Privacy Policy
Privacy Policy
Last updated: November 20, 2023
This Privacy Policy describes Our policies and procedures on the collection, use and
disclosure of Your information when You use the Service and tells You about Your privacy
rights and how the law
protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the
following conditions. The following definitions shall have the same meaning regardless of
whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts ofour Service.
Affiliate means an entity that controls, is controlled by or is under common controlwith a party, where "control" means ownership of 50% or more of the shares, equityinterest or other securities entitled to vote for election of directors or othermanaging authority.
Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entitythat collects Consumers' personal information and determines the purposes andmeans of the processing of Consumers' personal information, or on behalf of whichsuch information is collected and that alone, or jointly with others, determines thepurposes and means of the processing of consumers' personal information, thatdoes business in the State of California.
CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") asamended by the California Privacy Rights Act of 2020 (the "CPRA").
Company (referred to as either "the Company", "We", "Us" or "Our" in this
Agreement) refers to Beach 2U LLC, 781 Kolu St Ste E Wailuku, HI 96793.
For the purpose of the GDPR, the Company is the Data Controller.
Consumer, for the purpose of the CCPA/CPRA, means a natural person who is aCalifornia resident. A resident, as defined in the law, includes (1) every individualwho is in the USA for other than a temporary or transitory purpose, and (2) everyindividual who is domiciled in the USA who is outside the USA for a temporary ortransitory purpose.
Cookies are small files that are placed on Your computer, mobile device or anyother device by a website, containing the details of Your browsing history on thatwebsite among its many uses.
Country refers to: Hawaii, United States
Data Controller, for the purposes of the GDPR (General Data ProtectionRegulation), refers to the Company as the legal person which alone or jointly withothers determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, acellphone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatoryauthorities, in particular the U.S. Federal Trade Commission (FTC), for the Internetindustry to develop and implement a mechanism for allowing internet users tocontrol the tracking of their online activities across websites.
GDPR refers to EU General Data Protection Regulation.
Personal Data is any information that relates to an identified or identifiableindividual.
For the purposes of GDPR, Personal Data means any information relating to You
such as a name, an identification number, location data, online identifier or to one or
more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity.
For the purposes of the CCPA/CPRA, Personal Data means any information that
identifies, relates to, describes or is capable of being associated with, or could
reasonably be linked, directly or indirectly, with You.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data onbehalf of the Company. It refers to third-party companies or individuals employedby the Company to facilitate the Service, to provide the Service on behalf of theCompany, to perform services related to the Service or to assist the Company inanalyzing how the Service is used. For the purpose of the GDPR, Service Providersare considered Data Processors.
Third-party Social Media Service refers to any website or any social networkwebsite through which a User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of the
Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Beach 2U, accessible from beach2u.com
You means the individual accessing or using the Service, or the company, or otherlegal entity on behalf of which such individual is accessing or using the Service, asapplicable.
Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiableinformation that can be used to contact or identify You. Personally identifiable informationmay include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP
address), browser type, browser version, the pages of our Service that You visit, the time
and date of Your visit, the time spent on those pages, unique device identifiers and other
diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information from Third - Party Social Media Services
The Company allows You to create an account and log in to use the Service through thefollowing Third-party Social Media Services:
You may also have the option of sharing additional information with the Company through Your Third - Party Social Media Service's account. If You choose to provide such information
and Personal Data, during registration or otherwise, You are giving the Company
permission to use, share, and store it in a manner consistent with this Privacy Policy.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze OurService. The technologies We use may include:
- Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.However, if You do not accept Cookies, You may not be able to use some parts of ourService. Unless you have adjusted Your browser setting so that it will refuse Cookies,our Service may use Cookies.
- Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example,recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Free Privacy Policy website article.
We use both Session and Persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies
- Type: Session Cookies
- Administered by: Us
- Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
- Cookies Policy / Notice Acceptance Cookies
- Type: Persistent Cookies
- Administered by: Us
- Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
- Functionality Cookies
- Type: Persistent Cookies
- Administered by: Us
- Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re - enter your preferences every time You use the Website.
- Tracking and Performance Cookies
- Type: Persistent Cookies
- Administered by: Third - Parties
- Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. ThePersonal Data You provide can give You access to different functionalities of the Servicethat are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking ofthe purchase contract for the products, items or services You have purchased or of anyother contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalentforms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary orreasonable for their implementation.
- To provide Youwith news, special offers and general information about other goods,services and events which we offer that are similar to those that you have alreadypurchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- To deliver targeted advertising to You: We may use Your information to develop anddisplay content and advertising (and work with third-party vendors who do so) tailoredto Yourinterests and/or location and to measure its effectiveness.
- For business transfers: We may use Your information to evaluate or conduct a merger,divestiture, restructuring, reorganization, dissolution, or other sale or transfer of someor all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is amongthe assets transferred.
- For other purposes: We may use Your information for other purposes, such as dataanalysis, identifying usage trends, determining the effectiveness of our promotionalcampaigns and to evaluate and improve our Service, products, services, marketing andyour experience.
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with ServiceProviders to monitor and analyze the use of our Service, to advertise on third partywebsites to You after You visited our Service, for payment processing, to contact You.
- For business transfers: We may share or transfer Your personal information inconnection with, or during negotiations of, any merger, sale of Company assets,financing, or acquisition of all or a portion of Our business to another company.
- With Affiliates: We may share Your information with Our affiliates, in which case wewill require those affiliates to honor this Privacy Policy. Affiliates include Our parentcompany and any other subsidiaries, joint venture partners or other companies that Wecontrol or that are under common control with Us.
- With business partners: We may share Your information with Our business partnersto offer You certain products, services or promotions.•With other users:when You share personal information or otherwise interact in thepublic areas with other users, such information may be viewed by all users and may bepublicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service maysee Your name, profile, pictures and description of Your activity. Similarly, other userswill be able to view descriptions of Your activity, communicate with You and view Yourprofile.
- With Your consent: We may disclose Your personal information for any other purposewith Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the
purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to
retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means
that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data
protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information
represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place
including the security of Your data and other personal information.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within
the Service.
You may update, amend, or delete Your information at any time by signing in to Your
Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete
any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data
if required to do so by law or in response to valid
requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action isnecessary to:
- Comply with a legal obligation
- Protect and defend therights or property of the Company
- Prevent or investigate possible wrong doing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of
transmission over the Internet, or method of electronic storage is 100% secure. While We
strive to use commercially acceptable means to protect Your Personal Data, We cannot
guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third
- party vendors collect, store, use, process and transfer information about Your activity on Our
Service in accordance with their Privacy Policies.
Analytics
We may use third - party Service providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt - out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt - out browser add - on. The add - on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:
https://policies.google.com/privacy
Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt - out of receiving
any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
- WooCommerce Their Privacy Policy can be viewed athttps://woo.com/document/marketplace-privacy/
- Podium Their Privacy Policy can be viewed athttps://legal.podium.com/#privacypolicy-us
Payments
We may provide paid products and/or services within the Service. In that case, we may use third - party services for payment processing (e.g. payment processors).
- Authorize.net
- Their Privacy Policy can be viewed at
- https://www.authorize.net/company/privacy/
We will not store or collect Your payment card details. That information is provided directly to Our third - party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI - DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express and Discover. PCI - DSS requirements help ensure the secure handling of payment information.
Behavioral Remarketing
The Company uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third - party vendors use cookies and non - cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.
These third-party vendors collect, store, use, process and transfer information about Youractivity on Our Service in accordance with their Privacy Policies and to enable Us to:
- Measure and analyze traffic and browsing activity on Our Service
- Show advertisements for our products and/or services to You on third-party websitesor apps
- Measure and analyze the performance of Our advertising campaigns
Some of these third-party vendors may use non-cookie technologies that may not beimpacted by browser settings that block cookies. Your browser may not permit You to blocksuch technologies. You can use the following third-party tools to decline the collection anduse of information for the purpose of serving You interest-based advertising: - The NAI's opt-out platform:http://www.networkadvertising.org/choices/
- The EDAA's opt-out platformhttp://www.youronlinechoices.com/
- The DAA's opt-out platform:http://optout.aboutads.info/?c=2&lang=ENYou may opt-out of all personalized advertising by enabling privacy features on Your mobiledevice such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). SeeYour mobile device Help system for more information.
We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third
- party vendors. This allows Our third - party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third - party vendors and their cross - device capabilities please refer to the Privacy Policy of each vendor listed below.
The third - party vendors We use are:
- Google Ads (AdWords)
- Google Ads (AdWords) remarketing service is provided by Google Inc.
- You can opt - out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page:
- http://www.google.com/settings/ads
- Google also recommends installing the Google Analytics Opt - out Browser Add - on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt - out Browser Add - on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
- For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one or morespecific purposes.
- Performance of a contract: Provision of Personal Data is necessary for theperformance of an agreement with You and/or for any pre-contractual obligationsthereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legalobligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect Your vitalinterests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in thepublic interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of thelegitimate interests pursued by the Company.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
- Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third - party You have chosen, Your Personal Data in a structured, commonly used, machine - readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by
contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use
of Your Personal Data. For more information, if You are in the European Economic Area
(EEA), please contact Your local data protection authority in the EEA.
CCPA/CPRA Privacy Notice
This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the
State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular
Consumer or Device. The following is a list of categories of personal information which we
may collect or may have been collected from California residents within the last twelve (12)
months.
Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.
- Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. Collected: Yes. - Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Collected: Yes. - Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No. - Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: Yes. - Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No. - Category F: Internet or other similar network activity.
Examples: Interaction with our Service or advertisement.
Collected: Yes.
Category G: Geolocation data.
Examples: Approximate physical location.
Collected: No. - Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No. - Category I: Professional or employment - related information.
Examples: Current or past job history or performance evaluations.
Collected: No.
Category J: Non - public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No. - Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Category L: Sensitive personal information.
Examples: Account login and password information, geolocation data.
Collected: Yes.
Under CCPA/CPRA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA/CPRA's scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector - specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm - Leach - Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
- Indirectly from You. For example, from observing Your activity on our Service.
- Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
- From Service Providers. For example, third - party vendors to monitor and analyze the use of our Service, third - party vendors to deliver targeted advertising to You, third - party vendors for payment processing, or other third - party vendors that We use to provide the Service to You.
Use of Personal Information
We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:
- To operate our Service and provide You with Our Service.
- To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
- To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
- Other one - time uses.
If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We
will update this Privacy Policy.
Disclosure of Personal Information
We may use or disclose and may have used or disclosed in the last twelve (12) months the
following categories of personal information for business or commercial purposes:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category D: Commercial information
- Category F: Internet or other similar network activity
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Share of Personal Information
We may share, and have shared in the last
twelve (12) months, Your personal information
identified in the above categories with the following categories of third parties:
- Service Providers
- Payment processors
- Our affiliates
- Our business partners
- Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You
Sale of Personal Information
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.
We may sell and may have sold in the last twelve (12) months the following categories of personal information:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e)) - Category D: Commercial information
- Category F: Internet or other similar network activity
Sale of Personal Information of Minors Under 16 Years of Age
We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third - party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to
never provide information on other websites without their permission.
We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt - in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt - in to the sale of personal information may opt - out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.
Your Rights under the CCPA/CPRA
The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
- The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
- The categories of personal information We collected about You
- The categories of sources for the personal information We collected about You
- Our business or commercial purposes for collecting or selling that personalinformation
- The categories of third parties with whom We share that personal information
- The specific pieces of personal information We collected about You
- If we sold Your personal information or disclosed Your personal information for abusiness purpose, We will disclose to You:
- The categories of personal information categories sold
- The categories of personal information categories disclosed
- The right to say no to the sale or sharing of Personal Data (opt - out).
You have the right to direct Us to not sell Your personal information. To submit an opt - out request, please see the "Do Not Sell My Personal Information" section or contact Us. - The right to correct Personal Data. You have the right to correct or rectify anyinaccurate personal information about You that We collected. Once We receive andconfirm Your request, We will use commercially reasonable efforts to correct (anddirect our Service Providers to correct) Your personal information, unless an exceptionapplies.
- The right to limit use and disclosure of sensitive Personal Data. You have the rightto request to limit the use or disclosure of certain sensitive personal information Wecollected about You, unless an exception applies. To submit, please see the "Limit theUse or Disclosure of My Sensitive Personal Information" section or contact Us.
- The right to delete Personal Data. You have the right to request the deletion of YourPersonal Data under certain circumstances, subject to certain exceptions. Once Wereceive and confirm Your request, We will delete (and direct Our Service Providers todelete) Your personal information from our records, unless an exception applies. Wemay deny Your deletion request if retaining the information is necessary for Us or OurService Providers to:
- Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our
contract with You. - Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer - reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
- Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use ofdiscounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA/CPRA Data Protection Rights
Please see the "Do Not Sell My Personal Information" section and "Limit the Use or
Disclosure of My Sensitive Personal Information" section for more information on how to
opt out and limit the use of sensitive information collected.
Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:
Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
- Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
- Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
- Verify Your identity or authority to make the request
- And confirm that the personal information relates to You
Any disclosures We provide will only cover the 12 - month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your personal information
that is readily usable and should allow You to transmit the information from one entity to
another entity without hindrance.
Do Not Sell My Personal Information
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.
You have the right to opt - out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of Your personal information for interest - based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.
Website
If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell My Personal Information" buttons listed on the Service to review your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access the Service.
Additionally, You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
- The NAI's opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA's opt-out platform: http://www.youronlinechoices.com/
- The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
Mobile Devices
Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:
- "Opt out of Interest - Based Ads" or "Opt out of Ads Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices
Limit the Use or Disclosure of My Sensitive Personal Information
If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.
We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the "Use of Your Personal Data" section or contact us.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your
browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform
websites that You do not want to be tracked. You can enable or disable DNT by visiting the
preferences or settings page of Your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies orpractices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
We have no control over and assume no responsibility for the content, privacy policies orpractices of any third party sites or services.
You are advised to review this Privacy Policy periodically for any changes. Changes to this
Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
