Last updated September 28, 2022
Table of Contents
- Information We Collect
- How We Collect Information
- Cookies and Interest-Based Advertising
- Third Parties that Collect Information on Our Sites
- How We Use and Share Information
- Other Important Privacy Provisions
- Children’s Privacy
- Additional California Consumer Rights
- Contact Us
Conflict Between This Policy and Local Laws and Regulations
Information We Collect
We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
- Demographic information such as what language(s) you prefer,
- Internet & network information such as browsing/search history, IP address, data collected by cookies and similar technologies, device information such as device IDs, specifications, and operating system;
- Geolocation data such as non-precise geographic location indicators from mobile devices, websites;
- Outside Sources such as information collected from public databases, joint marketing partners, as well as from third parties, such as social media information, marketing leads, search resulting and links including paid listings;
- Audio/visual information such as call recordings, chat transcripts, email correspondence, and testimonials;
- Inferences drawn from other Personal Information or data that relate to your preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, including credit reports and scores.
The types of Personal Information we collect about you may vary based on how you use our Sites and/or Services and your relationship with us.
We may retain Personal Information for the length of time needed to carry out the purposes outlined in this Policy and to adhere to our recordkeeping policies, which are informed by applicable laws and industry standards.
Usage Data and Site Activity
We automatically collect information in connection with the actions you take on our Sites (“Usage Data”). For example, each time you use our Sites, we may collect the type of web browser you use, the type of device you use, your device ID, your operating system and version, your IP address, your internet service provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites. Among other things, this data helps us estimate our audience size and usage patterns, recognize you when you return to our Sites, store information about your preferences, customize our Sites according to your interests, and speed up your searches. If the data we automatically collect is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.
We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.
How We Collect Information
We may ask you to provide us with Personal Information when you communicate with us online or offline, including web forms, events, surveys, and marketing or promotional programs. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of our Sites or Services or we may not be able to fulfill your requested interaction. We may also capture your contact information, such as phone numbers and email addresses, when you contact us.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as data brokers, marketing and sales agencies or partners, analytics firms, government agencies, other customer or consumers, and credit reporting agencies.
Cookies and Interest-Based Advertising
Cookies and Automated Tools
We use the following types of cookies:
- Session Cookies: Session cookies keep track of you or your information as you move from page to page within our Sites and are typically deleted once you close your browser. For example, session cookies allow our online order forms to function properly.
- Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to our Sites. For example, persistent cookies may allow us to remember your preferences.
- Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.
We employ software technology that enables us to track certain aspects of a user’s visit to our Sites. This technology helps us better manage content on our Sites by informing us what content is effective, how consumers engage with our Sites, and how consumers arrive at and/or depart from our Sites. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether a user views a web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.
Information from Advertisements
If you arrive at our Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).
Social Media Widgets
Our Sites may include social media features, such as the Facebook, YouTube, Instagram, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our Sites as well as other Personal Information. A cookie may be set to ensure that these features properly function. These companies’ privacy policies govern your interactions with these features.
Third Parties that Collect Information on Our Sites
Certain third parties may collect Personal Information and/or Usage Data from users of our Sites using automatic collection tools such as cookies and tracking pixels. The collection, use, and disclosure of Personal Information and/or Usage Data by these third parties is governed by their privacy policies.
- Basis Technologies
- Bing Ads
- Full Story
- Survey Monkey
- Trust Pilot
How We Use and Share Information
We may use Personal Information for business purposes, such as to:
- Account creation, fulfillment, servicing and customer support: to create customer accounts, allow customers to create online accounts and profiles, provide goods or services, keep customers informed about the status of their products and services, engage in general customer service operations, provide newsletters, announcements, service bulletins and other information, or to otherwise fulfill the purpose for which you provide your information;
- Marketing and market research: to send communications and offers for our or third parties’ products and services, including offers based on consumers’ interests, personal and business characteristics and location, perform analytics for market and consumer research, trend analysis, financial analysis, and anonymization of personal information;
- Customer communications and interactions: to administer surveys, polls, sweepstakes, contests, promotional events, or to otherwise communication and interact with customers and consumers;
- Website use and analytics: to provide you with access to and use of our Sites and Services, analyze consumers’ use of our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data;
- Eligibility and pricing: to determine if consumers are eligible for certain products, services, or offers and the pricing related to such offers;
- Product research: to conduct research and analysis for maintaining, protecting, and developing services, increase and maintain the safety of our products and services, and prevent misuse;
- Business operations: to evaluate, develop, and improve business operations, products and services offered, carry out our obligations and enforce our rights arising from any contracts entered into between you and us, perform business administration and other normal business activities;
- Compliance: to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others;
- Information security and fraud prevention: to operate information security and anti-fraud programs; and
- Other purposes: for any other purpose with your consent.
Reviews and Testimonials
If you provide a review or testimonial, we may post it publicly on our Sites or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
If you do not want us to use your Personal Information for certain marketing purposes, you may take advantage of applicable opt-out options such as checking the relevant box located on the form on which we collect your information, adjusting your user preferences in your account profile, or opting out of promotional emails through an unsubscribe link or by emailing us at firstname.lastname@example.org.
We may provide your Personal Information to other businesses (“Service Providers”) to provide services to us or on our behalf. Categories of service providers we use include:
- Fulfillment and account servicing vendors, which help us provide products, services and information to you, service your account or benefits, and collect past due balances;
- Payment processors, which help us to accept and process the payments for our products/services to you;
- Marketing and communications vendors, which help us market our products/services to you, conduct promotions, surveys, and other outreach campaigns;
- Research and development vendors, which help us develop and improve our products and services;
- Consumer reporting agencies, which help us evaluate your eligibility for certain products or financing options;
- Data and business analytics vendors, which help us collect, analyze, and improve the accuracy of our data (including Personal Information);
- IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;
- Professional service firms, which provide accounting, legal, auditing, and other professional services; and
- General service providers, which help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.
We require each Service Provider to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information we provide to them other than as specified by us.
In the past twelve months we may have shared each category of Personal Information that we collect (listed above) with Service Providers.
We may share or sell your Personal Information with other companies who do not provide services to us (“Third Parties”), including affiliates, social media and advertising networks, data brokers, and other advertisers. These companies may use your Personal Information for their everyday business purposes, including marketing, customer service, fulfillment, and related purposes. We have not sold your Personal Information in the past 12 months, but reserve the right to do so in the future.
Other Important Privacy Provisions
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ (without obligation) commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use.
The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Sites, you must keep this password confidential. We ask that you not share your password with anyone and urge you to be careful about giving out information in public areas of the Sites, like message boards. The information you share in public areas may be viewed by any user of the Sites.
Even with data security safeguards in place, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired, or sold, or in the event of a divestiture, restructuring, reorganization, or transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
Links and Other Websites
Our Sites may contain links to third party websites, including social media platforms. Please be aware that if you access these links, you will be leaving our site. We encourage users to read the privacy policies of those sites, as we are not responsible for their content, links, or privacy procedures.
Our Sites are not intended for children under 16 years of age. No one under age 18 should provide Personal Information to us or on the Sites. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on our Sites. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us using the contact information listed below.
Additional California Consumer Rights
If you are a resident of California, you may have additional rights to access and control your Personal Information under the California Consumer Privacy Act. Exemptions may apply.
Right to Opt-Out from the Sale of Personal Information
As a California resident, you have the right to direct us not to sell your Personal Information to Third Parties. We will process requests within 15 business days, subject to any applicable exceptions and extensions permitted by law.
Right to Know
As a California resident, you have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which we collected your Personal Information; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Service Providers or Third Parties with whom we shared your Personal Information; and (v) the categories of Third Parties to whom we sold your Personal Information. We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver’s license numbers. To protect consumers’ Personal Information, you must provide required information and/or documentation to verify your identity. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law.
Right to Deletion
As a California resident, you have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. To prevent unauthorized individuals from making deletion requests, you must provide required information and/or documentation to verify your identity.
Submitting a Request
If you are a California resident and would like to exercise your rights, you may submit a request though email@example.com or by post to:
6100 Emerald Pkwy
Dublin, OH 43016
If you are an authorized agent submitting a request for another California resident, you must provide a copy of a lawful power of attorney or written authorization from the Consumer (along with proof of your identity). You will be provided options on how to provide this documentation after submitting the request. We may contact you or the Consumer on whose behalf you claim to act to verify your authorization.
California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites and Services do not respond to “do not track” signals.