and this may result in a profile of your likes and dislikes.

(g) No Information Collected from Children. We will never knowingly collect any Personal Information from anyone under the age of 16. If we accidently do collect such information, we delete the same upon notice.

2. INFORMATION COLLECTED THROUGH TECHNOLOGY ON OUR WEBSITE AND EMAILS.

(a) Generally. We, our service provides, and third-party vendors, networks, ISP(s), and supporting advertisers use technologies such as cookies, web beacons, and java scripts to collect information about you. Using these technologies, we collect your IP addresses, browser type, ISP, referring/exit pages, operating system, date/time stamp, and/or clickstream data. We use this to analyze trends, monitor and update our Website, ease of movements through our Website, and gather demographic information about our user base, as a whole, to attract advertising on our Website. We may create reports or logs based on these technologies on an individual or aggregated basis. California residents should be advised we do not respond to do not track signals or cookies.

(b) Web Beacons. We use web beacons to collect information about your visit to our Website, measure and improve the effectiveness of advertisements, and track delivery of advertising. Web Beacons collect only a limited set of information including a cookie number, time, and date of page view, as well as a description of the page on which the Web Beacon resides. We may also use Web beacons in email messages sent to you. This allows us to determine if you opened or acted upon the email message. Because Web beacons are the same as any other content request, you cannot opt-out or refuse them. However, they can be rendered ineffective by either opting-out of cookies or changing the cookie setup in your browser.

(c) Pixels. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

3. COOKIE POLICY.

(a) A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the Website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

(i) Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

(ii) Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.<

(iii) Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around the website. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited and will not be able to monitor our performance.

(iv) Targeting Cookies. These cookies are set on our website by our supporting advertisers. They may be used by those companies to build a profile of your interests and show you relevant advertisements on our website as well as other websites. They may or may not store personal information. Often, they are based on unique identifier set in your browser and device. If you do not allow these cookies, you will experience less targeted advertising.

(v) Google Analytic Cookies. We use various ad services provided by Google that connects the activity on our Website with their advertising network and they may use cookies that collects information regarding certain patterns in your browsing history. To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google’s Analytics Advertising. This includes: (1) Remarketing with Google Analytics; (2) Google Display Network Impression Reporting; (3) Google controlled Campaign Manager integration; and (4) Google Analytics Demographics and Interest Reporting. Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis service. Google utilizes the data collected through its cookies to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-on here https://tools.google.com/dlpage/gaoptout/

4. INFORMATION RECEIVED FROM THIRD-PARTY SOURCES.

We may acquire Personal Information from other sources as follows:

(a) Service Providers. We use third-party service providers to support our Websites and Services and business processes including without limitation, identifiers, internet and electronic network activity, general geo location, and inferences.

(b) Third-Parties. We obtain Personal Information about you from third-party sources, including commercially or government provided or available sources, data aggregators or brokers, and public databases, as well as companies that license or sell your information to us. This information may include your name, general geographic information, IP Address, and publicly-observed data.

(c) 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.

5. USE OF INFORMATION.

We use the Personal Information we collect from and about you for any of the following business purposes:

(a) To provide our Websites and/or Services to you and to our clients. To analyze, improve, operate, and maintain our Websites, Services, and systems, or develop new products, services, or marketing.

(b) To obtain and pass information, products, or services that you have requested or may be of service or interest to you from us to third-parties, and this includes passing your information on to our clients who provide the products and services to communicate with you directly.

(c) To carry out our obligations and enforce our rights arising from any contracts entered into between you, us, our clients, service provides, or third-parties, involving the services or products you or they have requested.

(d) 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.

(e) To determine the effectiveness of our marketing programs, including use of your data in an aggregated non-specific format for analytical and demographic purposes. Pursue legitimate interests, such as direct marketing, research, and development (including marketing research), network and information security, and fraud prevention, and measure interest and engagement in the Services.

(f) Develop of new products and services or improve our products and Services and ensure internal quality control and safety.

(g) Verify individual identity when necessary, carry out audits, prevent prohibited or illegal services or security protocols, communicate with you about activities on the Services, and changes to our agreements, and prevent and prosecute potentially prohibited or illegal activities.

(h)Comply with our legal obligation.

(i) We may use third-parties to measure and target advertisements on our behalf that are tailored to your online interests or improve our marketing efforts. To facilitate these activities, we allow these third-parties to use cookies, web beacons, pixel tags, and similar technologies to collect certain data and other information about your online activity. 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.

6. SHARING AND SALE OF INFORMATION.

(a) Generally. All information, including the personal information (including your name and email), may be leased, licensed, shared, disclosed, or sold to third-parties including to our affiliates, service providers, vendors, advertisers, or other third-parties for third-party marketing. This may result in unsolicited email messages to you about those third-party products and services.

(b) Website Functionality. We share all categories of information set out in this policy with third-party Service Providers we employ to perform technical or analytical functions on our behalf. Examples include third-parties who host our Website, analyze our data, provide marketing assistance, and provide customer service.

(c) Third-Party Products and Services. We share all categories of information set out in this Privacy Policy with third-parties including affiliated entities, service providers, and data aggregators with your information with third-parties who will provide you with their opportunities, products, or services.

(d) Anonymized Information. We share aggregated anonymous information about you, combined with Service Providers and other third-party vendors and clients for their analysis, promotion, and marketing. This includes demographic information and behavioral information.

(e) Marketing Vendors 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.

(f) 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.

(g) Interest-Based Advertising. We may use third-parties to measure and target advertisements on our behalf that are tailored to your online interests or improve our marketing efforts. To facilitate these activities, we allow these third-parties to use cookies, web beacons, pixel tags, and similar technologies to collect certain data and other information about your online activity. 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. For more information on how you can opt-out of interest-based advertising, please visit www.networkadvertising.org.

(h) Legal Process. We disclose your information, if legally required to do so, or at our discretion, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to: (i) conform to legal requirements or comply with legal process; (ii) protect our rights, property, or our affiliated companies; (iii) prevent a crime or protect national security; or (iv) protect the personal safety of users or the public.

(i) Acquisition or Merger. We may disclose and transfer your information to a third-party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of our assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we, our liquidator, administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of, such information in a transaction approved by the court.

7. THIRD-PARTY COLLECTION AND USE OF INFORMATION.

(a) Advertisers. Advertising agencies, advertising networks, and other companies who place ads on our Website, may use their own technology, to collect information about you. We do not control the use of such technology and have no responsibility for the use of such technology to gather information about you. We also do not control how such information is used or shared. Please be sure to read their privacy policy and practices.

(b) Links. For your convenience, our Website and email messages sometimes contain hypertext links to websites owned by third-parties. We are not responsible for the privacy practices or the content of such other websites. We do not operate or control any information, software, products, or services available on these third-party websites. The inclusion of a link on our Website does not imply any endorsement of the services, products, or website, or its sponsoring organization.

(c) Analytics. As described above, we use Service Providers to monitor, analyze, and report on the traffic to, from, and within our Website and email messages.

8. STORAGE AND SECURITY OF INFORMATION.

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 data to use or through our Website, is at your own risk.

9. CHANGE TO THIS PRIVACY POLICY.

We have the right to make material changes to this Privacy Policy. We will post those changes through a prominent notice on the Website with no further notice to you. Please review this policy often so that you will always know what information we gather, how we might use that information, and with whom we disclose, share, and sell it.

10. CALIFORNIA RESIDENT SUPPLEMENTAL NOTICE.

A. 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, please email us at [email protected].

B. California Consumer Privacy Act of 2018. This Privacy Notice for California Residents supplements the information contained in our primary Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and CPRA have the same meaning when used in this Notice. The CCPA and CPRA are collectively referred to as the “CCPA” for purposes of this Notice.

C. 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. The right to exercise control over our collection and processing of 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:

• • Email Submissions to [email protected].

Before processing your request, we will need to verify your identity and confirm you are a resident of a 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 10 business days, subject to any applicable exceptions and extensions permitted by law. We will process all other privacy requests within 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.

D. 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.

E. 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.<

As such, we retain Personal Information for as long as you continue to use our Websites and/or services for the purposes explained in our Privacy Notice. When you discontinue the use of our Websites or services, we will retain your Personal Information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices you have made, such as to receive marketing communications. In particular, 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.

G. Opt-Out Preference Signal (Global Privacy Control). You may use an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”), to opt-out of the sale/sharing of your personal information. However, this technology and our use of it is not fully developed by the market. Our database containing your information may not be linked to your browser identification and because your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account or database information as the connection between your browser and our database is not known to us, we may not be able to fulfill this request. If you would like us to make the connection between your browser and your account within our database or wish to opt-out of the sale of your personal information, please email us [email protected].