Last updated: April, 2023
- certain information that is publicly available;
- information that is deidentified or aggregated in a way that it cannot be used to identify a particular consumer or household (“Deidentified Data”). We commit to maintaining Deidentified Data in its deidentified form and not to attempt to reidentify the Deidentified Data, except and solely for the purpose, of determining whether our deidentification processes satisfy the requirements of applicable laws; or
- information we collect, receive, or otherwise process for or on behalf of our customers through or in connection with our Services (“Customer Personal Data”). We do not control what Customer Personal Data our customers may collect, receive, or otherwise process through or in connection with their use of our Services. Instead, we collect, receive, and otherwise process Customer Personal Data at their direction and on their behalf. For this reason, any Customer Personal Data collected, received, or otherwise processed through our Services is covered by our customers’ applicable privacy policies and notices.
TYPES OF PERSONAL DATA COLLECTED
The categories of Personal Data we collect and use in connection with your access to, use of, or interaction with our Operations may fall into one or more of the categories described below. Please note, the types of Personal Data within each category below are provided as examples of the types of Personal Data within each category and are not a representation that we will actually collect that the specific type of Personal Data from or about you.
- Identifiers, such as your real name, alias, email address, IP address, account name, and other similar identifiers.
- Financial Information, such as your bank account number or credit card number. Please note, we will only collect your Financial Information if you use your personal credit card or bank account to pay for services we provide to the applicable customer.
- Commercial Information, such as records of products or services purchased, obtained, or considered, and other similar information.
- Internet or Other Similar Network Activity, such as information about your interactions with our websites or online advertisements and other similar information.
- Non-Sensitive Geolocation Information, such as the city, state, and ZIP code associated with an Internet Protocol address and other similar imprecise location information.
- Professional or Employment-Related Information, such as your current employer, job title, and other similar information.
- User Generated Information, such as feedback, comments, and other information you elect to provided us through or in connection with your access to, use of, or interaction with our Operations.
SOURCES OF PERSONAL DATA COLLECTED
A large portion of the Personal Data we collect from or about you in connection with our Operations is collected directly from you or in connection with your access to, use of, or interaction with our Operations (including Personal Data we automatically collect). You have the option not to provide any Personal Data we ask you to provide in connection with your access to, use of, or interaction with our Operations. However, there are some features of our Operations where we have to collect certain Personal Data, and, if you do not provide us with the required Personal Data, you will not be able to access, use, or interact with that feature.
From Third Parties
We may also receive information (which may include Personal Data) about you from third parties, including, without limitation, online and offline sources, social media platforms, advertising networks, or other public or commercial sources, which may include, without limitation, the following categories of third parties:
- Social Media Platforms – This category includes social media platforms owned or operated by third parties, such as Facebook, Instagram, LinkedIn, Twitter, and YouTube, where we maintain a social media account or where you otherwise interact with us or share our content.
- Transactional Third Parties – This category includes third parties who are not related to us but provide us with Personal Data necessary to enable us to provide you with certain features and functionalities of our Operations.
- Service Providers – This category includes third parties that provide services to us related to the functionality and operability of our Operations, such as hosting the online portions of our Operations, managing communications we send and receive, and processing orders and payments.
- Targeted Advertising Partners – This category includes third parties that facilitate the delivery of our targeted advertisements, promotions, and offers.
- Analytics Providers – This category includes third parties that operate tracking technologies, such as web beacons, cookies, clear gifs and pixel tags on the online portions of our Operations to collect information used to analyze the use and performance of our Operations, including, among other things, measuring the effectiveness of our Operations, content, communications, and advertising.
USES OF PERSONAL DATA COLLECTED
The primary purposes for which we use Personal Data we collect or receive through or in connection with our Operations are:
- Customer Service and Communications – We may use Personal Data to: (1) provide customer service and support; (2) respond to your requests for information about our Operations or Services; (3) call or email you with alerts and updates about our Operations or Services; and (4) administer surveys or otherwise obtain feedback from you.
- Business Purposes – We may use Personal Data for business purposes that include, without limitation: (1) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, any contracts with you or our applicable customers; (2) operating and improving our Operations and Services; (3) conducting statistical or demographic analysis; (4) customizing your experience with the online portions of our Operations; (5) preventing fraud; (6) assessing the success of our marketing and advertising campaigns; and (7) other business purposes permitted under applicable law.
- Marketing Purposes – We may use Personal Data to advertise and market to you, including notifying you about special promotions, opportunities, offers, and events through calls, emails, or other means.
- Law Enforcement/Legal Purposes – We may use Personal Data to cooperate with law enforcement or for other legal purposes, including to: (1) comply with legal and regulatory requirements; (2) cooperate with law enforcement or other governmental agencies for the purposes of investigations, public safety, or matters of public importance where we are legally required to do so or believe that disclosure of Personal Data is necessary or appropriate to protect the public interest; and (3) protect and defend against legal actions or claims.
RETAINING PERSONAL DATA COLLECTED
We retain Personal Data for only as long as we have a legitimate business purpose to keep it. These purposes may include retaining Personal Data to:
- complete the transaction for which the Personal Data was collected;
- continue our ongoing business relationship with you or our applicable customer;
- ensure the security and integrity of our Operations; and
- satisfy any legal, regulatory, tax, accounting, or reporting requirements.
To determine the appropriate retention period for individual categories of Personal Data we collect, we consider the nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the Personal Data, the purposes for which we process that Personal Data and whether we can fulfill those purposes through other means, and applicable legal, regulatory, tax, accounting, reporting, or other requirements.
DISCLOSING PERSONAL DATA TO THIRD PARTIES
In order to conduct our Operations, comply with our obligations under applicable laws and agreements, we may disclose your Personal Data to certain third parties, including, without limitation, the following categories of third parties:
- Service Providers – We may disclose Personal Data to our service providers, including, without limitation, the third parties that provide services to us related to marketing, hosting the online portions of our Operations, payment processing, and fraud protection and prevention.
- Marketing Partners – We may disclose Personal Data to third parties that facilitate the delivery of targeted ads, promotions, and offers on and off of the online portions of our Operations.
- Government and Law Enforcement – We may disclose your Personal Data to individuals or private parties where necessary to enforce and comply with the law, to protect our property or legal rights, for the safety of the public or any person, to prevent harm, and to protect the security and integrity of our Operations.
- Professional Advisors – We may disclose your Personal Data to our professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to us.
- Others – We may disclose your Personal Data to any other third party upon your request or with your express consent to do so.
ANALYTICS TOOLS WE USE
We may use, or permit the use of, analytics tools on the online portions of our Operations that, subject to your choices and any exercise of rights available to you, may collect information about you in connection with your access to, use of, or interaction with the online portions of our Operations, which may include, without limitation:
We use these tools to learn whether the online portions of our Operations are operating optimally, learn whether you are a repeat visitor to the online portions of our Operations, personalize advertising, obtain valuable data and statistics about the usage and effectiveness of the online portions of our Operations, and help us provide an enjoyable, personalized and innovative online experience for you. We may combine information gathered from these cookies and other tracking technologies with other Personal Data.
Generally, the type of information we collect through cookies and other tracking technologies is specific to your computer or other device and includes the date and time a device accessed the online portions of our Operations; what parts of the online portions of our Operations were accessed and if they were delivered successfully; and the IP address, internet service provider, device ID, approximate geographic location, and browser type of a device that accesses the online portions of our Operations.
The Options/Settings section of most internet browsers will tell you how to manage cookies and other tracking technologies that may be uploaded to your device, including how to disable such technologies. You can disable our cookies, or all cookies, through your browser settings, but please note, disabling cookies may impact some of the features of the online portions of our Operations and may prevent them from operating as intended. You can learn more about cookies, including how to see what cookies have been uploaded to your device and how to manage and delete them, by visiting https://www.allaboutcookies.org/.
- Analytics and Interest-Based Advertising Tools – The online portions of our Operations may include certain analytics and advertising tools provided or operated by third parties, including:
HOW TO MANAGE YOUR PERSONAL DATA
We recognize that you may want to limit how your Personal Data is collected, used, and shared. We offer several choices with respect to how we collect or use your Personal Data, including:
- Opting Out of Email Marketing – You can opt-out of receiving marketing and other promotional email communications we send you by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send to you for non-marketing purposes, including, but not limited to, emails and other communications about your access to or use of the Services.
- Opting Out of Targeted Advertising – If you wish to limit third-party advertising, you can visit the National Advertising Initiative Consumer Opt-Out page and the Digital Advertising Alliance’s Consumer Choice Tool. In addition, the electronic device you use to visit the online portions of our Operations may offer additional privacy settings; please see the device settings for details. Please note that even if you opt-out of receiving interest-based advertising, you will still receive advertisements, but they will be more general in nature.
- Updating Your Personal Data – If you wish to update or correct any Personal Data you have provided to us, you can contact us by email at firstname.lastname@example.org. We recommend that you do not use email communications to send us sensitive Personal Data. If you need to change that Personal Data, we recommend that you call us directly at 855-980-2144.
- Additional Rights for Residents of California – If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your Personal Data to third parties for direct marketing purposes: (1) the categories of Personal Data we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the information; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you. You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to
Attn: CA Privacy Rights Request
1301 Spring Street, Suite 25i
Seattle, WA 98104
THIRD PARTY PLATFORMS AND OTHER SITES
SECURITY OF PERSONAL DATA
We are committed to protecting the security of your Personal Data. We use commercially reasonable safeguards to maintain the security and privacy of Personal Data we collect and use in connection with our Operations. Nevertheless, when disclosing Personal Data, you should remain mindful that there is an inherent risk in the transmission of information via the internet. Although we take precautions to protect against the risk of unauthorized access to your Personal Data, we cannot guarantee the security of any information, including your Personal Data, that you disclose and you do so at your own risk.
INDIVIDUALS OUTSIDE THE UNITED STATES OF AMERICA
We are located in the United States of America and all Personal Data we collect or receive on or in connection with our Operations will be collected or received in the United States of America. If you access, use, or otherwise interact with our Operations or otherwise engage with us from outside the United States, please be aware that the laws applicable to Personal Data collected, stored, used, or otherwise processed in United States of America may not provide the same protections as the laws in other countries or economic regions.
We do not target or direct our Operations at children under the age of 18. If we learn that we have collected the Personal Data of anyone under the age of 18, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 18 and discover that your child has submitted Personal Data to us, please contact us at email@example.com. We will make reasonable efforts to remove such information from our databases.