Last Updated: February 12, 2021
Conflict Between this Policy and Laws and Regulations
INFORMATION WE COLLECT
We collect information that personally identifies, relates to, describes, or is capable of being associated with you ("Personal Information"), including:
- Unique Identifiers such as name, date of birth;
- Contact Information such as mailing address, email address, phone number;
- Characteristics of Protected Classifications such as age, gender, marital status;
- Demographic Information such as generation, income, education level, parental status;
- Commercial Information such as transaction history, videos watched, Sites or Services login history;
- Financial Information such as credit/debit card number, brand, and expiration date;
- Internet and Network Information such as IP address, device ID, browsing/search history, browser type, in-app notifications and settings;
- Audio/Visual Information such as call recordings, video or audio testimonials or stories;
- Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., topical interests, consumer response models, propensity to purchase models).
The specific Personal Information we collect about you may vary based on how you use the Sites and/or Services and your relationship with us.
We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, and credit card or bank account information (collectively, "Business Information"). This information is generally not considered Personal Information because it relates to a business or a business contact.
Usage Data and Sites Activity
We automatically collect information in connection with the actions you take on the Sites ("Usage Data"). For example, each time you visit our website, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, the number of clicks to, from, and within the Sites, and the duration of your visits to the Sites. When you use our mobile application, we gather information such as data and time of your use, duration of use, your device type, and operating system. If this information is reasonably capable of being associated with you, we treat it as Personal Information under the category Internet and Network Information. If this information is not reasonably capable of being individually associated with you, we treat it as Usage Data.
Communication RecordingsWe 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), register to use the Sites, purchase Services, and at other times. 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 the Sites or Services or we may not be able to fulfill your requested interaction.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as data brokers, marketing/advertising agencies, payment processors, and government agencies.
Cookies and Other Automated Tools
- Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you. We may also use information from advertising cookies to improve our marketing strategies.
- Functional Cookies: Functional cookies allow our Sites to work as intended such as by ensuring fonts display correctly, allowing you to engage with features like polls, quizzes, and forms, or embedding content from third-party platforms such as Facebook, Twitter, or YouTube. These cookies may also be used to personalize features and remember settings.
Cookies remain on a user's system for varying periods of time. Some only remain during a viewing session, others may remain for a year or longer.
Information from Advertisements
If you arrive at the 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).
THIRD PARTIES THAT COLLECT INFORMATION ON OUR SITES
Certain third parties, including but not limited to those identified below, collect Personal Information and/or Usage Data from users of our Sites and Services using automatic information collection tools such as APIs, 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.
HOW WE USE AND SHARE INFORMATION
We use Personal Information for internal purposes, such as:
- Provide you with the Sites and Services,
- 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 purchases and services, respond to questions and address customers concerns, and deliver updates, upgrades, and product improvement information;
- Marketing and market research: to send communications and offers and place advertisements for our products or services or third parties' products, services, or campaigns, 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;
- Surveys, promotional events, contests: to administer surveys, polls, sweepstakes, contests, and other promotional events and contests;
- Other company communications: to provide consumers with information that may be of interest such as company newsletters, announcements, reminders, and service bulletins;
- Sites and Services use and analytics: to provide you with access to and use of our Sites and Services, analyze consumers' use of our Sites and Services, including the use of third-party web analytics services which may utilize automated technologies to collect data (such as IP address, device configuration, and crash statistics);
- 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, perform business administration, and conduct other normal business activities;
- Compliance: to comply with applicable legal requirements, government requests, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others; and
- Information security and fraud prevention: to operate information security and anti-fraud programs.
Testimonials and Stories
If you provide a testimonial or story, we may post it publicly on the Sites, Services, or in other advertising material. By providing a testimonial or story, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications, without any compensation to you. Unless prohibited by applicable law, we may also use your likeness and story on the Sites, Services, or in other advertising material in connection with your testimonial or story.
We may establish a relationship with other businesses to provide services to us which may include corporate affiliates ("Service Providers"), including for:
- Provision of the Sites and Services;
- Facilitating marketing and non-marketing communications;
- Marketing design and development;
- Business analytics (both marketing and non-marketing related);
- IT and network administration such as mobile application development, data storage and management, website hosting, and data security;
- Sweepstakes and event design and administration;
- Payment processing;
- Professional services such as legal and accounting;
- Obtaining legal records;
- Collection of accounts; and
- Day-to-day business operations such as courier services, facilities management, and document destruction.
We only provide our Service Providers with the Personal Information necessary for them to perform these services on our behalf. Each Service Provider is expected 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 other than as specified by us.
We may share the following types of Personal Information with one or more Service Providers: unique identifiers; contact information; characteristics of protected classifications; demographic information; commercial information; financial information; geolocation information; audio/visual information; Internet and network information; inferences drawn from the foregoing categories of Personal Information.
You may also be asked to provide Personal Information directly to a Service Provider. For example, we may connect you with a third-party financial institution or financial calculator provider and request that you provide Personal Information directly to them.
We may sell your Personal Information to third parties. In the past twelve months we have sold contact information, unique identifiers, and internet and network information to third parties. The third parties to whom we sold these categories of Personal Information include marketers of consumer goods, financial advisory services, political campaigns, political action committees, and political parties. We do not knowingly sell Personal Information of individuals under 16 years of age.
OTHER PRIVACY AND SECURITY PROVISIONS
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 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.
Other Websites & App Stores
Please be aware that third-party websites accessible through the Sites or recommended through our Services may have their own privacy and data collection policies and practices. If you access our applications through an app store such as the Apple App Store, Google Play Store, or Roku Channel Store, your interactions with those stores and the manufacturer of the device you are using will be governed by their respective privacy policies. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.
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 transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
How Long We Retain Your Data
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations, to remarket to you, and to maintain our anti-fraud and security programs.
Children's PrivacyThe Sites and Services are not intended for children under the age of 18 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.
ADDITIONAL CALIFORNIA CONSUMER RIGHTS
If you are a resident of California, you have additional rights to access and control your Personal Information under the California Consumer Privacy Act ("CCPA"). Exemptions may apply.
Right to Know
You have the right to request that we disclose 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, we will disclose to you: (i) The categories of Personal Information we collected about you; (ii) The categories of sources for the personal information we collected about you; (iii) Our business or commercial purpose for collecting or selling that Personal Information; (iv) The categories of third parties with whom we share that Personal Information; (v) The specific pieces of Personal Information we collected about you (also called a data portability request); and (vi) If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
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. We will not provide specific pieces of Personal Information unless you expressly request them.
You may only make a consumer request for access or data portability twice within any 12-month period.
Right to DeletionYou 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 legal exemptions include, but are not limited 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 (Cal. Penal Code § 1546 et. seq.).
- 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.
Right to Opt-Out of the Sale of Personal Information
You have the right to request that we do not sell your Personal Information to others. Please note that opting out of the sale of Personal Information will not affect any sale of your Personal Information that may have occurred prior to the date of your opt-out request.
Submitting a CCPA Request
You may submit your request(s) by or sending an email to [email protected] or writing to us at our mailing address below. In your correspondence, please include at least your name, mailing address, email address, and a description of your request. You may also submit a request to opt-out of the sale of your Personal Information by completing our Do Not Sell My Personal Information form.
After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not process Right to Know or Deletion requests without verifying your identity, so please respond promptly. If you do not timely respond to our requests for information, we may deny your request.
We will process verified Right to Know and Deletion requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law up to 90 days. If you request access to specific Personal Information and that information creates a high risk of potential harm from disclosure to an unauthorized person, we will withhold that information and replace it with a category identifier. For example, if we withhold a social security number, we will inform you that we have a social security number on file. If you have an online account with us, we will provide the response to your request via the online account, otherwise, we will give you the option to choose between mail and electronic delivery. We will retain a copy of your deletion request for at least two years as required by law.
If you are an authorized agent submitting a request on behalf of a California resident (other than a request to opt-out of the sale of Personal Information), you must provide a copy of a lawful power of attorney or a written signed authorization from the consumer along with proof of your identity. You may provide this documentation via email to [email protected] after submitting the request. We may contact you and the consumer on whose behalf you claim to act to verify your identity, the consumer's identity, and your authorization to act on the consumer's behalf.
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.