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Last updated: December 23, 2019.
Collectively, we refer to the Websites, Social Media Pages, emails, and offline business interactions as the “Services.”
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:
We and our service providers collect Personal Information in a variety of ways, including:
We and our service providers use Personal Information for the following purposes:
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
We will engage in this activity with your consent or where we have a legitimate interest.
We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.
We use this information to manage our contractual relationship with you.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
We disclose Personal Information:
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
We and our service providers may collect Other Information in a variety of ways, including:
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. 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.
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 marketing-related emails from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by using the opt-out mechanism contained in each such email. 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 access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a 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), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the California Consumer Privacy Act of 2018 (“CCPA”).
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 only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and 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 recordkeeping 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:
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 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.
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.
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.
ADDITIONAL INFORMATION REGARDING THE EEA: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.
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.
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
You may also lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.
Pursuant to the CCPA, we are providing the following chart detailing which categories of Personal Information about California residents (other than employees, job applicants, contractors, dependents or beneficiaries) we collect, disclose, and/or sell.
Category of Personal Information
A. Identifiers, such as name, contact information, IP address, and other online identifiers.
B. Financial information, including payment card number.
C. Commercial information, such as transaction information and purchase history.
D. Internet or network activity information, such as browsing history and interactions with our website.
E. Geolocation data, such as device location.
F. Audio, electronic, visual, similar information, such as call and video recordings.
G. Professional or employment-related information.
H. Characteristics of protected classifications under California or federal law, such as sex, age, and marital status.
I. Biometric information, such as fingerprints and voiceprints.
J. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.
K. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
In addition to the Personal Information listed above, we also collect and disclose the following Personal Information from employees, independent contractors, owners, directors, officers and job applicants, as well as their emergency contacts, dependents and beneficiaries, for purposes of operating, managing, and maintaining our business, managing our workforce (including recruitment), and administering benefits:
A. Identifiers, such as Social Security numbers and other government-issued ID numbers;
B. Personal information, as defined in the California customer records law, such as health and health insurance information
C. Characteristics of protected classifications under California or federal law, such as race, religion, national origin, disability, request for leave, citizenship and immigration/work authorization status;
D. Professional or employment-related information, such as information relating to references, CV, details of qualifications, human resources data and data necessary for benefits and related administration services; and
E. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.
As described in detail above, under “Collection of Personal Information,” we collect this Personal Information from you and from other categories of sources, such as our joint marketing partners. Also as described in detail above, under “Use of Personal Information,” we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives.
As described in detail above, under “Disclosure of Personal Information,” we share Personal Information with other entities such as our affiliates and third-party service providers.
Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, to administer offers and events, for our employment and vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products, services, and offers; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
We share Personal Information with our affiliates, service providers, third-party sponsors of sweepstakes, contests, and similar promotions, and our business partners.
If you are a California resident, you may request that we:
To make a request for the disclosures or deletion described above, please contact us in accordance with the “Contacting Us” section above. We will respond to your request consistent with applicable law.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
If you are a resident of California, under 18, and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by contacting us in accordance with the “Contacting Us” section above. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.