Effective Date: March 29, 2022.
1. Introduction and Overview .
If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.
2. Information Collection .
A. Information You Provide.
We collect information about you when you use the Service, including information you provide when you register an account, update your profile, access our content, make a purchase, participate in a promotion, contact support, or apply for a job. The categories of information we collect include:
- Contact Data , including your first and last name, email address, postal address, and phone number.
- Account Credentials , including your username, password, password hints, and information for authentication and account access.
- Demographic Data , including your age, gender, and country.
- Billing Data , including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
- Profile Data , including your interests, preferences, and favorites.
- Content, including content within any messages you send to us (such as feedback or questions to customer support) or publicly post on the Service (such as in product reviews or blog comments). We also collect content within any messages you exchange with other users through the Service (such as if you use any chat functionality).
- Personal Contacts Data, including the first and last name, email address, and phone number of your personal contacts. We collect data about your contacts with your consent and in order to fulfill a request by you, such as finding your contacts on the Service or inviting your contacts to join the Service. Such functionality is only intended for U.S. residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent for us to use their contact information to fulfill your request.
- Job Applicant Data , including your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
B. Information Collected Automatically.
In addition, we automatically collect information when you use the Service. The categories of information we automatically collect include:
- Service Use Data , including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
- Device Data , including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id (which is a user-resettable identifier associated with your device).
- Location Data , including non-precise location data (such as location derived from an IP address or data that indicates a city or postal code level).
The types of tracking technologies we use to automatically collect this information include:
- Cookies , which are small data files stored on your browser that save data about your visit. Cookies often include a unique identifier (e.g., cookie #123). We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and expire on a set expiration date or when they are deleted manually.
- App Technologies , which are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include Software Development Kits (SDKs), which is code provided by separate entities, such as Facebook, that allows us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality.
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.
3. Use of Information .
- Providing the Service to you.
- Preventing and addressing fraud, breach of policies or terms, or threats or harm.
- Understanding trends, usage, and activities, including through tracking technologies or surveys, to make business and marketing decisions.
- Communicating with you about updates, security alerts, changes to policies, and other transactional messages.
- Personalizing your experience to show you content we believe you will find interesting.
- Engaging in direct marketing, promotional communications, and non-personalized advertising.
- Engaging in personalized advertising, including Interest-based Advertising.
- Fulfilling any purpose at your direction.
- With notice to you and your consent.
Notwithstanding the above, we may use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) for any purpose to the extent permitted by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
4. Disclosure of Information .
- Service Providers and Contractors . We disclose information to service providers and contractors that process information on our behalf. Service providers and contractors assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers and contractors from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law.
- Analytics and Advertising . We disclose information to vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
- Affiliates. We disclose information to our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
- Partners . We disclose information to our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
- Promotions . Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we disclose information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
- Public Forums. We disclose information you make public through the Service, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.
- Merger or Acquisition . We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
- Security and Compelled Disclosure. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
- Facilitating Requests. We disclose information where you direct us to disclose the information.
- Consent. We disclose information with notice to you and your consent.
Notwithstanding the above, we may disclose publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law. For information on your rights and choices regarding how we disclose information about you, please see the “Your Rights and Choices” section below.
5. Viewing Information .
6. Other Parties .
We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service.
7. Analytics and Advertising .
We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“ Interest-based Advertising”).
We also use audience matching services (which is a type of Interest-based Advertising) to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“ Matched Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Service, and the ad partner matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may disclose your hashed email address to Facebook as part of our use of Facebook Custom Audiences.
For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
8. Your Rights and Choices .
A. Account Management.
You may access, update, or delete certain information that you have provided to us through your account by visiting your account settings. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
B. Tracking Technology Management.
- Cookies. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.
C. Analytics and Interest-Based Advertising Management.
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/ .
The companies we work with to provide you with Interest-based Advertising may be participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“ NAI”). To opt out of receiving Interest-based Advertising from the participating companies, please visit https://www.aboutads.info/choices and https://www.networkadvertising.org/choices/ for website opt outs and https://www.aboutads.info/appchoices for mobile opt outs. Note that opting out through these links only means that the selected participants should no longer deliver Interest-based Advertising to you, but does not mean that the participants will not process your information for Interest-based Advertising purposes or that you will no longer receive Interest-based Advertising from other companies.
Please note that the above opt outs only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of any opt outs offered by other entities.
To opt out of us disclosing your hashed email address to an ad partner for Matched Ads purposes, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of Matched Ads. We will remove your email address from any subsequent lists disclosed to ad partners for Matched Ads purposes.
- E-mails. You can unsubscribe from receiving promotional emails by following the unsubscribe instructions at the bottom of the email, or emailing us at email@example.com with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional messages.
- Push Notifications. If you have opted-in to receive push notification on your device, you can opt-out by adjusting your device settings or uninstalling our app.
Please note that your opt out is limited to the email address and device used and will not affect subsequent subscriptions.
9. Data Security .
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
10. International Transfer .
12. Contact Us .
By email: firstname.lastname@example.org
By telephone: 646-468-6532
By mail: 1601 Broadway, 11th Floor, New York, NY 10019 Attn: GIGnition
13. California .
The California Consumer Privacy Act (“CCPA”), and its replacement the California Privacy Rights Act (“CPRA”), provide additional rights to California residents. This section addresses those rights and applies only to California residents. Any rights specifically relating to the CPRA shall not take effect until January 1, 2023.
A. Notice of Collection.
We have collected the following categories of personal information (as described in the CCPA/CPRA) in the past 12 months. For further details on the personal information we collect and how we obtain this information, please review the “Information Collection” section above.
- Identifiers , including name, postal address, email address, and online identifiers (such as IP address).
- Customer records , including phone number, billing address, and credit or debit card information.
- Characteristics of protected classifications under California or federal law , including gender.
- Commercial or transactions information , including records of products or services purchased, obtained, or considered.
- Internet activity , including browsing history, search history, and interactions with a website, email, application, or advertisement.
- Non-precise geolocation data , including location derived from an IP address.
- Professional, employment, or education-related information .
- Inferences drawn from any of the information identified in this section.
We collect and use this personal information for the business purposes set out in the “Use of Information” section above.
We disclose this personal information to the categories of persons set out in the “Disclosure of Information” section above.
B. Sensitive Personal Information.
In addition, we have collected sensitive personal information (as defined in the CPRA) in the past 12 months. For further details on the sensitive personal information we collect and how we obtain this information, please review the “Information Collection” section above.
We collect, use, and disclose this sensitive personal information as necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services, and for other permissible business purposes under the CPRA.
We retain personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
D. Right to Know, Correct, and Delete.
You have the right to know certain details about our data practices. In particular, you may request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold or shared;
- The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared;
- The business or commercial purpose for collecting or selling or sharing the personal information; and
- The specific pieces of personal information we have collected about you.
Unless you specify otherwise, the response we provide will cover the 12 month period preceding our receipt of the request. Starting with personal information collected on or after January 1, 2022, you may request that we disclose details beyond the 12-month period, and we shall do so unless doing so proves impossible or would involve a disproportionate effort.
In addition, you have the right to correct (effective January 1, 2023) or delete the personal information we have collected from you.
To exercise any of these rights, please email us at email@example.com. If you have an account with us, we may require you to use the account to submit the request. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
E. Right to Opt-Out.
To the extent we “sell” or “share” your personal information as those terms are defined under the CCPA/CPRA, you have the right to opt-out of the “sale” or “sharing” (effective January 1, 2023) of your personal information by us to third parties at any time. You may exercise this right by emailing us at firstname.lastname@example.org and specifying you wish to opt-out.
F. Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
G. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
H. Shine the Light.
Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
14. European Economic Area, Switzerland, and United Kingdom
The General Data Protection Regulation (“GDPR”) provides additional rights to individuals located in the European Economic Area, Switzerland, and the United Kingdom, (collectively, “Europe”). This section addresses those rights and applies only to those individuals.
Data protection laws in the distinguish between organizations that process
personal data for their own purposes (known as “controllers”) and
organizations that process personal data on behalf of other organizations
(known as “processors”). Company acts as a controller with respect to
personal data collected as you interact with our Service.
B. Lawful Basis for Processing.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.
C. Your Rights.
You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please contact us as set out in the “Contact Us” section above and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request.
Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.