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If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.
You may have additional rights based on your jurisdiction. Please click the relevant link below for more information:
We collect information about you when you use the Service, including information you provide when you register an account, update your profile, access our content, participate in a promotion, contact support, or apply for a job. The categories of information we collect include:
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
In addition, we automatically collect information when you use the Service. The categories of information we automatically collect include:
The types of tracking technologies we use to automatically collect this information include:
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.
We also collect information from other sources. The categories of sources from which we collect information include:
Notwithstanding the above, we may use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) for any purpose to the extent permitted by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
Notwithstanding the above, we may disclose publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law. For information on your rights and choices regarding how we disclose information about you, please see the “Your Rights and Choices” section below.
We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service.
Some examples include:
We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).
We also use audience matching services (which is a type of Interest-based Advertising) to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Service, and the ad partner matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may disclose your hashed email address to Facebook as part of our use of Facebook Custom Audiences.
For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
You may access, update, or delete certain information that you have provided to us through your account by visiting your account settings. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.
The companies we work with to provide you with Interest-based Advertising may be participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To opt out of receiving Interest-based Advertising from the participating companies, please visit https://www.aboutads.info/choices and https://www.networkadvertising.org/choices/ for website opt outs and https://www.aboutads.info/appchoices for mobile opt outs. Note that opting out through these links only means that the selected participants should no longer deliver Interest-based Advertising to you, but does not mean that the participants will not process your information for Interest-based Advertising purposes or that you will no longer receive Interest-based Advertising from other companies.
Please note that the above opt outs only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of any opt outs offered by other entities.
To opt out of us disclosing your hashed email address to an ad partner for Matched Ads purposes, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of Matched Ads. We will remove your email address from any subsequent lists disclosed to ad partners for Matched Ads purposes.
Please note that your opt out is limited to the email address and device used and will not affect subsequent subscriptions.
The Service is not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us at firstname.lastname@example.org. We will delete the personal information in accordance with COPPA.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
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The California Consumer Privacy Act (“CCPA”), and its replacement the California Privacy Rights Act (“CPRA”), provide additional rights to California residents. This section addresses those rights and applies only to California residents. Any rights specifically relating to the CPRA shall not take effect until January 1, 2023.
We have collected the following categories of personal information (as described in the CCPA/CPRA) in the past 12 months. For further details on the personal information we collect and how we obtain this information, please review the “Information Collection” section above.
We collect and use this personal information for the business and commercial purposes set out in the “Use of Information” section above.
We disclose this personal information to the categories of persons set out in the “Disclosure of Information” section above.
We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the CCPA/CPRA. A “sale” is broadly defined under the CCPA/CPRA to include a disclosure for something of value, and a “share” is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising. We may collect, sell, or share the following categories of personal information for commercial purposes: identifiers, internet activity, non-precise geolocation data, and inferences drawn. The categories of third parties to whom we may sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. For details about your rights regarding sales and shares, please see the “Right to Opt-Out” section below.
We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.
We retain each category of personal information, for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
You have the right to know certain details about our data practices. In particular, you may request the following from us:
Unless you specify otherwise, the response we provide will cover the 12 month period preceding our receipt of the request. Starting with personal information collected on or after January 1, 2022, you may request that we disclose details beyond the 12-month period, and we shall do so unless doing so proves impossible or would involve a disproportionate effort.
In addition, you have the right to correct (effective January 1, 2023) or delete the personal information we have collected from you.
To exercise any of these rights, please email us at email@example.com. If you have an account with us, we may require you to use the account to submit the request. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
To the extent we “sell” or “share” your personal information as those terms are defined under the CCPA/CPRA, you have the right to opt-out of the “sale” or “sharing” (effective January 1, 2023) of your personal information by us to third parties at any time. You may exercise this right through our form at Do Not Sell My Personal Information or by emailing us at firstname.lastname@example.org and specifying you wish to opt-out.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at email@example.com with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
We do not sell and will not sell your covered information (as those terms are defined by NRS 603A.340).
The General Data Protection Regulation (“GDPR”) provides additional rights to individuals located in the European Economic Area, Switzerland, and the United Kingdom, (collectively, “Europe”). This section addresses those rights and applies only to those individuals.
Data protection laws in the distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Company acts as a controller with respect to personal data collected as you interact with our Service.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.
You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please contact us as set out in the “Contact Us” section above and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request.
Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you may contact our Data Protection Officer at firstname.lastname@example.org. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.