Privacy Policy
Last updated: March 28, 2024
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 of
our Service.
-
Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to
the Company as the legal entity that collects Consumers' personal information and
determines the purposes and means of the processing of Consumers' personal
information, or on behalf of which such information is collected and that alone,
or jointly with others, determines the purposes and means of the processing of
consumers' personal information, that does business in the State of California.
-
Company (referred to as either "the Company", "We",
"Us" or "Our" in this Agreement) refers to
MIS Strategies, LLC dba Merchants Information Solutions, P.O. Box 2070 Phoenix, AZ 85001-2070.
For the purpose of the GDPR, the Company is the Data Controller.
-
Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a
natural person who is a California resident. A resident, as defined in the law,
includes (1) every individual who is in the USA for other than a temporary or
transitory purpose, and (2) every individual who is domiciled in the USA who is
outside the USA for a temporary or transitory purpose.
-
Cookies are small files that are placed on Your computer, mobile device or any
other device by a website, containing the details of Your browsing history on that
website among its many uses.
-
Country refers to: United States
-
Data Controller, for the purposes of the GDPR (General Data Protection Regulation),
refers to the Company as the legal person which alone or jointly with others
determines the purposes and means of the processing of Personal Data.
-
Device means any device that can access the Service such as a computer, a
cellphone or a digital tablet.
-
Do Not Track (DNT) is a concept that has been promoted by US regulatory
authorities, in particular the U.S. Federal Trade Commission (FTC), for the
Internet industry to develop and implement a mechanism for allowing internet users
to control the tracking of their online activities across websites.
-
Personal Data is any information that relates to an identified or identifiable
individual.
-
For the purposes for 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, 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.
-
Sale, for the purpose of the CCPA (California Consumer Privacy Act), means 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 to another business or a third party for monetary
or other valuable consideration.
-
Service refers to the Website.
-
Service Provider means any natural or legal person who processes the data on behalf
of the Company. It refers to third-party companies or individuals employed by the
Company to facilitate the Service, to provide the Service on behalf of the Company,
to perform services related to the Service or to assist the Company in analyzing
how the Service is used. For the purpose of the GDPR, Service Providers are
considered Data Processors.
-
Third-party Social Media Service refers to any website or any social network
website 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 MIS Website, accessible from
centra.merchantsinfo.com
-
You means the individual accessing or using the Service, or the company, or other
legal entity on behalf of which such individual is accessing or using the Service,
as applicable.
Under GDPR (General Data Protection Regulation), 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
identifiable information that can be used to contact or identify You. Personally
identifiable information may include, but is not limited to:
-
Email address
-
First name and last name
-
Phone number
-
Address, State, Province, ZIP/Postal code, City
-
Bank account information in order to pay for products and/or services within the
Service
-
Usage Data
When You pay for a product and/or a service via bank transfer, We may ask You to
provide information to facilitate this transaction and to verify Your identity. Such
information may include, without limitation:
-
Date of birth
-
Passport or National ID card
-
Bank card statement
-
Other information linking You to an address
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.
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 Our Service. 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 our Service. Unless you have adjusted Your browser setting so that it will
refuse Cookies, our Service may use Cookies.
-
Flash Cookies. Certain features of our Service may use local stored objects (or
Flash Cookies) to collect and store information about Your preferences or Your
activity on our Service. Flash Cookies are not managed by the same browser settings
as those used for Browser Cookies. For more information on how You can delete
Flash Cookies, please read "Where can I change the settings for disabling, or
deleting local shared objects?" available at
https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
-
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. You can learn more
about cookies here:
https://www.termsfeed.com/blog/cookies/.
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. The
Personal Data You provide can give You access to different functionalities of the
Service that are available to You as a registered user.
-
For the performance of a contract: the development, compliance and undertaking of
the purchase contract for the products, items or services You have purchased or of
any other contract with Us through the Service.
-
To contact You: To contact You by email, telephone calls, SMS, or other equivalent
forms 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 or reasonable for their implementation.
-
To provide You with news, special offers and general information about other goods,
services and events which we offer that are similar to those that you have already
purchased 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 and
display content and advertising (and work with third-party vendors who do so)
tailored to Your interests 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 some or 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 among the assets transferred.
-
For other purposes: We may use Your information for other purposes, such as data
analysis, identifying usage trends, determining the effectiveness of our
promotional campaigns and to evaluate and improve our Service, products, services,
marketing and your experience.
We may share Your personal information in the following situations:
-
With Service Providers: We may share Your personal information with Service
Providers to monitor and analyze the use of our Service, to advertise on third
party websites to You after You visited our Service, for payment processing, to
contact You.
-
For business transfers: We may share or transfer Your personal information in
connection 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
we will require those affiliates to honor this Privacy Policy. Affiliates include
Our parent company and any other subsidiaries, joint venture partners or other
companies that We control or that are under common control with Us.
-
With business partners: We may share Your information with Our business partners
to offer You certain products, services or promotions.
-
With other users: when You share personal information or otherwise interact in the
public areas with other users, such information may be viewed by all users and may
be publicly 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 may see Your name, profile, pictures and description of Your
activity. Similarly, other users will be able to view descriptions of Your
activity, communicate with You and view Your profile.
-
With Your consent: We may disclose Your personal information for any other purpose
with 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.
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
is necessary to:
-
Comply with a legal obligation
-
Protect and defend the rights or property of the Company
-
Prevent or investigate possible wrongdoing 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.
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).
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.
PayPal
Their Privacy Policy can be viewed at
https://www.paypal.com/webapps/mpp/ua/privacy-full
Authorize.net
Their Privacy Policy can be viewed at
https://www.authorize.net/company/privacy/
When You use Our Service to pay a product and/or service via bank transfer, We may ask
You to provide information to facilitate this transaction and to verify Your identity.
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
Your activity 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 websites
or apps
-
Measure and analyze the performance of Our advertising campaigns
Some of these third-party vendors may use non-cookie technologies that may not be
impacted by browser settings that block cookies. Your browser may not permit You to
block such technologies. You can use the following third-party tools to decline the
collection and use of information for the purpose of serving You interest-based
advertising:
You may opt-out of all personalized advertising by enabling privacy features on Your
mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization
(Android). See Your 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 more
specific purposes.
-
Performance of a contract: Provision of Personal Data is necessary for the
performance of an agreement with You and/or for any pre-contractual obligations
thereof.
-
Legal obligations: Processing Personal Data is necessary for compliance with a
legal obligation to which the Company is subject.
-
Vital interests: Processing Personal Data is necessary in order to protect Your
vital interests or of another natural person.
-
Public interests: Processing Personal Data is related to a task that is carried out
in the public interest or in the exercise of official authority vested in the
Company.
-
Legitimate interests: Processing Personal Data is necessary for the purposes of the
legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that
applies to the processing, and in particular whether the provision of Personal Data is
a statutory or contractual requirement, or a requirement necessary to enter into a
contract.
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 Privacy
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. 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.
Under CCPA, personal information does not include:
-
Publicly available information from government records
-
Deidentified or aggregated consumer information
-
Information excluded from the CCPA'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 for Business Purposes or Commercial Purposes
We may use or disclose personal information We collect for "business
purposes" or "commercial purposes" (as defined under the CCPA), 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.
-
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.
Please note that the examples provided above are illustrative and not intended to be
exhaustive. For more details on how we use this information, please refer to the
"Use of Your Personal Data" section.
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 for Business Purposes or Commercial Purposes
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
Please note that the categories listed above are those defined in the CCPA. This does
not mean that all examples of that category of personal information were in fact
disclosed, 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 disclosed.
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.
Sale of Personal Information
As defined in the CCPA, "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.
Please note that the categories listed below are those defined in the CCPA. This does
not mean that all examples of that category of personal information were in fact sold,
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 shared for value in
return.
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
Share of Personal Information
We may share 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 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
The CCPA 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 request. Under CCPA, 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 purpose for collecting or selling that personal
information
-
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 a
business 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 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 contact Us.
-
The right to delete Personal Data. You have the right to request the deletion of
Your Personal Data, subject to certain exceptions. Once We receive and confirm Your
request, We will delete (and direct Our Service Providers to delete) Your personal
information from our records, unless an exception applies. We may deny Your
deletion request if retaining the information is necessary for Us or Our Service
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.
-
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 of
discounts 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 Data Protection Rights
In order to exercise any of Your rights under the CCPA, 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
We cannot respond to Your request or provide You with the required information if We
cannot:
-
Verify Your identity or authority to make the request
-
And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of
receiving Your verifiable request. The time period to provide the required information
may be extended once by an additional 45 days when reasonable necessary and with prior
notice.
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 useable and should allow You to transmit the information
from one entity to another entity without hindrance.
Do Not Sell My Personal Information
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 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
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
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 opt out will place a cookie on Your computer that is unique to the browser You use
to opt out. If you change browsers or delete the cookies saved by your browser, You
will need to opt out again.
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
You can also stop the collection of location information from Your mobile device by
changing the preferences on Your mobile device.
"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.
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.
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 allow 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.
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
or practices 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.
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:
