October 3, 2017
1. Introduction and Overview
2. Information Collection
A. Information You Provide
We and our Service Providers (defined below) may collect information you provide directly via the Service. For example, we collect information when you make purchases, access our content, or otherwise communicate or transact with us through the Service.
The information we collect may include Personal Information. "Personal Information" is information that identifies you personally (whether alone or in combination), such as your first and last name, e-mail address, phone number, postal address, and payment card and shipping information. You may choose to voluntarily submit certain other information to us through the Service, including Personal Information, but you are solely responsible for your own Personal Information in instances where we have not requested that you submit such information to us.
B. Information Collected Automatically
The methods that may be used on the Service to collect Usage Information include:
- Log Information: Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
- Information Collected by Tracking Technologies: Cookies, web beacons (also known as "tracking pixels"), embedded scripts and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about your interactions with the Service or e-mails, including information about your browsing and activity behavior.
- Cookies: A cookie is a small text file that is stored on a user’s device, which may be a session ID cookie or tracking cookie. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies help in understanding how you use the Service, and remain longer. The Service may associate some or all of these types of cookies with your devices. Cookies may remain on your device for extended periods of time.
- Web Beacons ("Tracking Pixels"): Web beacons are small graphic images, also known as "internet tags" or "clear gifs," embedded in web pages and e-mail messages. Web beacons may be used to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
- Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Service, and deleted or deactivated thereafter.
Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services. For further information on Tracking Technologies and your choices regarding them, please see “Third Party Services, Features, and Devices” and “Your Rights and Choices” below.
C. INFORMATION FROM OTHER SOURCES
2. Use of Information
- Manage our Service;
- Process your transactions;
- Respond to your comments, questions, and requests, and provide customer service;
- Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
- Prevent and address fraud, breach of policies or terms, and threats or harm;
- Monitor and analyse trends, usage, and activities;
- Improve the Service or other Company websites, applications, marketing efforts, products and services;
- Send you advertisements and communicate with you regarding our and third party products, services, offers, promotions, rewards and events we think you may be interested in (for information about how to manage these communications and marketing efforts, please see “Your Rights and Choices” below); and
- Fulfill any other purpose disclosed at the time you provide Personal Information.
4. Sharing of Information
Our agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including Personal Information and Usage Information, in connection with their work on our behalf. These Service Providers are prohibited from using your Personal Information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
- 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;
- To protect the rights, property, life, health, security and safety of us, the Service or any third party;
- 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;
- With our affiliates for internal business purposes;
- With our affiliates, business partners, and other third parties for their own business purposes, including direct marketing purposes (California residents have certain rights set forth in “Your California Privacy Rights” below)
- For purposes disclosed at the time you provide Personal Information; and
- With your consent or at your direction.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.
5. Sweepstakes, Contests, Promotions
We may offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your Personal Information may be disclosed to third parties for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
6. Third Party Services, Features, and Devices
Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). In addition, our Service contains features that allow you to interact with, connect to, or access our Service through certain Third Party Services and third party devices (“Third Party Features”). For example, you use a Third Party Feature when you purchase a product through our Service using a third party payment processor. Remember that third parties may use Tracking Technologies to independently collect information about you and may solicit Personal Information from you. Also, if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature. If you publicly reference our Service on a Third Party Service (e.g., by using a hashtag associated with Company in a tweet or post), we may use your reference on or in connection with our Service.
Our Service also may contain Tracking Technologies operated by third parties. For example, analytics services may use Tracking Technologies on our Service to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Similarly, ad serving services, advertisers, and other third parties may use Tracking Technologies on our Service and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Service (“Interest-based Advertising”).
For further information on Tracking Technologies and your choices regarding them, please see “Information Collected Automatically” above and “Your Rights and Choices” below.
7. Your Rights and Choices
A. Accessing your information
You may access, update, or remove certain account information that you have voluntarily submitted to us through the Service by sending an e-mail to us here. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents have additional rights set forth in “Your California Privacy Rights” below.
B. Tracking technologies generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately.
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
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, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
You can opt-out of receiving certain promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or contacting us here with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions or, for e-mails, non-promotional communications, such as those about your account, transactions, servicing, or Company’s ongoing business relations.
D. Your California Privacy Rights
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.
Company may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please e-mail us here or send us a letter to ThoughtMatter, 27 W 24th St, Ste 600, New York, NY 10010. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Company is not required to respond to requests made by means other than through the provided e-mail address or mail address.
The Service is intended for a general audience and not directed to children under thirteen (13) years of age. Company does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe Company has collected such information in a manner not permitted by COPPA, please e-mail us here or send us a letter to ThoughtMatter, 27 W 24th St, Ste 600, New York, NY 10010, and we will remove such data to the extent required by COPPA.
9. Data Security
We take reasonable measures 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 your information collected through our Service.
10. International Transfer
12. Contact Us
If you have questions or concerns about any of our information collection or handling practices, or if you wish to change or remove any Personal Information provided to us, please contact us by email at email@example.com by postal mail sent to ThoughtMatter, 27 W 24th St, Ste 600, New York, NY 10010.