Last Updated/Effective Date July 1, 2020:
Table of Contents:
- SCOPE AND APPLICATION: What and who this Policy covers
- COLLECTION OF INFORMATION: The sources of and methods by which we, our service providers, and our advertisers collect information from and about you, including information about your interaction with the Company Services
- USE AND DISCLOSURE: How we use the information we collect from and about you, and who we might share it with and why
- SECURITY: How we protect your information from loss or misuse
- USER ACCESS AND CONTROL: How you can access and control the information we maintain about you
- OTHER IMPORTANT INFORMATION: Other things you should know about this Policy and how we handle your information
- CONTACT US: How to contact Company about this Policy
- CALIFORNIA CONSUMER PRIVACY ACT NOTICE: Other things you should know if you reside in California
2. COLLECTION OF INFORMATION
Company and our service providers may collect the following information from and about you:
Registration Information is the information you submit to register for a Company Service, for example, to receive a newsletter or enter a giveaway. Registration Information may include, for example, name, email address, and zip code.
Public Information and Posts consist of comments or content that you post to the Company Services and the information about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public Information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.
Activity Information. When you access and interact with the Company Services, Company and its service providers may collect certain information about those visits. For example, in order to permit your connection to the Company Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the Company Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other transactional information for that device.
Cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology including cookies) are comprised of small bits of data. Company’s websites, apps and other services send this data to your browser when you first request a web page and then store the data on your computer or other device so the website or app can access information when you make subsequent requests for pages from that service. These technologies may also be used to collect and store information about your usage of the Company Services, such as pages you have visited, and the video and other content you have viewed.
Other parties that support the Company Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate Company Services usage statistics, may also use these technologies to collect similar information when you use the Company Services or other parties’ services. Those parties may also use these technologies, along with activity information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer. Company does not control these technologies and their use is governed by the privacy policies of parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, including your choices with respect to them, see the section entitled “To deliver relevant advertisements,” below.
Your browser may be initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information. Users can manage the use of Flash technologies, with the Flash management tools available at Adobe’s website, see http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. To opt out of Google Analytics specifically, go to https://tools.google.com/dlpage/gaoptout. Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the Company Services.
Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services, commercially available sources, and information from our Company Affiliates or business partners.
Do Not Track Signals. At this time we do not respond to browser 'Do Not Track' signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted.
3. USE AND DISCLOSURE
We may use the information we collect from and about you to provide the Company Services and features to you, including: to measure and improve those Company Services and features and to develop new products and services; to improve your experience with both online and off-line Company Services by delivering content you will find relevant and interesting, including advertising and marketing messages; to allow you to comment on content, and participate in online games, contests, other promotions, or rewards programs; to provide you with customer support and to respond to inquiries. In order to provide you with content and advertising that is more interesting and relevant to you, we may use the information from and about you to make inferences and predictions about your potential areas of interest. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with other parties, to the extent permitted by applicable law.
We use the information we collect from and about you for these additional purposes:
To allow service providers to assist us in providing and managing the Company Services. The information we collect from and about you may be made available to certain service providers, such as contractors, analytics and other measurement companies, agents or sponsors, who help us analyze and understand your use of the Company Services, and manage and/or provide the Company Services.
To contact you. Company may periodically send promotional materials or notifications related to the Company Services. If you want to stop receiving promotional materials, you can follow the unsubscribe instructions at the bottom of each email. There are certain service notification and other non-promotional emails that you may not opt-out of, such as notifications of changes to the Company Services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.
To share with business partners. Company may share your information with business partners to permit them to send you marketing communications consistent with your choices.
To complete a merger or sale of assets. If Company sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), Company may transfer your information to the party or parties involved in the transaction as part of that transaction.
Company uses commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft and unauthorized use, disclosure, or modification. However, no one can guarantee the complete safety of your information.
5. USER ACCESS AND CONTROL
If you would like to access, review, correct, update, suppress, delete, or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us as outlined in Section 7; or using the mechanisms provided below. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, suppress, or delete. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.
If you are a resident of California, please see the section entitled “California Consumer Privacy Act Notice,” below, for more information about the rights you have under California law.
You may request that we not share your personal information on a going-forward basis with Company Affiliates or unaffiliated third parties for their direct marketing purposes by contacting us as outlined in section 7 below. We will try to comply with your request(s) as soon as reasonably practicable and consistent with applicable law.
6. OTHER IMPORTANT INFORMATION
Location of Data. The Company Services are hosted in and managed from the United States. If you are a user located outside the United States, you understand and consent to having any personal information processed in the United States or in any other country in which we have facilities or in which we engage service providers. United States and other countries’ data protection laws may not be the same as those in your jurisdiction.
In addition, Company is not responsible for the privacy or data security practices of other organizations, such as Facebook, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the Company Services.
Remember that even after you cancel your account, or if you ask us to delete your personal information, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services. Because of the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, for fraud detection or to comply with applicable law or our internal security or recordkeeping policies. It may not always be possible to completely remove or delete all of your information due to technical constraints or contractual, financial or legal requirements.
7. CONTACT US
8. CALIFORNIA CONSUMER PRIVACY ACT NOTICE
This California Consumer Privacy Act Notice Section provides information for California residents in connection with the California Consumer Privacy Act (“CCPA”). Under the CCPA, and for purposes of this Section, “Personal Information” generally means information that identifies, relates to, or describes a particular California resident and includes the categories listed below. This Section 8 provides details about the categories of Personal Information of California residents that we have collected, disclosed, or “sold” during the last 12 months, as well as rights California residents have under California law.
Categories of Personal Information Collected, Disclosed, and/or Sold:
The categories of Personal Information that we collected, disclosed, and/or “sold” are below, along with the categories of third parties to whom each category of Personal Information was disclosed, and/or “sold.” Please note that we disclose some categories of Personal Information in connection with certain types of advertisements, which could be considered a “sale” under the CCPA. Also, depending on the California resident’s interactions with us, Company may not have collected, disclosed, or “sold” each of these categories about each individual. Additionally, we do not knowingly “sell” Personal Information of minors under 16 years of age.
|Category of Personal Information Collected;||Categories of Third Parties to Whom Personal Information Is Disclosed;||Categories of Third Parties to Whom Personal Information is “Sold”|
|Identifiers, such as name, IP address, email address, and online and device identifiers;||Service providers, Company Affiliates, and other providers or partners that support our operational business purposes||Advertising provider|
|Personal information, as defined in the California Customer Records law, such as contact information;||Service providers, Company Affiliates, and other providers or partners that support our operational business purposes||Advertising provider|
|Internet or network activity information, such as browsing history and interactions with our websites, mobile, or connected TV applications (collectively, “Company Digital Properties”);||Service providers, Company Affiliates, and other providers or partners that support operational business purposes||Advertising provider|
|Geolocation data, such as device location;||Service providers, Company Affiliates, and other providers or partners that support operational business purposes||N/A|
|Audio, electronic, visual and other similar information, such as photographs and videos;||Service providers, Company Affiliates, and other providers or partners that support operational business purposes||N/A|
|Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.||Service providers, Company Affiliates, and other providers or partners that support our operational business purposes||Advertising provider|
Please note that the CCPA definition of “sale” does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other similar transaction involving of all or any portion of our business.
Sources of Personal Information. We collect this Personal Information directly from California residents themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to a Company Digital Property); joint marketing, co-branding, co- promotional, or advertising partners; Company Affiliates; and sources of demographic and other information. Depending on the individual’s interactions with us, Company may not have collected Personal Information from each of these categories of sources.
Purposes. We may use this Personal Information for the following purposes:
- to operate, manage, and maintain our business;
- to provide our products and services;
- to accomplish our business purposes and objectives, including: developing, improving, repairing, and maintaining our products and services; personalizing, advertising, and marketing our products and services; conducting research, analytics, and data analysis; maintaining our facilities and infrastructure; quality and safety assurance measures; performing identity verification; performing accounting, audit, and other internal functions; complying with law, legal process, and internal policies; maintaining records; and exercising and defending legal claims.
- developing, improving, repairing, and maintaining our products and services;
- personalizing, advertising, and marketing our products and services;
- conducting research, analytics, and data analysis;
- maintaining our facilities and infrastructure;
- quality and safety assurance measures;
- performing identity verification;
- performing accounting, audit, and other internal functions;
- complying with law, legal process, and internal policies;
- maintaining records; and
- exercising and defending legal claims.
Depending on the California resident’s interactions with us, Company may not have used Personal Information collected about that resident for each of these purposes.
California Rights. If you are a California consumer, you have the following rights:
- Right to Know. You have the right to request that we disclose to you the following information:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information during the 12 months prior to your request;
- The specific pieces of Personal Information we collected about you during that time period;
- The business or commercial purpose for collecting, disclosing, or selling Personal Information about you;
- The categories of Personal Information about you that we sold and the categories of third parties to whom we sold that Personal Information; and
- The categories of Personal Information about you that we otherwise shared or disclosed and the categories of third parties with whom we shared or disclosed that Personal Information.
To make a request for your Personal Information, please click here or call us at 888-596-3929. You will need to provide your name and email address, along with other details about your request. You will then receive verification instructions by email. For certain requests, you will be asked to authenticate to your account as part of the verification process, if you have an account/profile with us. But you do not need to have an account/profile to submit a request, In some circumstances, we may need additional information from you to verify your identity or proceed with your request.
You can use an authorized agent to submit a request for your Personal Information. When submitting a request online, your authorized agent should select the “Other” option on the form and, in the field provided, include your name, your email address, and whether or not you have an account/profile with us. In addition to verifying your identity, as described above, we also will need to verify your authorized agent’s ability to act on your behalf (e.g., by receiving a copy of your signed permission). Once verification is complete, we may communicate directly with you for privacy and security reasons.
Please note that, in some instances, we may decline to honor your request, where, for example, we are unable to verify your identity or an exception to this right applies.
2. Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you.
To make a request for deletion, please click here or call us at 888-596-3929. You will need to provide your name and email address, along with other details about your request. You will then receive verification instructions by email. For certain requests, you will be asked to authenticate to your account as part of the verification process, if you have an account/profile with us. But you do not need to have an account/profile to submit a request. Please note that you also will be asked to separately confirm that you would like to proceed with your deletion request. In some circumstances, we may need additional information from you to verify your identity or proceed with your request.
You can use an authorized agent to submit a request for deletion. When submitting a request online, your authorized agent should select the “Other” option on the form and, in the field provided, include your name, your email address, and whether or not you have an account/profile with us. In addition to verifying your identity, as described above, we also will need to verify your authorized agent’s ability to act on your behalf (e.g., by receiving a copy of your signed permission). Once verification is complete, we may communicate directly with you for privacy and security reasons.
Please note that, in some instances, we may decline to honor your request where, for example, we are unable to verify your identity or an exception to this right applies.
3. Right to Opt-Out of Sale. As noted above in this section, we share some categories of Personal Information in connection with certain types of advertisements. Because interest-based advertising relies on cookies and other similar technologies, opting out needs to be controlled at the device and/or browser level. If you wish to opt out of the sharing of your Personal Information in connection with tailored advertising in desktop and mobile browsers, please visit http://optout.aboutads.info/#/ or http://optout.networkadvertising.org/#. To opt out in mobile apps, you may use your device’s “Limit Ad Tracking” or similar settings or download and use the AppChoices app at https://youradchoices.com/appchoices. To opt out on connected TVs, please use the “Limit Ad Tracking,” “Interest-based Ads,” or equivalent settings on your device. Please note that opting out does not mean that you will stop seeing all ads. You can visit our “Do Not Sell My Personal Information” Internet Webpage here.
4. Right to be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.