Effective Date: September 1, 2016
Regarding Personal Information (defined below), if any modifications are materially less restrictive on our use or disclosure of the Personal Information previously disclosed by you, we will obtain your consent before implementing such revisions with respect to such information.
THE TYPES OF INFORMATION WE COLLECT
Personal Information. We collect information from you that is protected for purposes of privacy and data security (“Personal Information”). Personal Information that we collect may vary with each separate purpose for which you provide it, and it may include one or more of the following categories: name, email address, location data.
We also may collect publicly available Personal Information posted on social media platforms and profiles. When you engage with our content on or through social media platforms or other third party platforms, plug-ins, integrations or applications, you may allow us to have access to certain Personal Information in your profile that you have added to these platforms. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third-party platform or social media account user files, “like” photos and videos, your list of friends or connections, people you follow and/or who follow you, or your posts or “likes.”
Non-Personal Information. We reserve the right to collect anonymous information such as your mobile browser type, the type of your mobile device, your mobile device ID, the IP address of your mobile device, and the dates and times that you access this App and specific pages (“Non-Personal Information”). Non-Personal Information is essentially anonymous when collected.
Passively or Automatically Collected Data (“Usage Data”). Usage Data is essentially anonymous when collected, but could be used indirectly to identify a person.
We, our affiliated entities, and our marketing partners including third party service providers, advertisers, advertising networks and platforms, advertising agencies, and data brokers and aggregators may use automated means to collect various types of information about you, your computer or device used to access this App or its services. This information is based on your usage of the App, including information collected automatically from the App.
A representative, non-exhaustive list of the types of passively or automatically collected information may include: your network or Internet protocol address and type of browser, operating system, your Internet service provider, mobile network, device identifiers (such as an Apple IDFA or an Android Advertising ID), device settings, browser settings, pages of the App you have visited, pages or service visited before and after you visit a page or service, the type of mobile device used to view the page or service (e.g., iOS, Android), location information, and the content and advertisements you have accessed, seen, forwarded and/or clicked on, the various time details per session (e.g., the time spent on each page or service within the App) and the details about the path followed within the App with special reference to the sequence of pages visited, other parameters about the device operating system, and conversion rates and marketing and conversion data and statistics, reports and analytics, including without limitation your interactions to emails we send, and reviews and surveys regarding this site or any products listed on this site.
Geo-Location Data. You may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience on our services or on other services when we work with a marketing partner such as a third party service provider, advertiser, advertising network and platform, advertising agency, and a data broker or aggregator. If you agree to the collection of location data, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device.
Termination of Information Collection. App users may terminate the collection of all information by deleting this App from their mobile device.
HOW AND WHEN WE COLLECT INFORMATION
Personal Information. We collect Personal Information at the time you provide it to us. We collect Personal Information through sign-up forms and as part of your registration for an account, product, or service, promotion, or contest for the App. Personal Information that we collect may vary with the each sign-up or registration.
Your Communications With Us. We collect Personal Information that we receive from you as you communicate with us. If you complete a signup form subscribing to information or to participate in our mailing list activities, we will receive your Personal Information from our email services and/or autoresponder service.
Usage Data. We reserve the right to monitor your use of this App. As you navigate through the App, Non-Personal Information may be passively collected (that is, gathered without your actively providing the information) using various analytics and reporting technologies, such as cookies and web beacons.
HOW WE USE YOUR INFORMATION
Personal Information. We use your Personal Information for the performance of the features provided by the App, our private, internal reporting for the App, and security assessments for the App. If you have first provided consent through your mobile device, we may use your Personal Information together with a push notification token (not your native manufacturer ID) to send you push notifications regarding features or services specified in the App. We may also send you news or updates about changes to the App. You may manage push notifications in your device settings. If you have signed up for our email list, we may also send you this information via email.
We may use publicly available Personal Information posted on social media profile information including photos for purposes of assisting us, and our marketing partners with marketing and advertising activities and with contact management.
Non-Personal Information. We reserve the right to make full use of Non-Personal Information. For example, we may use Non-Personal Information to provide better service to App visitors, customize the App based on your preferences, compile and analyze statistics and trends about the use of this App, and otherwise administer and improve this App for your use.
We may make full, unrestricted use of Usage Data for any purpose in including: to customize or personalize ads, offers and content made available to you based on your usage of the App or its services, and to analyze the performance of those ads, offers and content, as well as your interaction with them.
We may combine and use the Personal Information and Usage Data we collect from all services and products offered by us and our affiliated entities over various apps and websites to provide, protect, and improve them, and to develop and offer new services and products. We will treat you as a single user of these combined services and products. We may also use this information to provide you personalized ads.
INFORMATION SHARING AND DISCLOSURE
General Disclosure Policy. Our general policy is that we will not share, sell, rent, or provide access to your Personal Information to others. The only exceptions to this general policy: (i) are described in the subsections below, and (ii) if you explicitly approve through our site or app. We may share and disclose Usage Data without restriction as described below.
Affiliated Entities. We reserve the right to provide your Personal Information and Non-Personal Information to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we legally control (by voting rights) or that control us.
Service Providers. We may provide access to your Personal Information and Usage Data to our trusted service providers that assist us with the operation and maintenance of the App. For example, we may contract with third parties to process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, and reporting, and software maintenance and development services. Our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.
Legal Process, Enforcement and Security Notice. We reserve the right to disclose your Personal Information and Non-Personal Information if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud or other illegal activity, and (iii) to investigate, respond to, or enforce violations of our rights or the security of this site. If we believe that the security of your Personal Information may have been compromised, we may notify you of the relevant facts as promptly as possible under the circumstances, and if you have provided us your email address, we may notify you by email. You consent to our use of your email address for this purpose.
Marketing Partners. We may share your Usage Data with our marketing partners including third party service providers, advertisers, advertising networks and platforms, advertising agencies, and data brokers and aggregators to serve and offer personalized ads. We may share Personal Information with our marketing partners to correlate and match our list with our marketing partners' lists for purposes of creating an “audience” for serving personalized ads.
Sweepstakes, Contests, or Promotions. When you choose to enter a sweepstakes, contest, or other promotion, and in accordance with the terms and conditions of the promotions, your Personal Information and Usage Data may be disclosed to our sponsors and to third parties who help administer the promotion, including in connection with winner selection, prize fulfillment, and aggregated data analysis. Your Personal Information and Usage Data also may be disclosed as required by law, such as on a winners list. Further, by entering a promotion, you are agreeing to the official rules that govern that promotion, including allowing our sponsors to use your name, voice, and likeness in advertising and marketing associated with the promotion in accordance with applicable law. All terms applicable to the particular promotion will be made available to you at the time you enter the promotion.
Your California Privacy Rights. As described above, from time to time, we make your Personal Information available to third parties. If you do not want us to share your Personal Information with other companies or organizations, you may request opt-out of this information sharing by making a request as provided below under “Contact Us”. This notice is designed to comply with California's “Shine the Light” law, but the opt-out option is available to all of our users.
SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS
“Cookies” are tiny pieces of information stored by your browser on your mobile device. Cookies are also used to customize content based on your browser. Most browsers are initially set to accept cookies. If you want to disable cookies, there is a simple procedure in most browsers that allows you to turn off cookies. Please remember, however, that cookies may be required to allow you to use certain features of our App. We reserve the right to use third party web analytics services that use third party cookies (cookies passed by them, not by us) to collect Non-Personal Information about your use of our App. These web analytics services may also transfer this information to third parties where required to do so by law, or where such third parties process the information on the service's behalf.
Web Beacons are used to assist in delivering cookies, and they allow us to count users who have visited pages of our App. We may include Web Beacons in promotional e-mail messages or our newsletters in order to determine whether messages have been opened and acted upon.
We may participate with our marketing partners for purposes of providing personalized ads based on your interests. This activity is performed by collecting Usage Data and by using cookies and other tracking and data collection methodologies discussed above to transfer information to our marketing partners which manage advertising activities.
Facebook Custom Audience. We may participate in Facebook's Custom Audience program which enables us to display personalized ads to users of this App and persons on our email lists when they visit Facebook. We provide Personal Information such as your email address to Facebook to enable Facebook to determine if you are a registered account holder with Facebook.
Other Personalized And Behavioral Advertising Services. We may participate in additional retargeting and behavioral advertising services that will be similar to the services described above.
DO NOT TRACK REQUESTS
Some Web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and website, we do not respond to “Do Not Track” signals at this time. As the technology and communication between browser and website improves, we will reevaluate the ability to honor “Do Not Track” signals and may make changes to our policy.
We will implement reasonable and appropriate security procedures consistent with prevailing industry standards to protect data from unauthorized access by physical and electronic intrusion. Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure. Therefore, while we strive to protect your Personal Information by following generally accepted industry standards, we cannot ensure or warrant the absolute security of any information you transmit to us or archive through our App.
When you transmit Personal Information through our registration process or if you purchase products or services, we encrypt that information in transit using secure socket layer technology (SSL).
After the secure transfer of your Personal Information, the information is maintained and stored with 128-bit encryption.
ONWARD TRANSFER OUTSIDE YOUR COUNTRY OF RESIDENCE
Any Personal Information which we may collect through this App will be stored and processed in our servers located only in the United States. By using this site, if you reside outside the United States, you consent to the transfer of Personal Information outside your country of residence to the United States.
UPDATING PERSONAL INFORMATION
Upon request, we will permit you to request or make changes or updates to your Personal Information for legitimate purposes. We request identification prior to approving such requests. We reserve the right to decline any requests that are unreasonably repetitive or systematic, require unreasonable time or effort of our technical or administrative personnel, or undermine the privacy rights of others. We reserve the right to permit you to access your Personal Information in any account you establish with this site for purposes of making your own changes or updates, and in such case, instructions for making such changes or updates will be provided where necessary.
CHILDREN'S ONLINE POLICY
We are committed to preserving online privacy for children. This App is a general audience App. Consistent with the Children's Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child's information, please contact us as provided below under “Contact Us”, and be sure to include in your message the same login information that your child submitted.
–Material Modifications Since September 1, 2016: none.
Notice: This document is Copyright © Chip Cooper of the law firm of Jones & Haley, P.C., and licensed for use by the owner of this App under distribution rights granted to FTCGuardian.com. All rights reserved worldwide. No part of this document may be copied, reprinted, reproduced, or transmitted in any form or by any means without the prior written permission of the copyright owner.