LAST UPDATED: March 1st, 2020
- Through offline business interactions you may have with us.
Collectively, we refer to the Websites, Social Media Pages, emails and offline business interactions as the “Services”.
Within this Policy you will find:
- Who We Are
- Personal Information
- Collection of Personal Information
- Use of Personal Information
- Disclosure of Personal Information
- Cookies and Other Information
- Choices and Access
- Retention Period
- Third Party Services
- Jurisdiction and Cross-Border Transfers
- Sensitive Information
- Third Party Payment Services
- Contacting Us
WHO WE ARE
Personal Information is information that identifies you as an individual or relates to an identifiable individual:
- Telephone Number;
- Email Address;
- Location data (for example, a location is derived from your Internet Protocol (“IP”) address or data such as a zip code or name of a town or city);
- Information you provide on any Website page or other online sharing platforms, such as photos, comments, ratings and other information you choose to submit with us;
- Social media account ID, photos, posts and other account content; and
- Any other information you voluntarily provide so that we can communicate with you (for example, when you contact us to provide customer feedback).
COLLECTION OF PERSONAL INFORMATION
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services
- We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, or make a purchase.
- We collect Personal Information from you offline, e.g. contact customer service.
- From Other Sources
- We receive your Personal Information from other sources, for example:
- If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.
USE OF PERSONAL INFORMATION
We and our service providers use Personal Information for legitimate business purposes including:
- Providing the functionality of the Services and fulfilling your requests.
- To provide the Services’ functionality to you, such as providing you with related customer service.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
- To complete your transactions, and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions and policies.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Providing you with our newsletter and/or other marketing materials and facilitating social sharing
- To send you marketing related emails, with information about our services, new products and other news about our company.
- To facilitate social sharing functionality that you choose to use. For example, when you comment on any Website page. This informs us about who you are and how to contact you in case we want to follow up with you on your comment.
We will engage in this activity with your consent or where we have a legitimate interest.
- Analysis of Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate interest.
- Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For enhancing, improving, or modifying our current products and services;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
DISCLOSURE OF PERSONAL INFORMATION
We disclose Personal Information:
- To our third party service providers, to facilitate services they provide to us.
- These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology, marketing management, financial services, customer service, email delivery, auditing, and other services.
- By using the Services, you may elect to disclose Personal Information.
- On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages and any Website page). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations.
- This can include laws outside your country of residence.
- To cooperate public and government authorities.
- To respond to a request or to provide information we believe is important
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders or provide information we believe is important.
- For other legal reasons.
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to third parties in connection with any actual or potential reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
COOKIES AND OTHER INFORMATION
In addition to Personal Information, we and our third-party partners, also collect certain Other Information when you visit our Websites, use our Services, read our emails, or otherwise engage with us. “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. This includes:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal your specific
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Using cookies
- Through your browser or device:
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
- IP Address
- Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contacting Us section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
- Receiving electronic communications from us: We will only send you marketing-related email communications consistent with your preferences. The ability to opt in/out of such communications is available at check-out and within your account. You can also stop receiving marketing email communications from us by sending an email to email@example.com with subject “Unsubscribe”.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt- out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change or delete your Personal Information
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please send an email to firstname.lastname@example.org . We will respond to your request consistent with applicable law. In your request, please make clear what Personal Information you would like to have changed, or whether you would like to have your Personal Information suppressed from our database. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.
JURISDICTION AND CROSS-BORDER TRANSFERS
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
THIRD PARTY PAYMENT SERVICES
6060 W Manchester Ave – Suite 216
Los Angeles, CA 90045
Note: Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.