Effective Date: August 25, 2021
This is a short summary of some key elements of this Policy, but please review our full policy below. To see the full text, including definitions of capitalized terms, you may click on the links to each section or scroll to the end.
We and/or our Service Providers may collect information such as the following, some of which may be considered “personal information” under law:
Your information may be used for business and commercial purposes such as:
Your information may be shared, without limitation, with:
YOUR CHOICES AND YOUR CA PRIVACY RIGHTS
You have certain choices regarding information collection and communications options explained here, including:
WHAT MAY WE COLLECT?
We and/or our vendors, consultants, agents, and other service providers acting on our behalf (collectively, “Service Providers”) collect information from and about you in connection with your use of the Service, as described below. Some of this may be considered “Personal Information” (or similar terms) as defined under applicable laws where you reside (collectively “Personal Information”). This may refer to information that identifies you, such as name, email, address, and other information traditionally referred to as “personally identifiable information” (or “PII”). It may also include information which relates to, or could reasonably be linked with, you or (in some cases) your household, but which may not identify you on its own, such as certain information regarding your devices, site usage, interests, and demographics. If information is aggregated or deidentified (in accordance with applicable law), it is no longer considered Personal Information. Certain publicly available data and other information may be excluded from Personal Information under applicable law as well.
Information You Provide.
We and/or our Service Providers may collect certain information, including Personal Information, that you choose to provide directly, such as:
Information Collected Automatically.
We and/or our Service Providers may use a variety of technologies that automatically or passively collect certain information about you or your device when you use the Service or certain optional features of the Service (collectively, “Usage Information”), such as:
Usage Information is primarily collected by our Service Providers and processed on an aggregated basis but may constitute Personal Information where applicable.
Technologies used when collecting information automatically may include the following customary methods, depending on the features you access on the Service and the Service Providers involved:
These technologies are used solely for the following types of purposes:
The above technologies are primarily used by these Service Providers:
We also use Mailchimp as our marketing platform for sending emails, hosting surveys, and storing certain data. They use certain technologies as described above. You may learn more about their practices at https://mailchimp.com/legal/privacy/#3._Privacy_for_Contacts.
Information from Other Sources.
We may obtain information about you from other sources, such as:
Some of this information may be treated as Personal Information we collect under certain circumstances in accordance with applicable law.
A NOTE ABOUT THIRD PARTY SERVICES
HOW MAY WE USE IT?
We may use your information, including Personal Information, for the following types of business and commercial purposes:
We will retain any Personal Information collected as long as it is needed for the above purposes and in accordance with applicable law.
HOW MAY WE SHARE IT?
We may share the information described above with other parties as follows:
Information shared with third parties may be used as described in their respective privacy policies. Some of this information may be deemed Personal Information. Please rest assured we do not sell, trade, or license Personal Information for direct marketing purposes, and would not do so in the future without your consent in accordance with applicable law.
WHAT CHOICES AND CONTROLS DO YOU HAVE?
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, then under the California Consumer Privacy Act of 2018 and its implementing regulations (collectively, as it may be amended, “CCPA”), California law provides you with specific rights regarding your Personal Information (as defined under the CCPA). These involve information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household, subject to certain exclusions such as certain publicly available, aggregated, or deidentified information, and with certain exemptions such as information collected in an employment/contractor or business-to-business context. These rights include:
(a) The right to know about the processing of Personal Information collected, disclosed, and (if applicable and as defined under the CCPA) “sold” about you in the prior 12 months, including the categories and specific pieces of Personal Information collected, the business or commercial purposes for collection and disclosure, the categories of sources from which it was obtained, and the categories of parties to whom it was disclosed.
(b) The right to request the deletion of such Personal Information collected from you, subject to certain exceptions.
(c) The right not to receive discriminatory treatment for exercising your CCPA rights. Please note we will not discriminate against you because you exercise your such rights, and we do not offer any financial incentives for the collection or use of Personal Information.
(d) If the Business “sells” Personal Information (which may be for “monetary or other valuable consideration”), the right to opt-out of the “sale.” Please note we have not “sold,” and do not “sell” your Personal Information (and accordingly, do not “sell” such Personal Information respecting children under 16). This assessment is based on the definition of “sell” under the CCPA, current regulatory guidance, and current customary interpretations. Should our practices ever change in the future, then we will provide a compliant notice and method to opt out.
Requests to Know or Delete
If you are a California consumer, you or your authorized agent may request information about the Personal Information we have collected about you in the prior 12 months (as described under (a) above) or to request that we delete your information (as described under (b) above) by emailing us at email@example.com. In the request, please specify which right(s) you are seeking to exercise and the scope of the request. In accordance with the CCPA, we may require additional information to verify your identity (or to verify that your authorized agent has the authority to make the request on your behalf) before responding to a CCPA rights request. If we are unable to so verify, we may deny your requests. We will confirm receipt and respond to all verified requests in accordance with applicable timelines required by the CCPA.
The following categories of Personal Information enumerated in the CCPA may have been collected in the past 12 months from the following potential sources (as such information and sources may be more fully described in the “What May We Collect?” section above):
These additional categories and sources may apply to information collected in the future:
In the past 12 months, any of the above categories of Personal Information collected may have been used for certain of the business and commercial purposes described in the “How May We Use It?” section above, such as Research (e.g., understanding our audience), Communications (e.g., to respond to direct requests from you), Optional Features (e.g., participation in certain activities on social media pages), and Security/Enforcement. In the future, we may use it for additional purposes such as Service Operations, and additional uses within the categories above.
In the past 12 months, any of the above categories of Personal Information collected may have been disclosed for business and commercial purposes described in the “How May We Share It?” section above, including Service Providers (e.g., our vendors performing services for us), Affiliates, and Law Enforcement/compliance. Future additional categories of disclosures may include the sharing of Identifiers and other information as may be required when you enter Promotions.
Note about CCPA: The above reflects our good faith understanding of the law and our data practices as of the date posted above, but the CCPA is a new law and there remain differing interpretations of it and its implementing regulations. Accordingly, we may update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.
“Shine the Light” Law
California’s “Shine the Light” law (California Civil Code Section 1798.83) permits California residents to request certain details about how certain types of their information are shared with third parties for such third parties’ own direct marketing purposes. We do not share such information in such manner, but should we ever do so in the future, we will provide California customers with such information upon request or permit them to opt in to, or opt out of, this type of sharing.
We take commercially reasonable steps to help protect your Personal Information against unauthorized access, disclosure, misuse, or loss. However, no data transmission or storage can be guaranteed to be 100% secure. Therefore, we cannot ensure or warrant the security of any information collected through the Service.