Effective date: May 20, 2020
Irrespective of which country you reside in or supply information from, you authorize us to use your information in the United States and any other country where we may operate. We control and/or operate the Platform from offices in the United States of America. We do not represent that materials on the Platform are appropriate or available for use in other locations. Persons who choose to access this Platform from other locations do so on their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent local laws are applicable.
What types of Personal Information do we collect?
The information we gather from users enables us to personalize and improve our Services, and allows our users to set up a user account and profile that can be used to personalize their experience on the Platform. We collect the following types of information (all considered “Personal Information”) from our users:
Personal Information you provide to us:
We collect and store the following types of information on our servers only when you optionally choose to provide it to us by filling out a form or taking some other explicit action. You can choose not to provide us with any of the information below, but you may not be able to take advantage of certain features without providing the appropriate information.
• First and/or last name.
• Billing information
• User name and password.
• Phone number.
Personal Information collected automatically:
In order to understand how our Platform is being used and to make it better, we also automatically receive, store, and log certain types of technical information whenever you interact with our Platform. Information of this sort includes:
• Technical information about a users’s browser and mobile device.
• Usage information such as the pages users request, searches they conduct, emails they open, and features they interact with.
• IP address, tokens, cookies, and device identifiers.
• Crashes and error reports.
How do we use your information?
In addition to the specific uses discussed above, Personal Information you submit to us may be used in the following ways:
• To provide access to our products and services.
• To keep users logged into our Platform.
• To communicate with users about their accounts.
• To process or fulfill request(s) and/or order(s) for products, Services, information or features.
• To provide users with updates, offers, and announcements about products, new products, services, features, promotions, enhancements, improvements or updates.
• To solicit input and feedback to improve user experience.
• To provide administrative services, manage account preferences, and to respond to and address technical issues, harm, or disputes.
• To help us optimize our Services.
• As we, in our sole discretion, otherwise determine to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Platform and Service.
We may provide these Services ourselves or share the information with partners who will provide the services for us. We may use aggregated user data to market the Service or the Platform to others.
How do we share your Personal Information?
We will not disclose Personal Information of our users to any persons or entities outside of our company, nor lease, license, rent, transfer, disclose, disseminate or otherwise grant access to such information unless:
• Users have been given an opportunity to “opt-in” and have agreed to opt-in to such disclosure of their information;
• We must share user information in order to provide a product or service that has been ordered or requested by that user, in which case we will require that any third person or entity we use to fulfill the order agrees that it does not have the right to use user information other than to fulfill the order or request;
• We believe in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• It is reasonably necessary to enforce our other Platform terms and conditions, this Policy, or any other legal agreements we enter with our users;
• It is required to detect, prevent, or otherwise address fraud, abuse, misuse, potential violations of law (or rule/regulation), and/or security or technical issues; or
• It is required or reasonably necessary to protect against imminent harm to the rights, property or safety of us, our users, employees, minors, members of the public and/or our Platform.
We may also disclose information about you to our auditors or legal advisors in conjunction with accessing our disclosure obligations and/or rights under this Policy.
Types and disclosures of aggregate information
We may share aggregated information concerning our users, without attribution of Personal Information, to other companies with whom we conduct business. In other words, we may combine your anonymized data with those of all or a particular group of our users to prepare collective profiles of our users and their activities for our internal use and can share the same with our partners. Such information allows us to continue to grow and provide you with quality information through higher quality product development, more relevant partnerships, and more accurate marketing and advertising of the Platform. For example, we may use and/or share the following:
• Tracked number of our users who view certain pages or use certain features.
• Compiled total dollar amount of sales conducted through the Platform in a particular geographic region.
• Tracked purchasing trends.
• Tracked user behavior and page views.
What do we do to keep your Personal Information secure?
We take commercially reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of your Personal Information that you share and we collect and store. These security measures include practices such as:
• Keeping sensitive or Personal Information on a secured server behind a firewall.
• Using secure socket layer (“SSL”) technology.
• Using regular Malware scanning.
• Internal reviews of our data collection practices and platforms.
• Physical security measures to guard against unauthorized access to systems where we store Personal Information.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Platform cannot be guaranteed and you transmit such information at your own risk; and (c) any such information and data may be viewed or tampered with in transit by a third party.
What can you do to protect your Personal Information?
While we are committed to taking all reasonable precautions to protect your Personal Information, there are steps you can take as well when using online services, such as ours:
• Use only secure websites when disclosing information.
• Create strong passwords and use them wisely (e.g. don’t use the same password for us that you use for your bank, for example).
• Never respond to unsolicited requests for social security number or financial information.
• Do not disclose passwords to the Platform or Account Information to any other person.
• If logins are required for site access, be sure to sign off when finished using a shared computer.
• Be careful about disclosing personal information such as name, address, or e-mail address in discussion forums or other public areas of the sites. Any information disclosed in public user communication, can be collected and used by third parties and may result in unsolicited messages from third parties.
• Only upload photos and other public information if it is appropriate for such information to become public under the circumstances.
What can you do if you no longer want to receive communications from us?
You can opt out of any automated notifications or communications by:
• Following the instructions included with each email.
• Contacting us with an unsubscribe request to our email address found at the end of this Policy; however our employees, contractors or agents may still need to contact users who opt out personally, for example, in response to a support inquiry or if that user is in violation of our website terms and conditions.
If we have provided any third party with your Personal Information (with your permission) and you subsequently opt-out, you will have to contact the third-party directly with your opt-out request(s).
Fair Information Practice Principles
The FTC created the Fair Information Practice Principles as a result of the Commission’s inquiry into the manner in which online entities collect and use personal information and safeguards to ensure that such practices are fair and provide adequate privacy protection. We take our own self-regulation very seriously and support your rights as a consumer to causes of action against disreputable and unprincipled data collectors and users. Consistent with the FTC’s Principles, and in the event of a data breach, we will do the following:
• Notify users by posting a notice on our Platform within 3 business day(s)
California Residents – California Civil Code Section 1798.83
California residents have the right to receive: a) information identifying any third-party company(ies) to whom we may have disclosed (within the previous calendar year) personal information pertaining to you and your family for that company’s direct marketing purposes, and b) a description of the categories of personal information disclosed. If you are a California resident and wish to obtain such information, submit a request to our email address found at the end of this Policy with “Request for California Privacy Information” as the subject line and in the body of your message. Please be aware that not all information sharing is covered by requirements and only information on covered sharing will be included in our response.
How can you update, delete, or correct your personal information?
We believe you should have the ability to access, edit, and delete the Personal Information that you have provided to us and encourage you to promptly update your Personal information if it changes. You may change any of your Personal Information in your Account online at any time by:
• Logging in in accordance with instructions posted elsewhere on this Platform.
Children’s Online Privacy Protection
Our Platform is not designed or intended for use by children under 13. If you are under 18, you should use the Platform and Services only with involvement of a parent or guardian. Children under 13 may not submit any personally identifiable information to us, and if we discover that we have inadvertently gathered any such information from a child under 13, we will take appropriate steps to delete it. If you are the parent or guardian of a person under the age of 13 who has provided personally identifiable information to us, please inform us by contacting us at [INSERT SUPPORT EMAIL i.e. privacy@___.com] and we will remove such information from our database. If you are concerned about your children’s use of the Platform, you may use web-filtering technology to supervise or limit access to the Platform. Visit www.OnGuardOnline.gov for tips from the Federal Trade Commission on protecting kids’ privacy online.
How we comply with the CAN-SPAM Act
The CAN-SPAM Act is US legislation that regulates commercial emails with strict penalties for those who send emails with materially false or misleading content or fail to provide recipients of commercial emails with an opportunity to decline them. We only collect your Personal Information for the purposes which we outlined in this Policy and we will do the following:
NOT use false or misleading information in the subject line or body of our emails.
Identify messages as advertisements by using the label “advertisement” in a conspicuous manner.
Monitor third party email marketing services, if one is used.
Label any adult content in the subject line of our emails as “ADULT”.
Provide accurate “From” fields so that users know who is sending the email.
Provide visible and operable unsubscribe mechanisms in all of our emails.
Include our physical address in the body of our emails.
Honor any opt-out requests to our emails within 10 business days.
Refrain from using harvested email addresses.
You may contact us at the email below if you would like to unsubscribe from our marketing communications at any time.
What will happen if we change this Policy?
We may update this Policy from time to time. Use of information we collect now is subject to the Policy in effect at the time such information is used. This is how you will be notified if we make any material changes to our Policy:
• We will deliver an email announcement to the email address associated with each user account. It is each user’s responsibility to maintain a valid e-mail address as a registered user. If a user opts out of communications from us, they may not receive these notifications, however the changes will still govern any use of the Service, and users are still responsible for checking for any changes.
• We will post a notice on this Platform prior to the change becoming effective.
How can you contact us?
• By email at firstname.lastname@example.org
• By calling us at 1-888-731-0571