Date Posted: February 8, 2023
- INFORMATION COLLECTION.
We collect the following categories of information about you when you visit and use our Website or participate in our Surveys or other promotions:
(a) Personal Information. This is information collected which can identify you. This includes your name and email address, employment status or other unique information you provide to us during your participation in online surveys, signing up for our emails, or through the course of communicating with us for any reason.
(b) Demographic Information. This includes your zip code, mobile phone carrier, age, gender, salary range, education, marital status, occupation, military service, industry of employment, personal and online interests. If you can be personally identified through this information, it is Personal Information.
(c) Our Website Tracking. We may track and record your movement through our Website including the pages, articles, and ads you visit on our website, what services or products you access or order, information about your computer hardware and software, including your IP address, general geographic location of the computer or device you are using, browser preference, operating system other websites you visit. When we can identify you personally, through the use of this information, it is Personal Information.
(d) Third-Party Information. We may collect personal and non-personal information about you from a third-party which may include personal, demographic, and technology information. This includes, information found in cookies or persistent identifiers, and email opt-in records. We may not have access or control over these cookies and other tracking devices as they are owned and used by unaffiliated parties including advertisers, networks, ISPs, analytics consultants, or social media networks. We have no responsibility or liability for the policies and practices of these parties.
(e) Technology Information. We automatically collect you IP address, browser type, internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and/or clickstream data from cookies, web beacons or other technology.
(f) No Information Collected from Children. We will never knowingly collect any Personal Information from anyone under the age of 16. If we accidently do collect such information, we delete the same upon notice.
- TECHNOLOGY INFORMATION COLLECTION.
(a) Generally. We, our vendors, networks, ISP(s) and supporting advertisers use technologies such as cookies, web beacons, and java scripts to collect information about you. Using these technologies, we collect your IP addresses, browser type, ISP, referring/exit pages, operating system, date/time stamp, and/or clickstream data. We use this to analyze trends, monitor and update our Website, ease of movements through our Website and gather demographic information about our user base, as a whole, to attract advertising on our Website. We may create reports or logs based on these technologies on an individual or aggregated basis. California residents should be advised we do not respond to do not track signals or cookies.
(b) Cookies. If enabled, cookies store small amounts of information on your computer about actions you take on our Website. This helps us track which of our features you visit most often, and what content you view and keep track of the number of return visits. We accumulate and aggregate statistical information generally pertaining to our Website, to market our website and deliver specific content to you based on your past viewing history. You can modify or disable cookies, but our Website may not function properly for you. You may read more about cookies at http://cookiecentral.com/faq/.
(d) Web Beacons. We use web beacons 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 message. 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.
- USE OF INFORMATION.
(a) We use the information to provide you with the services and/or products you have requested. We may share your information with a third-party to provide such services or products. We do not control the privacy practices of third-parties. Please contact the third-party with any questions about their privacy practices.
(b) We use the information to respond to any questions you have, operate, and improve the functionality of our Website. We use the information for testing, research, analysis and product or marketing development. Our services include the display of personalized products, content, and advertising, relating to your experience and interests. This includes maintaining and improving the safety, security and integrity of our Website, databases, and technology assets.
(c) We use the information to promote our and third-party campaigns, products, and services to you that might be of interest to you.
(d) We also use the information to respond to your questions concerns or requests.
(d) Third-parties will use the information when we share, lease, or sell it to provide you with their services and products.
- SHARING AND SALE OF INFORMATION.
(a) Generally. All information, including the personal information (including your name and email), may be leased, licensed, shared, disclosed, or sold to third-parties including to our affiliates, service providers, vendors, advertisers, or other third-parties for third-party marketing. This may result in unsolicited email messages to you about those third-party products and services.
(b) Website Functionality. We share all categories of information set out in this policy with third-party Service Providers we employ to perform technical or analytical functions on our behalf. Examples include third-parties who host our Website, analyze our data, provide marketing assistance, and provide customer service.
(d) Anonymized information. We share aggregated anonymous information about you, combined with Service Providers and other third-party vendors and clients for their analysis, promotion, and marketing. This includes demographic information and behavioral information.
(e) Legal Process. We disclose your information, if legally required to do so, or at our discretion, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect our rights or property, or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
(f) Acquisition or Merger. We may disclose and transfer your information to a third-party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of, such information in a transaction approved by the court.
- THIRD-PARTY COLLECTION AND USE OF INFORMATION.
(b) Links. For your convenience, 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 other websites. 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.
(c) Analytics. As described above, we use Service Providers to monitor, analyze and report on the traffic to, from and within our Website and email messages.
- DISCLAIMER OF THIRD-PARTY COLLECTION AND USE.
Our Website offers links to third-party owned and operated websites, including links embedded in advertisements and links to various news sources not under our control. These third-party websites may have information policies and practices different from ours. In addition, certain companies associated with our Website have their own privacy policies. We do not own or control such companies and websites and are not responsible for the privacy policies or practices or the content of websites.
- STORAGE AND SECURITY OF INFORMATION.
We use reasonable industry-accepted technology and controls to protect your information and data from disclosure to unauthorized third-parties. This includes firewalls, secured facilities, and logged and limited access. Although mostly effective to prevent disclosure, no guarantee can be given that all information you provide to us will not be accessed by unauthorized persons. Thus, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Any transmission of data to use or through our Website is at your own risk.
- CALIFORNIA CCPA AND CPRA NOTICE.
Effective Date: January 1, 2023
(a) Information We Collect. As set forth in our primary policy, we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- 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”), clinical trial data or other qualifying research data; and
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.
We have collected the following categories of personal information within the last 12 months as defined in the CCPA:
- Identifiers. First and Last Name, postal address, unique personal identifier, online identifier, internet protocol address, email address.
- Personal Information. First and Last Name, address, telephone number, credit card or debit card, when purchases are made.
- Commercial Information. Records of products or services purchased, obtained, or considered and history or tendencies toward products and services or response to advertising.
- Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation data. Through collection of your IP, we collect your general location, upon requesting services, or product we collect your physical address.
- Inferences drawn from other personal information. From information we collect as set forth herein and information provided by third-parties, we are able to profile a general understanding of your preferences, characteristics, and personal preferences to determine what ads or products or services you may be interested in receiving.
- Highly Sensitive Information. Certain of the categories listed above represent “Highly Sensitive Information” as this term is defined in the CPRA. We do not collect, use, share, or store Highly Sensitive Information except for purposes of performing our services, providing our products, or for purposes as requested by you. We may collect Highly Sensitive Information such as credit card or financial information for purposes of a transaction involving our products or services. We do not share Highly Sensitive Information with third-parties unless they are necessary to assist us in performing the services or provide the products or otherwise as requested by you. We do not sell Highly Sensitive Information to any third-parties.
(b) Retention Periods for Highly Sensitive Information. Pursuant to the requirements of the CPRA, we retain personal information and Highly Sensitive Information only as long as it is reasonably necessary to do so in accordance with the provisions of the CPRA and our internal policies. You may request deletion of such information in accordance with the provisions of this Notice in the manner set forth below. We are required by certain applicable laws to retain certain information including your personal information and Highly Sensitive Information in accordance with applicable laws requiring us to maintain such information or for a legitimate business purpose to maintain such information including but not limited to prevent fraud or to enforce our policies.
(c) Use of Personal Information. We may use, or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information.
- To process your requests, purchases, transactions, payments, and prevent fraud.
- Customer support and to respond to inquiries, including to investigate and address concerns and monitor and improve our responses.
- To personalize your Website or advertising experience and to deliver content, product, and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email. We also use this information for targeted advertising through Google.
- To help maintain the safety, security, and integrity of our Website, products, services, databases, other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- 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.
- To evaluate or conduct a merger 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 about our customers is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
(d) Sharing Personal Information. We may disclose your personal information to a service provider, as set out in our primary policy. When we disclose personal information for this 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.
Otherwise, we share and or sell as the terms are defined in the CCPA and CPRA your personal information with the following categories of third-parties: service providers, third-party vendors, and clients, our affiliated companies.
(e) Your Rights and Choices. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
(f) Access to and Correction of Specific Information and Data Portability Rights. You have the right to request that we disclose and or correct certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), 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 (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
(g) Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), 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 provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
- 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.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
(h) Right to Opt-Out of the Sale of Personal Information. You have the right to opt-out of any sale of your Personal Information by us. If you are requesting a product or service, this is an exemption from this right, and we will process your request. However, you have the right to cease all further sale of your Personal Information. You may email us or use our web portal and fully fill out the request form.
(i) Opt-Out Preference Signal (Global Privacy Control). You may use an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”), to opt-out of the sale/sharing of your personal information. However, this technology and our use of it is not fully developed by the market. Our database containing your information may not be linked to your browser identification and because your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account or database information as the connection between your browser and our database is not known to us, we may not be able to fulfill this request.
If you would like us to make the connection between your browser and your account within our database, please email us or submit the requested form through our website portal below.
(j) Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Email Us at: email@example.com
- Visiting our web portal: https://www.safesubscribe.org/request-form/?brandId=1b118b566d735373383efac8c8081d82
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. The appointment must be in writing and presented by your agent. If your authorized agent requests sensitive information about you then we may ask you to provide us with a sworn declaration to further verify your identity.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- You will be required to provide your full name, email address, and zip code.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
(k) Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by email unless you request, we mail the same to you and provide a current mailing address.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
(l) Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.
(m) Changes to Our Privacy Notice. We reserve the right to amend this privacy notice at our discretion and at any time. The only notice to you will be our posting of the updated notice on the Website and update the notice’s effective date.