The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through the Website represents to us that he or she is 13 years of age or older. If we learn that personal information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has transferred personal information to the Website, please contact Company using our contact information below to have that child’s account terminated and information deleted.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
“Personally-Identifying Information” is information such as a name or email address that, without more, can be directly associated with a specific person. Company collects certain Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves at the time they create an account. That information may include each user’s name, address, and email address. We also may request information about your interests and activities, your gender, job title, age, date of birth, username, hometown, country, postal code and other demographic information, and other relevant information as determined by Company from time to time. If you are transacting business with us, then we may also collect credit or debit card information or other payment information. Users of the Website are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
We may occasionally use names and email addresses and other contact information provided to us to send users notifications regarding new services offered by the Website that we think they may find valuable. We may also send users service-related announcements from time to time that may include, without limitation, notifications of service expiration and renewal and related payment information, as well as other information related to the expiration or renewal. We reserve the right to send you notices about your account even if you opt out of all voluntary email notifications.
Company will disclose Personally-Identifying Information under the following circumstances:
Direct Mail Partners. From time to time we may share our postal mailing list with selected providers of goods and services that may be of interest to you. If you prefer not to receive mailings from these providers, you may opt-out at the time you register for our Website, or at any time thereafter by going to your account settings or contacting us using the contact information below.
Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, Company will email users about products and services that Company believes may be of interest to them and Company also will provide users’ email information to third parties, so that those third parties may directly contact users about additional products and services. If a user wishes to opt-out of receiving marketing materials from Company, user may do so by following the unsubscribe link in email communications, by going to your account settings or contacting us using the contact information below. Similarly, to cease having your email information provided to third parties, you may do so by going to your account settings or contacting us using the contact information below. Even after opting-out, a user may continue to receive marketing emails from third parties to whom Company already has provided the user’s email information. Users will be responsible for directly contacting such third parties to request cessation of further marketing emails.
Business Partners: When you make purchases or engage in promotions offered through our Website or our services, we may share Personally-Identifying Information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address and other information to that merchant.
Co-Branded Partners. If you have joined our Website through one of our co-branded websites, then we may also share your Personally-Identifying Information with the co-branded partner that is associated with the co-branded website. Such shared information will be subject to the privacy policies applicable to such co-branded partner.
Third Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, sweepstakes, surveys and other features offered through our Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
Changing Personally-Identifying Information; Account Termination
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Users of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. Like most website operators, Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system and browser type, and the locations of the Web pages the user views right before arriving at, while navigating and immediately after leaving the Website. Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.
A “Web Cookie” is a string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the site. Company uses Web Cookies to track the pages that users visit during each Website session, both to help Company improve users’ experiences and to help Company understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the Website is being used. Company does not attempt to link information gathered using Web Cookies to Personally-Identifying Information. However, when logged in, a Web Cookie is associated with a unique user profile. Therefore, users are advised to clear Web Cookies from computers whenever finished with a logged in session if those computers will also be used by other persons. PLEASE NOTE THAT IF YOU SET YOUR BROWSER TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, YOU WILL NOT BE GRANTED ACCESS TO THE WEBSITE. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.
Third Party Advertisers
We use third-party advertising companies to serve ads when you visit the Website. These companies may use information (not including any Personally-Identifying Information) about your visits to this and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the following link: http://networkadvertising.org/managing/opt_out.asp. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.
We allow advertisers to choose the characteristics of users who will see their advertisements and we may use any of the non-personally identifiable attributes we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. We do not identify you to the advertiser.
A “Web Beacon” is an object that is embedded in a web page that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails, and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons, however, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered and permit you to accept or decline Web Cookies on an individual basis.
Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on our Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
We take security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot control the actions of other users with whom you share your information. We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share will not become publicly available. We are not responsible for third party circumvention of any privacy settings or security measures.
The Website encrypts sensitive information such as your credit card number and your personal information using secure socket layer (SSL) technology to provide for the secure transmission of the information from your computer to our servers. In addition, we use commercially reasonable efforts to limit access to your Personally-Identifying Information to the employees, agents, and officers of Company who need the information for their jobs. All of our employees are kept up to date on our privacy and security practices. For more information about the security measures Company uses in connection with the Website, please contact us using the contact information found below.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.
Because we do not collect or determine the use of any Personal Data contained in the Client Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, We are not acting in the capacity of data controller in terms of the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”) and does not have the associated responsibilities under the GDPR.