Privacy Policy
Last Updated: August 14, 2023
Artisan Design Group and/or its subsidiaries (collectively “ADG”, “we”, “us”, or “our”) takes data privacy and security seriously. This Privacy Policy (“Privacy Policy”) describes how we collect, use, share, and/or disclose personal information that we collect from individuals who visit our Sites, use our Services, or otherwise engage with us as described below (such individuals are collectively referred as “User”, “you”, or “your”).
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR PERSONAL INFORMATION. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU SHOULD NOT USE OUR SITES, SERVICES, OR OTHERWISE INTERACT WITH US. BY ACCESSING, VISITING, BROWSING, OR USING OUR SITES, REGISTERING OR SUBMITTING YOUR INFORMATION THROUGH OUR SERVICES, OR INTERACTING WITH US, YOU AGREE TO THE PRACTICES, TERMS, AND CONDITIONS DESCRIBED IN THIS PRIVACY POLICY. THIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME. YOUR CONTINUED USE OF YOUR SITES AFTER WE MAKE CHANGES IS DEEMED ACCEPTANCE OF THOSE CHANGES, SO PLEASE CHECK THE PRIVACY POLICY PERIODICALLY FOR UPDATES.
THE SITES ARE INTENDED FOR USERS LOCATED IN THE UNITED STATES AND ARE NOT INTENDED FOR USERS LOCATED IN ANY OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA.
THE SITES ARE NOT INTENDED FOR USE BY MINORS. ACCORDINGLY, WE DO NOT REQUEST ANY PERSONAL INFORMATION FROM MINORS, AND MINORS ARE NOT ALLOWED TO MAKE PURCHASES OR APPLY FOR JOBS ON THE SITES. MINORS SHOULD NOT POST ANY PERSONAL INFORMATION TO THE SITES.
1. Introduction and Scope
When we refer to “Personal Information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with you, directly or indirectly.
When we refer to “Sites” in this Privacy Policy, we mean our websites, mobile applications, platforms, or other online solutions, software applications, media, features, subdomains, content, and/or functionality made available by us containing a link to this Privacy Policy.
When we refer to “Services” in this Privacy Policy, we mean the products available on or through the Sites and any other services available via the Sites.
This Privacy Policy also governs how we may collect, use, store, and disclose Personal Information that we obtain through or from general interactions with you, including, when you request information or make general inquiries to us, interact with us via business-to-business contacts, request or receive our marketing information, or engage with us through our social media pages.
We may de-identify, aggregate, and/or anonymize your Personal Information by excluding and removing data components (such as your name, email address, or linkable tracking ID) through obfuscation, or through other means so that the resulting data set is no longer personally identifiable to you (such resulting data set is known as “Aggregated Data”). Our use of Aggregated Data is not subject to this Privacy Policy. This Privacy Policy does not cover information collected by any third party or information collected by us that does not link to this Privacy Policy.
2. Information We May Collect
The Personal Information we collect depends upon things such as the nature of our relationship, the method you communicate with us, and the purpose of your interaction with us. We may collect the following Personal Information directly from you, from third-party sources, and automatically as you use our Sites and Services:
- Contact Information: Such as your name, email address, mailing address, telephone number, professional title, and/or business name
- Registration Information: Such as your username, email address, and/or password to login to an online account with us.
- Government Issued Identifiers: Such as your Social Security number, tax identification number, driver’s license number, or other identification numbers issued by government bodies or agencies.
- Financial Information: Such as your bank account numbers, credit card numbers, details of transactions you effectuate, and creditworthiness.
- Communications Data: Such as information you provide through our online web forms when you contact us with questions, feedback, surveys, engage with us for customer support or customer service related requests, or otherwise choose to provide to us when you correspond with us online.
- Usage Data: Such as information about how you use our Sites and interact with us, including information you provide when you use any interactive features of the Sites or our services, the URL that referred to you our Sites, the areas within our Sites that you viewed and your activities there, domain name, a date/time stamp, Internet service provider (ISP), operating system, IP address, clickstream data, and similar device and usage information.
- Device Information: Such as information that is automatically assigned to your devices used to access our Sites, including IP address, unique device identifier, device type, browser type, location information, and other information about your browser.
- Social Media Information: Such as your name, username, or other profile information in connection with your social media account that we may collect if you connect with us through a third-party social media network or other websites, such as Facebook, Instagram, Twitter, or LinkedIn.
- Other information that you voluntarily share with us to facilitate your use of our Sites and Services which is not specifically listed here. We will use such data in accordance with this Privacy Policy, as otherwise disclosed at the time of collection, in accordance with our agreement, or to the extent necessary for performing the services.
We may also collect information about you from additional online and offline sources, including our affiliates, credit reporting agencies, and other third-party sources as permitted by law.
The entry of Personal Information is required to access certain portions of our Sites and Services. You may choose not to provide us with any Personal Information and may still access certain portions of our Sites. However, you may not be able to fully utilize all functionalities and features of our Sites and services if certain categories of personal information are required in order for us to deliver those functionalities.
3. How We May Use Your Information
To the extent permitted by applicable law, we may use information that we collect about you or that you provide to us, including any Personal Information for the following purposes:
- Operate and improve our operations, business, services, and the Sites;
- Provide you with Services, products, content, customer service, and functionality;
- Honor our terms of service and contracts;
- Manage our relationship with you and to manage your account;
- Process and complete transactions;
- Improve our products and services and develop new products and services;
- Maintain our databases and back-ups, including records of our communications with you;
- Ensure the privacy and security of our Site, and services;
- Detect fraud and prevent loss;
- Support and improve the Sites, including evaluations of functionality and features;
- Improve our customer service;
- Communicate with you, including by email, telephone, SMS, or equivalent forms of electronic communication, and to respond to your feedback, requests, questions, or inquiries;
- Promote our products and services;
- Market our services and products to you, including by providing more tailored advertising (we will only provide you with marketing-related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time);
- Assess the success of marketing campaigns;
- Analyze use of the Sites, and our services and prepare aggregate traffic information;
- Recognize your device and remember your preferences and interactions;
- Provide you with a more personal and interactive experience on and the Sites;
- Determine and track user interests, trends, needs, and preferences;
- Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transfers;
- Obtain and maintain insurance coverage, manage risks, and obtain professional advice;
- Accomplish any other purpose related to and/or ancillary to any of the purposes and uses described in this Privacy Policy for which your information was provided to us;
- Accomplish another purpose described to you when you provide the information, for which you have consented, or for which we have a legal basis under law;
- Comply with federal, state, or local laws;
- Comply with a civil, governmental, or regulatory inquiry, order, subpoena, summons or process;
- Cooperate with law enforcement agencies;
- Exercise or defend legal rights or claims;
- Create, use, retain, or disclose de-identified or Aggregated Data; and
- As otherwise set forth in this Privacy Policy, to fulfill the purpose or reason you provided the information, and/or with your consent such as when required by law.
If we need to use your Personal Information for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.
We do not use Personal Information for making any automated decisions affecting or creating profiles other than as described herein.
Marketing Communication Preferences: We process your Personal Information to contact you with information regarding Services that may be of interest to you. You can ask us to stop sending you marketing messages at any time by following the update email preferences or unsubscribe links on any marketing message sent to you or by contacting us at any time using the contact details in the Contact Us section. Please note that we may still find it necessary to communicate with you regarding your use of the Sites.
4. How We May Disclose Your Information
When permitted by applicable law, including in cases that require your consent, we may disclose Personal Information that we collect or you provide as described in this Privacy Policy to our affiliates, business partners, service providers, and others, as follows:
- Corporate Affiliates, which include, our subsidiaries, divisions, affiliates, and holding companies for various purposes permitted by law, including the advertising and marketing of their products and services to you.
- Service Providers, which include contractors, service providers and other third parties we use to support our business and deliver products or services to you, and/or who perform functions on our behalf such as customer service, data analysis, servicing accounts, marketing, and/or development of our products and services, and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
- Acquisitions or Similar Transactions, which include to a buyer or other successor in the event of 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 information held by us is among the assets transferred.
- With Your Consent or at Your Direction, which includes to third parties to market their products or services to you if you have consented to these disclosures or where you have consented to the disclosure of your information to other unaffiliated third parties who are not described elsewhere in this Privacy Policy.
- In Response to Legal Process or Defending Legal Claims, which includes, as required by law, court orders, subpoena, or other legal process or if we reasonably believe such action is necessary to comply with the law and the reasonable requests of regulators, law enforcement, or other public authorities or quasi-government authorities, including fraud detection agencies. We may also disclose the information to establish, protect, or exercise our legal rights, to enforce our terms and conditions or other legal agreements, to defend against a legal claim, to detect, investigate, prevent, or take action against illegal activities or potential threats to the rights, property, or safety of any other person, or as required by law.
- Professional Advisors, which includes our attorneys, accountants, tax advisors, investment advisors, and other fiduciaries or consultants that need access to your information to provide operational or other support on your behalf.
- De-Identified or Aggregated Data. We may disclose anonymous, de-identified, or Aggregated Data about our users that does not identify any specific individual, such as groupings of demographic data or customer preferences.
5. Data Retention
We retain and use your Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, to pursue legitimate business purposes, to enforce our agreements, and other business or commercial purposes to the extent provided in this Privacy Policy.
We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, or (3) if you ask us to delete your personal information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete your personal information, it will be removed from our active servers and databases; but it may remain in our archives when it is not practical or possible to delete it.
6. Data Security
We recognize the importance of safeguarding your Personal Information. We endeavor to maintain reasonable and appropriate physical, technical, and organizational safeguards designed to protect your Personal Information from accidental loss and unauthorized access, use, alteration, or disclosure. From time to time, we review our security procedures to consider appropriate new technologies and methods. We use reasonable security measures when transmitting Personal Information to customers in responding to requests under applicable data protection or privacy laws.
While our security measures seek to protect the Personal Information in our possession, no security system is perfect, and no data transmission is 100% secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to or from our Sites. The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of our Sites or our Services, you are reasonable for keeping your password confidential. Do not share your password with anyone. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.
7. Cookies and Similar Technologies
Cookies
A “cookie” is a small file that is accessible within a folder on a computer and it is used for record-keeping purposes. “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website. You can block and control cookies using the information noted below. If you block all cookies, certain functionalities on our Sites or services may not work.
What Cookies and Similar Technologies Are in Use and Why Do We Use Them?
- Essential Cookies: Essential cookies and other similar technologies used by us enable you to navigate our Sites and use our Services and their features. Without these essential cookies, the Sites will not perform correctly, and we may not be able to provide the Sites to you or provide you with certain services or features of our Sites.
- Functionality/Preference Cookies: Functionality cookies (or preference cookies) and other similar technologies allow our services to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of our services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
- Performance Cookies: These cookies and other similar technologies collect information about how you use our services, including which pages you go to most often and if they receive error messages from certain pages. These include cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited. These cookies are only used to improve the functions of our Sites and how they perform.
- Advertising Cookies: Advertising cookies and other similar technologies are used by us to display promotions or advertisements based on your use of the Sites and interests and to manage our use of advertising resources. These cookies collect information about your activities on our Sites to provide you with interest-based advertising. WE may also allow our third-party business partners to use targeting and or advertising cookies on our Sites for similar purposes, including collecting information about your online activities over time and across different websites. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt-out of receiving targeted ads from members of the National Advertising Initiative (“NAI”) on its website (www.networkadvertising.org).
Other Similar Technologies
In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.), HTML Local Storage, Social Widgets, or UTM Codes that can be used to collect data as users navigate through and interact with a website.
- Web Beacons: Web beacons, also known as pixel tags or clear GIFs, are small strings of code that enable delivery of a graphic image on a webpage for the purpose of transferring data, such as the IP (Internet Protocol) address of the computer that downloaded the page on which the Web beacon appears, the URL (Uniform Resource Locator) of the page on which the Web beacon appears, the time the page containing the Web beacon was viewed, the types of browser that fetched the Web beacon and the identification number of any cookie on the computer previously placed by that server. Web beacons and similar technologies let us know whether you accessed or opened our email or that certain content was viewed or clicked.
- Tracking Pixels: A tracking pixel is a small piece of code we may use to collect and share information on your usage of our website, such as the pages that you have visited, or the way you have interacted with them. Through the tracking pixels, your browser automatically establishes a connection with the server of an online advertiser. In this way, the online advertiser receives information that you access our Sites. This can allow us to ensure that we are serving ads that match your interests, when you are visiting any of the websites of the online advertiser, or a website that includes ads served by the online advertiser. If you are authenticated to an online advertiser using tracking pixels, e.g. by being registered and logged in to a social network, the online advertiser can assign the visit to our website to your account. The data we may collect through tracking pixels is anonymous and does not include any personal information of individual users. We have no influence on the extent to which the data collected through the tracking pixels is used by the online advertisers and therefore direct you to their privacy notices.
- Social Widgets: These are buttons or icons provided by third-party social media platforms that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.
- UTM Codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the http or https address entered to go to a webpage) when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.
Particular third-party cookies or tracking technologies used on our Sites include, but are not limited to:
- Google Analytics: We may use Google Analytics to collect and process data about the number of people using the Sites and to better understand how they find and use the Sites. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions on the Sites. The information stored is reduced to a random identifier. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting:
https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245
You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en).
- Facebook Pixel. We use Facebook Pixel to customize and display advertisements only to Facebook users who have shown an interest in our Sites or who have specific characteristics (e.g., certain demographics or interests in certain topics or products determined by websites visited) that we submit to Facebook. The use of Facebook Pixel helps ensure that our advertisements are in line with the potential interests of users and do not have a nuisance effect. Facebook Pixel also allows us to track the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether uses have been redirected to our Sites after clicking on a Facebook advertisement. The Facebook Pixel is directly integrated into our Website by Facebook and can store a cookie on your device. The information collected about you is anonymous for us. However, the information collected via the Facebook Pixel, on the Sites as well as other websites on which Facebook Pixel is installed, is also stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy.
We do not control these third parties’ technologies or website or how they may use your personal data once you are referred to these third-party websites. If you have any questions, you should contact the responsible party directly or consult their privacy policies.
Choices About Cookies
Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Sites.
If you decline the use of cookies, you may not have access to the full benefits of the Services. Further, your opt-out only applies to the web browser you use, so you must opt out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again. In addition, adjusting the cookie settings on the services may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings on the services.
Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers (PLEASE NOTE: these third party links are provide for your convenience, and we may not actively monitor the content of these links):
For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/.
8. Your Choices to Control Your Information
Please use the “Contact Us” details provided at the end of this Privacy Policy to exercise your rights and choices under this Privacy Policy. We honor such requests when we are required to do so under applicable law.
Email Opt-Out: If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails. Please note that registered users on the Sites cannot opt-out of receiving transaction emails related to their account.
Online Tracking Signals: We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the settings in this Privacy Policy
Accuracy and Updating Your Information: Our goal is to keep your information accurate, current, and complete. You may send us an e-mail via the “Contact Us” details at the end of this Privacy Policy to correct or update any Personal Information that you have provided to us. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate Personal Information about you, you may want to update your information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We are not responsible for any losses arising from inaccurate, inauthentic, deficient, or incomplete personal data that you provide to us.
9. Links to Third-Party Websites
This Privacy Policy does not apply to any third-party websites or applications.
Our Sites may contain links to websites or mobile applications operated and maintained by third parties. These links are to external websites and third parties that have their own privacy policies. If you follow any links that direct you away from the Sites or services, including links to social media sites or to other websites, this Privacy Policy will not apply to your activity on the other sites you visit. Because of the dynamic media capabilities of the Sites, it may not be clear to you which links are to the Platform and which are to external, third party websites. If you click on an embedded third-party link, you will be redirected away from the Sites to the external third-party website. You can check the URL to confirm that you have left the Sites.
We cannot (i) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (ii) control the privacy policies or the privacy practices of any third parties regarding their independent collection or use or your personal information, or (iii) endorse any third-party information, products, services or websites that may be reached through embedded links on the Sites.
Any Personal Information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.
10. Children’s Privacy
Our Sites are not intended for children under 13 years of age. No one under age 13 may provide any Personal Information to or on the Sites. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on our Sites or on or through any of its features/register on the Sites, make any purchases through the Sites, use any of the interactive or public comment features of the Sitesor provide any information about yourself to us. If we learn that we have collected Personal Information from any person under the age of 13 without verification of parental or guardian consent, we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 years of age and believe your child has provided us with Personal Information, please contact us via the instructions at the “Contact Us” section below.
11. Updates to this Privacy Policy
We reserve the right to add to, change, update, or modify this Privacy Policy at any time to reflect any changes to how we treat your information or in response to changes in law. In the event we make changes to this Privacy Policy, such policy will be re-posted on this page. If we make material changes to how we treat your Personal information, we may notify you by e-mail to the e-mail address specified in your account and/or through a notice on the home page of our Sites. The date the Privacy Policy was last revised is identified at the top of the page. All changes are effective on the date listed at the top of this page and will apply to all information we have about you.
You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Sites and this Privacy Policy to check for any changes. Your continued use of the Sites and our services after the “Last Updated” date indicates your acceptance of the changes and your continued consent to our processing of your personal information according to the terms of the then-current Privacy Policy. If at any point you do not agree to any portion of this Privacy Policy, then you should immediately stop using the Sites and the services.
12. Contact Us
For more information, or if you have any questions or comments about this Privacy Policy and our privacy practices, you may contact us using the information below.
In Writing: Artisan Design Group
3401 Olympus Blvd., Ste. 450
Dallas, TX 75019
By Email: info@adgus.net
13. California Residents
The following supplements the information contained in the Privacy Policy, applies solely to all natural persons residing in the State of California (“consumers”), and is intended to comply with our obligations under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights of 2020, and its implementing regulations (collectively referred to as the “CCPA”). Any terms defined in the CCPA shall have the same meaning when used herein.
Notice at Collection
We collect the following categories of Personal Information from California consumers:
| Category | Description |
| Identifiers | Examples: 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. Sold or Shared? We do not sell or share this category of personal information. |
| Personal information described in 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, or medical information. Sold or Shared? We do not sell or share this category of personal information. |
| 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, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status. Sold or Shared? We do not sell or share this category of personal information. |
| Commercial Information | Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Sold or Shared? We do not sell or share this category of personal information. |
| 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. Sold or Shared? We do not sell or share this category of personal information. |
| Internet or other similar network activity | Examples: Browsing history, search history, information regarding a consumer’s interaction with an internet website application, or advertisement. Sold or Shared? We do not sell or share this category of personal information. |
| Geolocation data | Examples: Physical location or movements. Sold or Shared? We do not sell or share this category of personal information. |
| Sensory data | Examples: Audio, electronic, visual, or similar information. Sold or Shared? We do not sell or share this category of personal information. |
| Professional or employment-related information | Examples: Current or past job history or performance evaluations. Sold or Shared? We do not sell or share this category of personal information. |
| 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 identification codes, or student financial information. Sold or Shared? We do not sell or share this category of personal information. |
| Inferences drawn from other personal information | Examples: Inferences drawn from any of the information identified in this list to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Sold or Shared? We do not sell or share this category of personal information. |
| Sensitive Personal Information | Examples: Social Security number, driver’s license number, state identification number, passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation information, racial or ethnic origin, religious, or philosophical believes, or union membership, contents of mail, email, and text messages unless the business is the intended recipient of the communication, genetic data, biometric data for the purposes of uniquely identifying a consumer, health information, sex life or sexual orientation information. Sold or Shared? We do not sell or share this category of personal information. **We only collect Sensitive Personal Information for legitimate business purposes appropriate for the use and disclosure of Sensitive Personal Information as defined in the California Privacy Laws, and do not otherwise use it to infer characteristics about you. |
Exclusions from Personal Information: Personal information does not include:
- Publicly available information or lawfully obtained, truthful information that is a matter of public concern.
- Consumer information that is deidentified or aggregated.
- Information excluded from the scope of the CPRA including, but not limited to:
- Personal information collected, processed, sold, or disclosed subject to the Gramm-Leach-Bliley Act (GLBA) or the California Financial Privacy Act.
- An activity involving the collection, maintenance, disclosure, sale, communication, or use of any personal information bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a consumer reporting agency, a furnisher of information who provides information for use in a consumer report, and by a user of a consumer report provided that the agency, furnisher, or user is subject to regulation under the Fair Credit Reporting Act (FCRA).
- Medical information governed by the Confidentiality of Medical Information Act or protected health information as governed by the U.S. Department of Health and Human Services pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
- Personal information collected, processed, sold, or disclosed pursuant to the Driver’s Privacy Protection Act of 1994.
Categories of Sources
We have collected the Personal Information in this Privacy Poliyc form you directly when you provide it to us, automatically as you navigate through our Sites, and from our business partners, as applicable.
Business and Commercial Purposes for Collecting
We have collected the categories of Personal Information listed above for the purposes identified in the “How We May Use Your Information” in Section 3 of this Privacy Policy.
Categories of Personal Information Disclosed for a Business Purpose
We have disclosed the following categories of personal information to third parties for a business purpose during the preceding 12 months:
- Identifiers.
- Personal information described in Cal. Civ. Code § 1798.80(e).
- Protected classification characteristics under California or federal law.
- Commercial Information.
- Biometric Information.
- Internet or other similar network activity.
- Geolocation data.
- Sensory data.
- Professional or employment-related information.
- Non-public education information (per the Family Education Rights and Privacy Act).
- Inferences.
- Sensitive Personal Information
These categories of personal information have been disclosed for a business purpose to the following categories of third parties:
- Service providers or contractors (for services such as data analytics, data storage, mailing, marketing and advertising, payment processing, website and platform administration, technical support, security monitoring, and operating systems and platforms).
- Third parties with your consent
- Investors.
- Government entities.
- Marketing providers.
Prior to disclosing any personal information to a service provider or contractor for a business purpose, we enter into a written contract which describes, among other things: (1) the specific purpose which the personal information can be used by the service provider or contractor to perform the services specified in the contract; (2) requires the service provider or contractor to keep any personal information confidential; (3) prohibits the service provider or contractor receiving the personal information from retaining, disclosing, or using the personal information for any purpose other than performing and providing services under the contract; (4) provides us the right to take reasonable and appropriate steps to ensure that the service provider or contractor uses personal information in accordance with contractual terms.
Categories of Personal Information Sold or Shared to Third Parties
We have not sold or shared any categories of personal information to third parties in the preceding 12 months.
California Consumer Rights and Choices
The CCPA provides consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights. You may submit requests to us as described below and we honor those rights where they apply.
Right to Know: You have the right to request that we disclose Personal Information that it has collected, sold, or shared about you. This includes a request for any or all of the following:
- The categories of personal information we have collected about you.
- The categories of sources from which the personal information is collected.
- The categories of personal information that we have sold or disclosed for a business purpose about you.
- The categories of third parties to whom the personal information was sold or disclosed for a business purpose.
- The specific pieces of personal information we collected about you.
- The business or commercial purpose for collecting, selling, or sharing personal information.
Right to Delete: You have the right to request that we delete any Personal Information that we have collected, sold, or shared about you.
Right to Limit: In certain circumstances, you have the right to limit the use and disclosure of sensitive personal information. Our use of your sensitive personal information is solely for business purposes and not for those purposes for which a consumer may exercise a right to limit the use or disclosure under the CCPA. Therefore, we include this disclosure of information for information purposes only.
Right to Opt-Out of Sale/Sharing: You have the right to direct a business that sells or shares personal information about you to third parties to stop doing so. We do not sell or share any personal information as defined by the CPRA. Therefore, we include this disclosure of information for informational purposes only.
Right to Correct: You have the right to request that we correct inaccurate Personal Information that we maintain about you. Our goal is to keep your personal information accurate, current, and complete.
How to Submit Requests to Know, Requests to Delete, and Requests to Correct
You may submit a request a Request to know, Request to Delete, or Request to Correct by either:
- Calling us at [TOLL-FREE TELEPHONE NUMBER]
- Emailing [EMAIL ADDRESS]
Verification Procedures
We are required by the CCPA to verify the identity of individuals who submit a Request to Know, Request to Delete, or Request to Correct. We will take steps to verify your identity before granting you access to such personal information or acting on your request to exercise your rights as outlined below.
A verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected information. Whenever feasible, we will verify your identity by matching the identifying information provided by you in the request to the personal information we may already maintain about you. As part of this process, we ask that you provide the following information when submitting your request: name, telephone number, and email address.
You may designate an authorized agent to make a Request to Know, Request to Delete, or Request to Correct on your behalf. If you use an authorized agent to submit a request, we require the authorized agent to provide proof that the consumer gave the authorized agent signed, written permission to submit the request. We may also require you to verify your identity directly with us and you to directly confirm with us that you provided the authorized agent permission to submit the request. We will inform you if we cannot verify your identity.
- If we cannot verify the identity of the person making a Request to Know specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer. If we still cannot verify the request, and the request is denied in whole or in part, we will provide a copy of, or direct you to, our Privacy Policy.
- If we cannot verify the identity of the person making a Request to Delete or Request to Correct, we may deny the request and inform the person making the request that their identity cannot be verified.
Response Timing: Upon receiving a Request to Know, Request to Delete, or Request to Correct, we will confirm receipt of the request within 10 business days and provide information about how we will process your request. The information provided will include our verification process and when you should expect a response from us (unless we have already granted or denied the request). In general, we will respond to a request within 45 calendar days from the day the request is received but, if necessary, we may take an additional 45 calendar days to respond to the request. If this extension is needed, we will notify you of the extension and explain the reasons that responding to your request will take more than 45 calendar days.
Response Process: If you have an online account with us, we may deliver our written response to that account along with any requested personal information that may be responsive to your request in a portable and, to the extent technically feasible, readily usable format. If you do not have an account with us, we will deliver our written response and any requested personal information that may be responsive to you by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Limitations: We are committed to responding to requests in accordance with applicable law. However, your rights are subject to certain limitations including, but not limited to, the following:
- We are only required to respond to Requests to Know twice in a 12-month period.
- A response to a Request to Know may be limited to the 12-month period preceding receipt of the request if it would be impossible, involve disproportionate effort, or the request is for data for a specific time period.
- We are prohibited from disclosing certain specific pieces of personal information in response to a Request to Know including, but not limited to, Social Security numbers, driver’s license numbers, and financial account numbers.
We will not discriminate against you for exercising any of your CPRA rights including, but not limited to, by:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.