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Thank you for visiting an online service (e.g., website or mobile app) that posts a link to this Privacy Policy (“Service”) owned or operated by Interlaced Social LCC and its affiliates d/b/a adsbj (“AB”, “we,” or “us” or “our”). AB has created this Privacy Policy because we value our members and recognize their right to keep personal information private.
The AB Privacy Policy may be found below. In this Privacy Policy, we provide you with information as to how AB collects, uses, and shares information about you, including the choices AB offers with respect to that information, and applies to your use of any Service, regardless of how you access or use it. It does not apply to DL’s data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection). For certain Services, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you.
We are not responsible for information that you disclose to third parties, such as to other members of AB or other sites/apps throughout the Internet. By using the AB site or otherwise using the Service, you agree to the Service’s Terms of Use, Website Guidelines & Code of Conduct,and Prohibited List as well as DL’s data collection, use, and disclosure practices, other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service. If you do not agree and consent, please discontinue use of the Service and uninstall Service Downloads and applications.
California and Nevada residents have certain privacy rights detailed in the Your State Privacy Rights section here.To the extent that there is a conflict between this Privacy Policy and the State Privacy Rights section, the State Privacy Rights section will control as to California and Nevada residents.
About Ads and Tracking: Learn about certain choices regarding Tracking Technologies, including certain sharing of activities, location and/or cross-device usage for interest-based advertising here.
To aid navigation, click on the section headings below:
1. Personal Information We Collect
2. How We Use the Information We Obtain
3. Information We Share With Third Parties
4. Sweepstakes, Contests, and Promotions
5. Information You Disclose Publicly or to Others
6. Third-Party Content, Third-Party Services, Social Features, Advertising & Analytics
7. Data Security and Monitoring
10. Accessing and Changing Information
11. Choices: Tracking and Communications Options
(1)Personal Information We Collect
(2)California Consumer Privacy Rights
(c) Do Not Sell
(d) Non-Discrimination and Financial Incentive Programs
(3) How to Submit a Request Under the CCPA
(a) Methods to Submit a Request
13. Changes to This Privacy Policy
14. Contact Us
DL and/or its Service Providers (defined below) may collect information you provide directly to AB and/or its Service Providers via the Service. For example, AB collects information when you set up an account and thereafter when you use the Service, subscribe to notifications, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices, click here. For more information on Service Provider data collection and practices click here.
Information DL, its Service Providers and/or Third-Party Services may collect may include: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number (“Personally Identifiable Information” or “PII”); and (2) demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases
(“Demographic Information”)
. Except to the extent required by applicable law, Demographic Information is“non-Personally Identifiable Information”
or“non-PII”
(i.e., data that is not Personally Identifiable Information under this Privacy Policy). In addition, Personally Identifiable Information, including, without limitation, DL-Collected PII (defined below), once “De-identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements, including through anonymization, pseudonymization, and/or hashing) is also non-Personally Identifiable Information and may be used and shared without obligation to you, except as prohibited by applicable law. However, we do not make assurances that De-identified data is not capable of re-identification. To the extent any non-Personally Identifiable Information, or PII collected outside of the Service, is combined by or on behalf of AB with Personally Identifiable Information AB itself collects directly from you on the Service (“DL-Collected PII”), AB will treat the combined data as DL-collected PII under this Privacy Policy. The definition of “personal information” under certain state laws differs from the definition of PII used in this Privacy Policy. California and Nevada residents can learn more about their privacy rights here.DL, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of AB with DL-Collected PII, AB does not consider Usage Information (including, without limitation, unique device identifiers) to be Personally Identifiable Information or DL-Collected PII. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.
The methods that may be used on the Service to collect Usage Information include:
Note the Links Above Should be Enabled and Should Go to the Following:
Some information about your use of the Service and certain other online services may be collected using Tracking Technologies across time and services and used by AB and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain other online services. See Section 11 regarding certain choices regarding these activities.
DL is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
DL may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with DL-Collected PII. Notwithstanding anything to the contrary, except to the extent such data is combined by or on behalf of AB with DL-Collected PII, this Privacy Policy is not intended to limit DL’s activities regarding such third-party-sourced, or non-Service-sourced, information (including Personally Identifiable Information), and such data will only be treated as DL-Collected PII to the extend it is combined with DL-collected PII. AB is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.
Generally.
DL may use information about you, including DL-Collected PII and other Personally Identifiable Information, for any purposes not inconsistent with DL’s statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:
Except as restricted by applicable law, this Privacy Policy, or any other representation AB makes to you, AB may share non-Personally Identifiable Information, and Personally Identifiable Information that is not deemed DL-Collected PII hereunder (provided that AB is aware of no restrictions of DL’s use, if any), with third parties for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your Personally Identifiable Information, including DL-Collected PII, to non-Personally Identifiable Information, including without limitation through hashing it or substituting a unique identifier for the Personally Identifiable Information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices. DL’s sharing of DL-Collected PII is, however, subject to the following:
DL may also share any information about you (including, without limitation, DL-Collected PII) for any purposes not inconsistent with this Privacy Policy, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation as follows:
DL may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personally Identifiable Information. If you voluntarily choose to enter a Promotion, your information, including Personally Identifiable Information, may be disclosed to DL, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy. Please review those rules carefully.
The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personally Identifiable Information. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including DL. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personally Identifiable Information included in UGC is not subject to DL’s usage or sharing limitations, or other obligations, regarding DL-Collected PII or other Personally Identifiable Information under this Privacy Policy or otherwise, and may be used and shared by AB and third parties to the fullest extent not prohibited by applicable law. AB encourages you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Service’s Terms of Use click here.Although use of the Service is restricted to adults, California minors should see Section 13 of the Terms of Use regarding potential removal of certain UGC they have posted on the Service.
Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, AB relies on you to only send to people that have given you permission to do so. The recipient’s Personally Identifiable Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by AB for any other marketing purpose unless AB obtains consent from that person. Your contact information and message may be included in the communication.
The Service may include or link to third-party websites, apps, locations, platforms, code (e.g., plug-ins, application programming interfaces (“API”), and software development kits (“SDKs”)) or other services (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technologies to independently collect information about you and may solicit Personally Identifiable Information from you.
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” DL’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5) or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Service (e.g., by using a hashtag associated with AB in a tweet or status update), your post may be used on or in connection with the Service or otherwise by DL. Also, both AB and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
DL may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on other online services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on another online service after you have left the Service (i.e., “retargeting”). We may use Microsoft and Google for advertising services. See Section 11 for more information on your choices regarding certain personalized advertising.
DL may use Google Analytics, Adobe Analytics or other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help AB analyze Service users and how they use the Service. Information generated by these analytics services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage. See Section 11 for more information on your choices regarding these services.
DL is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.
DL takes reasonable measures to protect DL-Collected PII (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and DL does not guarantee the security of your information collected through the Service.
To help protect you and others, AB and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including DL-Collected PII and other Personally Identifiable Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Service; ensure compliance with the Terms of Use and this Privacy Policy; investigate violations of or enforce these documents; improve the Services and your Services experiences, and to protect the rights and property of DL, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.
The Service is intended for adults and not directed to individuals that are not at least 18 years of age (or 21 years of age in places where 18 years is not the age of majority). In addition, the Service is not available to anyone who is not at least 18 years of age (or 21 years of age in places where 18 years is not the age of majority). If you are not at least 18 years of age, you are not permitted to become a member, or to directly or indirectly view, possess, or otherwise use the Service.
If you are aware that a child or minor uses the Service, please contact us at [email protected] or using the information provided below so we can take appropriate actions.
DL does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.
DL is based in the U.S. and the information AB and its Service Providers collect is governed by U.S. law. If you are located in the European Union (EU), European Economic Area (EEA), and/or Switzerland, please note that AB does not intend to offer goods and services (include the Service) to EU, EEA, or Swiss individuals. The U.S. may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence.
Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personally Identifiable Information, in the U.S. as set forth in this Privacy Policy.
DL may provide web pages or other mechanisms allowing you to delete, correct, or update some of the DL-Collected PII, and potentially certain other information about you (e.g., profile and account information). DL will make good faith efforts to make requested changes in DL’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from DL’s databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required or permitted by applicable law; (b) to enforce our Terms of Use, and (c) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
a. Tracking Technologies Generally.
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Please be aware that if you disable or remove certain Tracking Technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, AB currently does not alter DL’s practices when AB receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visithttp://www.allaboutdnt.com, but AB is not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. AB is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section. We may, from time-to-time, and in certain jurisdictions, offer or point you to tools that allow you to exercise certain preferences regarding cookies and other Tracking Technologies associated with the Services, but such tools rely on third parties and third party information so we do not guaranty that the tools will provide complete and accurate information or be completely effective. For instance, here is where you can find cookie controls for popular browsers:
We do not represent that these third-party tools, programs or statements are complete or accurate. You will need to do this on each browser that you use to access our Services, and clearing cookies on your browser(s) may disable your preference settings. Also, our Services may not function properly or as intended if you block all or even certain cookies. Accordingly, you may want to consider the more limited opt-out choices noted in the next section.
b. Analytics and Advertising Tracking Technologies.
You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled “Tell our customers not to measure your use of their web sites or tailor their online ads for you.”
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. AB supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks AB directly engages to serve you Interest-based Advertising will do so as well, though AB cannot guaranty their compliance.
We may also use Microsoft Advertising Services. To learn about the data Microsoft collects and how your data is used by it and to opt-out of certain Microsoft browser Interest-based Advertising, please visit here.
We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to opt-out of certain Google browser Interest-Based Advertising, please visit here.
In addition, we may serve ads on other online services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”). This is done by using Tracking Technologies or by matching common factors between our data bases and the data bases of the other online services. For instance, we may use such ad services offered by Twitter and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
DL is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
You can opt out of receiving certain promotional communications (emails or text messaging) from AB at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from AB to text the word, “STOP”. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, AB may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or DL’s ongoing business relations
To learn more about how you can exercise certain choices regarding Cross-device data for Interest-based Advertising, see the prior section regarding the DAA’s Interest-based Advertising choices.
We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine the Light Law”) with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us at [email protected] or by sending a letter to adsbj; ATTN: Legal Department, 2261 Market Street #4626, San Francisco, CA 94114. Any such request must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
Effective Date of Notice: January 1, 2022
This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (together with its regulations, the “CCPA”) as a supplement to DL’s Privacy Policy and any other privacy policies or notices. In the event of a conflict between any other AB policy, statement or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA. Please see also any the general privacy policy or notice posted or referenced on our websites, apps, products, or services.
Consistent with the CCPA, Section (1) of this Notice covers our collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA for the twelve months preceding the Effective Date and will be updated annually. Our current privacy notices at the point of collection, as well as our general privacy policies and other privacy notices may reflect practices that are more current. Section (2) of this Notice explains the rights California Consumers have under the CCPA.
Consistent with the CCPA, job applicants, current and former employees and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered “Consumers” for purposes of this California Privacy Notice or the rights described herein. Publicly available information is also not treated as PI under the CCPA, so this notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data. Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.
In 2021, we collected, retained, used, and disclosed PI about California Consumers as follows:
|
Category of PI | Examples of PI |
| Identifiers | This may include but is not limited to: a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
| Personal Records | This may include information such as: physical characteristics or description, signature, telephone number, zip code, city, billing address, credit card number, debit card number, or any other financial information. |
| Personal Characteristics or Traits | This may include, but is not limited to: sex, marital status, gender identity, and creed. |
| Customer Account Details/Commercial Information | This may include, but is not limited to: records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. . |
| Internet Usage Information | This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement. |
| Geolocation Data | This may include, but is not limited to: precise physical location or movements and travel patterns. |
| Sensory Data | This may include, but is not limited to: audio recordings of customer care calls. |
| Inferences from PI Collected | This may include, but is not limited to: creating a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
The chart above reflects that categories of PI required by the CCPA. There may be additional information that we collect that meets the CCPA’s definition of PI but is not reflected by a category, in which case we will treat it as PI as required by the CCPA, but will not include it when we are required to describe our practices by category of PI.
As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We have no obligation to re-identify information or keep it longer than we need it to respond to your requests.
We may collect your PI directly from you or from your devices, and from service providers, as well as public sources of data
Generally, we collect, retain, use, and share your PI to provide you services and as otherwise related to the operation of our business. For more detail on our disclosures and sale of PI, see the next section.
We may collect, use and share the PI we collect for one or more of the following business purposes:
Additional business purposes include sharing PI with third parties for other than a sale or one of the foregoing business purposes as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with law or legal process, and to the consumer or other parties at the consumer’s request, and for the additional purposes explained in our Privacy Policy, and to assignees as part of an acquisition, merger, asset sale, or other transaction where a third party assumes control over all or part of our business (“Other Business Purposes”).
Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed business purposes. Our vendors may themselves engage services providers or subcontractors to enable them to perform services for us,which sub-processing is, for purposes of certainty, an Other Business Purpose for which we are providing you notice.
We may collect and use your PI for commercial purposes, such as for interest-based advertising.
In addition, we may collect, retain, and use PI for the purpose of sharing it as set forth in the next section.
In 2021, we disclosed PI about California Consumers to our service providers, other vendors, including those that facilitate interest-based and other advertising and marketing and/or other third parties, including without limitation as follows:
|
Category of PI | Categories of Recipients |
| Identifiers | Business Purpose Disclosure:
Sale: Cookie Operators (as defined in the Do Not Sell section below) |
| Personal Records | Business Purpose Disclosure: Third Parties (where the disclosure is not a sale, e.g., Other Business Purposes) Sale: Not Sold |
| Personal Characteristics or Traits | Business Purpose Disclosure:
Sale: Not Sold |
| Customer Account Details/Commercial Information | Business Purpose Disclosure:
Sale: Not Sold |
| Internet Usage Information | Business Purpose Disclosure:
Sale: Cookie Operators (as defined in the Do Not Sell section below) |
| Geolocation Data | Business Purpose Disclosure:
Sale: Cookie Operators (as defined in the Do Not Sell section below) |
| Sensory Data | Business Purpose Disclosure:
Sale: Not Sold |
| Inferences from PI Collected | Business Purpose Disclosure:
Sale: Not Sold |
For more information on your do not sell rights, see the Do Not Sell subsection below.
We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as more fully explained in the Right to Know and Right to Delete sections below. We will not fulfill your Right to Know or Right to Delete request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. To make a request, email us at [email protected] or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make.
Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest or not. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you financial account number, or an account password in response to a CCPA request; however, you may be able to access some of this information yourself through your account if you have an active account with us.
Your California Consumer privacy rights are as follows:
To make a Right to Know (Categories) or Right to Know (Specific Pieces) request, email us at [email protected] or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquiries we make. We will respond to your request as outlined in the How to Submit a Request Under the CCPA section below. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
For Categories of Information requests, as required by the CCPA, we will apply the verification standards set forth in the How to Submit a Request Under the CCPA section below.
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.
For Specific Pieces of Information requests, as required by the CCPA, we will apply the heightened verification standards set forth in the How to Submit a Request Under the CCPA section below.
You may request that we delete your PI that we have collected directly from you and are maintaining. However, we may have a basis for retention under CCPA.. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you.
For Delete requests, as required by the CCPA, we will apply the verification standards set forth in the How to Submit a Request Under the CCPA section below.
To make a Right to Delete request, email us at [email protected] or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquiries we make.
Deletion of your personal information will not deactivate your account. As a result, we cannot delete personal information necessary to maintain the account. If you would like to deactivate your account, please follow the instructions in your account settings or email us at [email protected].
As noted in our Privacy Policy above, there may be cookies and other Tracking Technologies on our Service that may provide data, which may be treated as PI under the CCPA, to other parties that may use it for their own purposes, which in turn may provide that data to other parties for their own purposes. We do not believe that we sell PI collected by third-parties that operate their own cookies in association with our Services (“Cookie Operators”). Cookie Operators collect PI that falls under the other identifiers (e.g., cookie ID, IP address, and other online IDs) and internet or other electronic activity information categories. However, we will treat PI collected by Cookie Operators, where not limited to acting as our service provider, as a sale and subject to a Do Not Sell opt-out request. We offer a cookie management tool that enables you to exercise your Do Not Sell opt-out request and enable certain cookie preferences on your device here. You must exercise your preferences on each of our websites you visit and from each browser and on each device that you use. Since your opt-out is designated by a cookie, if you clear or block cookies, your preferences will not be effective and you will need to enable them again via our cookie management tool. For additional information on cookies and alternative choices regarding them, including how to opt-out of certain interest-based advertising, see the Cookies and Tracking Technologies sections of our Privacy Policy above.
We do not knowingly sell the PI of Consumers under 16, as the Service is not available to anyone who is not at least 18 years of age.
We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute Company as defined above, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale, retention and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.
You have the right to exercise your CCPA rights. You may submit a request to exercise your CCPA rights (1) as an individual; or (2) via an authorized agent who meets the agency requirements of the CCPA and related regulations.
As permitted by the CCPA, any request you submit to us must be a Verifiable Consumer Request. This means that your request is subject to an identification and residency verification process. We will not fulfill your Right to Know (Categories), Right to Know (Specific Pieces), or Right to Delete request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected Personal Information.
We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
In addition to the above, we verify each request as follows:
Authorized agents may exercise rights on behalf of California Consumers, but we reserve the right to also verify the Consumer’s identity directly as described above. Authorized agents must contact us to submit a request by emailing us at [email protected] or follow the instructions at our Consumer Rights Request page here and indicating that they are submitting a request as an agent. We will require the agent to demonstrate authority to act on behalf of the Consumer by providing, for example, evidence of the agent’s identity, proof of registration with the California Secretary of State (if the agent is a business), and at least one of the following evidencing proof of the agent’s legal authority to act on behalf of the individual Consumer:
We may also require the Consumer to verify their own identity directly with us and to directly confirm with us that they provided the authorized agent permission to submit the request.
In the absence of any of the general conditions detailed above, we are entitled to reject any request submitted through an agent. In addition, the agent is subject to the verification standards applicable to the type of request(s) made.
Notwithstanding anything to the contrary, we may collect, use, and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
Although we do not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us at [email protected] and register an e-mail contact address for us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. Contact us in the same manner to update your contact email for notices. Changing your email elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada notice contact information. It is your responsibility to keep your notice contact information current.
We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not treat your previously collected DL-Collected PII, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. If you have a subscription to a Service, material changes to the Privacy Policy will only become effective with respect to the aspect of that subscription Service at the end of the then current term unless you otherwise consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
If you have any questions about this Privacy Policy, please contact us at [email protected] or here.
30049 US-278, Nettleton, MS 38858