- SCOPE AND APPLICATION
2. HOW WE COLLECT INFORMATION
We may collect information about you through the following categories of sources:
- Directly or indirectly from you, through our Services both online (e.g., website, app) and offline (e.g., at locations we operate from);
- From organizations that we may partner with to provide the Services to you;
- By combining information from different sources, including online and offline data; and
- From other sources and social media platforms that you may use to engage with us.
3. THE TYPES OF INFORMATION WE COLLECT
We may collect the following categories of information:
- Profile information, such as your name, mailing address, e-mail address, phone number, and usage and other preferences (and username and password, or other user credentials, if we provide any access-restricted Services);
- Transactional information including a history of all transactions you engage in with us through the Services including services purchased, obtained or considered, account balances and activity;
- Survey information in response to questions we may send you through the Services, including for research purposes or to improve our Services;
- Promotional information we collect when you participate in a loyalty program (e.g., points accrued or used) or in other contests we may offer;
- User Content that you may provide to publicly post via the Services if we permit (e.g., audio, photos, videos, comments, and other materials) along with any information you provide about yourself and the content—this may also include metadata associated with your content (such as location and date / time information embedded in pictures);
- Communications between you and us, such as via e-mail, mail, phone (e.g., recordings of calls with our customer service center) or other channels;
- Offline activity you engage in with us, such as at locations we operate from;
- Online User Activity described in the next section; and
4. AUTOMATED COLLECTION OF ONLINE USER ACTIVITY
We, our service providers and advertising partners may collect certain information about your device and use of our Services by automated means, including but not limited to cookies, pixels, SDKs and other similar technologies (“Online User Activity”). For example, a cookie is a file that may be placed on your device when using our Services to uniquely identify you or store information on your device for later retrieval. Cookies are very commonly used by websites and most browsers are configured by default to accept cookies.
When you use any website or app we provide, the information that we may collect by such automated means includes, for example:
- Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
- Device information and online identifiers including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, the device’s telephone number and your choice of communication settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”));
- Location information where you choose to provide us with information about your device’s location.
5. HOW WE USE THE INFORMATION THAT WE COLLECT
Except where otherwise noted, we may use the personal information that we obtain about you for the following business and commercial purposes as allowed by applicable laws:
- Provide our Services to you, including for identity verification and to determine if you qualify for certain Services we offer, to manage your interactions with us, facilitate memberships, subscriptions, payments and other transactions with us, to link your Account with third party services, general business operations and administration, and respond to your inquiries and other communications;
- Engage in customer satisfaction and marketing activities, and tailor the content that we display to you in our Services and communications, including data analytics, industry and market research, lead generation, advertising, and offer services and information that we believe may be of interest to you;
- Comply with and enforce as needed applicable legal requirements, industry standards, our policies, and our contractual rights, which includes, for example, for audit, compliance, policy, procedures, or regulation needs, to maintain the security our systems and services, and to investigate customer and insurance claims, fraudulent activities, and accidents;
- Analyze and enhance our communications and strategies, such as by identifying when emails sent to you have been received, read or acted upon; and
- Engage in data analytics to operate, evaluate, and improve our Services, including for customer analysis and modeling, credit risk management, customer applications and credit approvals, to monitor the performance of our Services through metrics such as total number of visitors, traffic, and demographic patterns, as well as optimize, diagnose or fix issues with the Services.
We may also use or share information in an anonymized or aggregate manner for many purposes such as research, analysis, modeling, marketing, and advertising, as well as improvement of our Services.
6. ONLINE ADVERTISING
You may see us promoted by other organizations, on various websites, web pages, social media and other platforms. Please note that we do not always have complete information about where our organization may be displayed or promoted, and if you believe that our Services our featured in venues that are inappropriate or offensive, please contact us.
7. HOW WE SHARE YOUR INFORMATION
We will not disclose your personal information to third parties without your consent, except in the following circumstances.
- We may share your information as permitted by law, including, for example, with our corporate affiliates, and with service providers that we believe need the information to perform a technology, business, or other professional function for us (examples include IT and cloud services, maintenance and hosting of our Services, payment processors, shipping and returns partners, data analytics providers, marketing partners, social networks and other service providers). We only provide such vendors with information so they can perform their required functions on our behalf.
- We also may disclose information about you (i) if we are required to do so by law or legal process such as a subpoena, when we believe in good faith that disclosure is necessary or proper; (ii) when we believe disclosure is necessary to prevent harm or financial loss; (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity, including a violation of our Terms; or (iv) under exigent circumstances to protect the personal safety of our staff, users or the public.
- Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us and applicable law.
8. YOUR PRIVACY CHOICES
We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.
- Account profile: Your online account profile may provide different options for the type of personal information you can provide as well as the types and methods of communication that you prefer. You may view or update your profile and privacy settings by logging in to your online account.
- Marketing Emails: From time to time, we may contact you via email or through other channels for the purpose of providing announcements, promotional information and/or other general communication. In order to improve our Services, we may be notified when you open an email from us or click on a link therein. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we may continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our terms of service.
- Text messages: In the event you are enrolled in any service that provides text messages to you, you can opt-out by replying “STOP” to any text message received.
- Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly.
- Mobile devices: As with cookies, mobile devices may allow a user to block certain information requests or device permissions (e.g., location information), but doing so may adversely impact some features or functions offered by our Services. Mobile device or mobile operating system providers typically provide instructions on how to adjust such privacy features.
9. STATE-SPECIFIC NOTICES
a. California residents
For California residents, the California Consumer Protection Act (the “CCPA”) provides various rights to individuals and households with respect to the collection and use of personal information that we have collected about you.
- You may request a copy of the following: (1) the categories of personal information we collected about you in (at least) the last 12 months; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting or selling (if applicable) the personal information; (4) the categories of third parties with whom we shared personal information in (at least) the last 12 months (if applicable), and the categories of personal information shared; and (5) the specific pieces of your personal information that we have collected, used, disclosed, or sold.
To request a copy of personal information we have collected about you, or to request that your information be deleted, please contact us via firstname.lastname@example.org. You may have an authorized agent submit a request on your behalf the same way. Shortly after you (or your agent) submit a request, we will check our records for matching information and contact you (via email at the email address provided during submission of your request) with instructions on how to verify the request before we fulfill it. We will aim to complete your requests as soon as reasonably practicable and consistent with any applicable laws. If you have an account with us, you may also see certain personal information (such as certain profile and transaction information) directly through your account page.
It is unlawful for us to discriminate against you because you exercised any of your rights under the CCPA. We do not “sell” your personal information for monetary or other valuable consideration, as that term is interpreted under CCPA.
We may offer discounts or other benefits to individuals who enroll in certain programs offered through our Services, such as opting-in to email promotions, text alerts, or certain services or loyalty programs we may offer. Please refer to the webpages where those programs are posted for details about their respective terms and conditions, and please note that they are subject to change from time to time. You can always opt-out of these programs, by contacting us, at email@example.com. We do not generally assign monetary value to consumers’ personal information, and promotions activity associated with any subscription programs we offer changes continually. To the extent the CCPA requires that a value be assigned to such programs, or to the price or service differences they involve, we value the information collected and used under each program as being equal to the value of the discounts or other financial incentives provided in each such program, based upon a practical and good-faith effort to assess, on an aggregate basis for all collected information: (i) the type of information collected in each program (e.g., email address), (ii) the use of such information by us in connection with marketing activities, (iii) the discount or free items we provide, and (v) the volume of individuals enrolled in the programs. These variable factors continue to change over time. This description is without waiver of any proprietary or business confidential information, including trade secrets, and it does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.
b. Nevada residents
For Nevada residents, please note that we do not sell personal information as defined by Nevada law (Ch. 603A, Sec. 1.6). You can submit a request to us regarding the sale of such information via the contact information provided below.
10. CONFIDENTIALITY AND SECURITY
We endeavor to maintain reasonable administrative, technical and physical safeguards designed to protect the personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot ensure the security of any information you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.
11. CHILDREN’S PRIVACY
Our Services are not directed to children under the age of sixteen (16) nor do we market our products or services to such children. We do not knowingly collect any data from or about children under the age of 16. If you believe that we might have any information from or about a child under 16, please contact us as directed below.
12. VISITORS TO OUR SERVICES OUTSIDE THE UNITED STATES
14. CONTACT US