Last Updated: April 21, 2020
1. Scope of Policy.
This Policy applies to this Website as well as all webpages Company hosts. It regulates the processing of information relating to you and grants both of us various rights with respect to your personal information. It also informs you of how to notify us to stop using your personal information.
2. Types of Information We Collect and How We Use.
2.1. Personal information is information that can be used to identify you or any other individual to whom the information may relate. We collect personal information about you when you visit and use our Website, including when you subscribe to receive communications from us or contact us through the Website; when you open and/or click on email communications including advertisements and newsletters; and when you request to unsubscribe from receiving email advertisements, newsletters, or other communications from us. No sensitive health information is collected through the Website - we do not collect information about past, present or potential future medical conditions or treatments.
Information collected through the Website may include your first name; last name; email address; home address and zip code; date of birth; phone number; IP address; device identifier; probabilistic identifiers; education; employment status; employment history; gender; products or services purchased, obtained, considered, or other purchasing or consuming histories; personal and online interests; domain name; mobile and/or operating device identifier; computer operating system; web browser type and version; browser history; date/time stamp of your visit; source URL/referring and exit pages; clickstream data; internet service provider; mobile phone carrier; behavioral data (opens, clicks); user-specific and aggregate information on areas of the Website used; geographic region based on IP address and/or web browser type; time zone; and area code and zip code associated with your web server; inferences drawn from any of the above information; or other information which you provide to us during the registration process or though the course of communicating with us about the services provided on our Website or through other means of communication, such as responses, registrations, sweepstake entries, surveys, reviews, comments, confirmations, emails, postings, messages, telephone calls, written correspondence or other electronic submissions and communications sent by you to the Website. We may collect this same information about all other persons when you provide it to us.
We use the information we gather on our Website to provide you with the services and or products you have requested. This includes passing your information on to a third party to provide such services or products. We do not control the privacy practices of third parties. If you have any questions or wish to remove your information from the third party databases, you will need to contact that party directly. We use the information we gather to respond to any inquires you make, operate and improve the functionality of our Website, connect you with advertisers and sponsors on our Website and deliver the prizes if you participate in and win one of the sponsored sweepstakes.
We also use electronic images known as web beacons (sometimes called single-pixel gifs, clear gifs or action tags) which allow us to collect information about your visit to our Website, measure and improve the effectiveness of advertisements and track delivery of advertising. Web beacons collect only a limited set of information including a cookie number, time and date of page view, as well as a description of the page on which the web beacon resides. We may also use web beacons in email messages sent to you. This allows us to determine if you opened or acted upon the email messages. Because web beacons are the same as any other content request, you cannot opt out or refuse them. However, they can be rendered ineffective by either opting out of cookies or changing the cookie setup in your browser.
In addition to the above, we also collect personal information through internet service providers, data analytics providers, operating systems and platforms, and consumer data resellers/brokers.
2.3. No Information Collected from Children: we will never knowingly collect any Personal Information from children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that personal information will be immediately deleted from its database.
3. Disclosure of Information to Third Parties.
4. Third Party Collection and Use of Information.
Third parties collect and use information about you on or through our Website in the following way:
4.1. Advertisers, advertising agencies, advertising networks, and other companies who place ads on our Website, may use their own cookies, web beacons, and other technology, to collect information about you. We do not control the use of such technology and have no responsibility for the use of such technology to gather information about you. We have no access or control over the cookies and practices of those third parties and are not responsible for their technology or tracking. We have no responsibility or liability for the policies and practices of these third parties. We encourage you to review the policies of such third parties through their websites.
4.2. Hyperlinks. Our Website and email messages sometimes contain hypertext links to websites owned by third parties. We are not responsible for the privacy practices or the content of such third party websites. These links are provided for your convenience and reference only. We do not operate or control any information, software, products or services, available on these third party websites. The inclusion of a link on our Website does not imply any endorsement of the services, products or website, or its sponsoring organization. We have no responsibility or liability for the policies and practices of these third parties. We encourage you to review the policies of such third parties through their websites.
4.3. Analytics. As described above, we use third parties to monitor analyze and report on the traffic to, from and within our Website and email messages.
5. Individual Choice and Access.
If you do not wish to receive marketing and promotional communications from us, please follow the opt-out instructions provided in our communication or contact us. You may request access to personal information we have about you by contacting us as described below.
6. Storing and Processing Your Information.
We endeavor to safeguard and protect your information. When you submit information on our Website, such information is protected both online and offline. We have security measures in place to protect against the loss, misuse, and alteration of personal information under our control. The servers in which we store your information are kept in a secure physical environment. The servers have industry standard firewalls. Access to such servers is password protected and access by our employees is limited. Currently, we use Secure Socket Layer software (“SSL”) to protect data and to secure any transactions. SSL encrypts information including names and addresses, as they are transmitted over the Internet. Please be advised that, although we take commercially reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure; therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of data at or through our Website is at your own risk. However, access to your information is strictly limited and not accessible to the public.
8. Your California Rights.
8.1. California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared.
8.3. Under the California Consumer Privacy Act of 2018 (“CCPA”), up to twice in a twelve (12) month period, a consumer has the right to request that a business disclose what personal information it collects, uses, discloses, and sells. Information regarding our collection, disclosure, and sale practices are detailed below, in addition to instructions on how to exercise your rights regarding your personal information.
What Personal Information Do We Collect?
We collect, and have collected personal information about our visitors in the preceding 12 months as summarized below:
|Categories of Personal Information||Categories of Sources from Which Personal Information is Collected||Business or Commercial Purpose for Which Each Category Will be Used|
|Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers), or information that identifies, relates to, describes, or is capable of being associated with, a particular individual||Consumer through the Website; Internet service providers; Data analytics providers; Operating systems and platforms; and Consumer data brokers/resellers||Website access and interaction; Tracking Website access and interaction; Fulfillment of requests submitted through the Website; Personalize and improve the Website; Marketing; Internal database; Analyze the Website; Secure the Website; Customer service; and Legal compliance|
|Characteristics of protected classifications under California or federal law||Consumer through the Website; Internet service providers; Data analytics providers; Operating systems and platforms; and Consumer data brokers/resellers||Website access and interaction; Tracking Website access and interaction; Fulfillment of requests submitted through the Website; Personalize and improve the Website; Marketing; Internal database; Analyze the Website; Secure the Website; Customer service; and Legal compliance|
|Commercial information||Consumer through the Website; Internet service providers; Data analytics providers; Operating systems and platforms; and Consumer data brokers/resellers||Website access and interaction; Tracking Website access and interaction; Fulfillment of requests submitted through the Website; Personalize and improve the Website; Marketing; Internal database; Analyze the Website; Secure the Website; Customer service; and Legal compliance|
|Internet or other electronic network activity information|
|Professional or employment-related information|
|Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behavior, etc.|
What Personal Information Do We Disclose or Sell?
We have disclosed personal information for a business purpose, or sold personal information to third parties in the preceding 12 months in all of the above categories to our marketing partners, including offline marketing companies and internal online data marketing companies, for lead generation purposes and sending email communications. In addition, we may disclose any personal information where requested by governmental or quasi-governmental authorities conducting an investigation; in response to a subpoena, court order, or other legal process; to exercise our legal rights or defend against legal claims; to verify or enforce compliance with the policies governing our Website and applicable laws; to protect against misuse or unauthorized use of our Website; to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms and conditions, or as otherwise required by law, or limit our legal liability; to protect or defend our rights or property; or protect the safety, rights, or property of our users. We may also sell, transfer, or otherwise disclose personal information to a successor entity in connection with a corporate merger, consolidation, the sale of substantially all assets, or other corporate change.
We do not have any actual knowledge of the sale of personal information of minors under 16 years of age. There are no financial incentives to disclose.
Your Right to Request to Know and How to Submit a Verified Request to Know
A “request to know” is a request related to the personal information that a business has about such consumer. It may include a request for any or all of the following from us: 1) specific pieces of personal information that we have collected about you; 2) categories of personal information that we have collected about you; 3) categories of sources from which the personal information was collected; 4) categories of personal information that we have sold or disclosed for a business purpose about you; 5) categories of third parties to whom the personal information was sold or disclosed; and 6) the business or commercial purpose for collecting or selling personal information.
The CCPA permits requests to know from the same consumer up to twice in a twelve (12) month period.
To submit a request to know, please click here: Request to Know, or email your request to . To process your request, you may be required to submit your first name, last name, California address, email address, and phone number in conjunction with your request. The information which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for information, we may require the following before processing the request: 1) provide proof of your written and signed permission with the authorized agent to act on your behalf; 2) directly verify your own identity with us; and 3) directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information which you submit in conjunction with your request to know will be used for the express purposes of verification and providing you with responsive information to your request, if required.
Your Right to Request Deletion and How to Submit a Verified Request to Delete
You have the right to request the deletion of any personal information which we have collected about you, or which we maintain. To submit a verifiable request to delete, please click here: Verified Request to Delete, or email your request to . To process your request, you may be required to submit your first name, last name, California address, email address, and phone number in conjunction with your request. The information which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for deletion, we may require the following before processing the request: 1) provide proof of your written and signed permission with the authorized agent to act on your behalf; 2) directly verify your own identity with us; and 3) directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information which you submit in conjunction with your request to delete will be used for the express purposes of verification and fulfilling your request, if required.
We utilize a two-step process for online requests to delete, whereby you first submit your request to delete, and second, you separately confirm that you want your personal information deleted.
To the extent that your personal information is necessary for us to maintain for a reason delineated in Cal. Civ. Code § 1798.105(d), including but not limited to complete a transaction for which the personal information was collected, provide a good or service you have requested, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug, etc., or to comply with a legal obligation, we are not required to comply with your request for deletion. For instance, we are not required to delete personal information which is necessary to maintain suppression files for those individuals who have opted out of receiving email marketing from us. If we are unable to verify your request, we will notify you as well.
Your Right to Opt-Out of the Sale of Your Personal Information
California affords consumers with the right to opt-out of the sale of their personal information. To submit a request to opt-out of the sale of your personal information, you may complete the information requested in our webform /do-not-sell, or you may email us at .
To process your request, to opt-out, you may be required to submit your first name, last name, California address, email address, and phone number in conjunction with your request. The information which you provide will be used to verify your request and to attempt to identify you within our data records. You may exercise your right to opt-out through an authorized agent. If you elect to use an authorized agent to exercise your right to opt-out of the sale of your personal information, we may require the following before processing the request: 1) provide proof of your written and signed permission with the authorized agent to act on your behalf; 2) directly verify your own identity with us; and 3) directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information which you submit in conjunction with your opt-out request will be used for the express purposes of verification and complying with your opt-out request.
Your Right to Non-Discrimination for the Exercise of Your Privacy Rights
California affords consumers with the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA. This means that you cannot be denied goods or services; be charged different prices or rates; be provided with a different level or quality of goods or services; or have it suggested that you will receive a different price or rate or different level or quality of goods or services. However, a business may offer a financial incentive or price or service difference if it is reasonably related to the value of the consumer’s data. A business shall notify consumers of any financial incentive or price or service difference.
10. Contact Us
If you have a disability which interferes with your ability to access this policy, we can make accommodations to present the policy in an alternative format to assist you. If you would like to receive this information in another format that is accessible to your needs (for example, audio, large print, etc.), please contact us.