Effective as of: July 1, 2020
1. Information We Collect or Receive. In the course of operating the Platform, we will collect and/or receive the following types of information for legitimate* purposes. A legitimate purpose is when we have a business or commercial reason to use your information, so long as your rights and interests do not override this. You authorize us to collect and/or receive such information.
(a) PERSONAL INFORMATION. We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us via the Platform, email, or other means. When you sign up to become a user or contact us, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). We may collect and use the following Personal Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
|Categories of Personal Information||Specific Types of Personal Information Collected|
|Personal Identifiers||Contact information (including your name, email address, postal address, and telephone number), authentication information you create (such as account password), and birthdays.|
|Characteristics of protected classifications under California or federal law.||Gender and other demographic information.|
|Commercial information||Subscription information and Household Income.|
|Geolocation data||Certain features and functionalities of the Platform are based on your location. To provide these features and functionalities while you are using your electronic device, we may, with your consent, automatically collect geolocational information from your electronic device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”). The collection of such Geolocational Information occurs only when the Platform is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.|
|Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||Information we collect to create a profile about you reflecting your preferences and characteristics.|
|Audio, visual, and similar information||Not applicable at this time.|
|Professional or employment-related information||Information we collect to authorize your use of the platform and to create an impact profile.|
|Other Information||In addition to the information above, we may automatically collect or receive additional information regarding you and your use of the Platform, your interactions with us and our advertising, and information regarding your computer and mobile devices used to access the Platform (collectively, the “Other Information”). Such Other Information may include:
(i) Internet or other electronic network activity information: (A) IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device; (B) browser type and language; (C) referring and exit pages and URLs; (D) date and time; and (E) details regarding your activity on the Platform, such as search queries and other performance and usage data.
(ii) Electronic Device Identifiers: We may collect or receive information regarding: (A) type of electronic device; (B) advertising Identifier (“IDFA” or “AdID”); (C) operating system and version (e.g., iOS, Android or Windows); (D) electronic device carrier; and network type (WiFi, 3G, 4G, LTE).(iii) Cookies as defined in Section 1(e) below.
(i) Google Analytics – http://www.google.com/analytics/learn/privacy.html.
(ii) Mailchimp – https://mailchimp.com/legal/privacy/
Please be advised that if you opt-out of any such service, you may not be able to use the full functionality of the Platform.
(i) identify the type of electronic device;
(ii) personalize your experience;
(iii) analyze which portions of the Platform are visited and used most frequently;
(iv) measure and optimize advertising and promotional effectiveness; and
(v) collect Other Information.
If you do not want us to deploy cookies in the Platform, you can opt-out by setting your electronic device to reject cookies. You can still use the Platform if you choose to disable cookies, although your ability to use some of the features may be affected. Cookies are considered “Other Information.”
3. HOW TO OPT-OUT OF THIRD-PARTY INTEREST-BASED ADVERTISING. If you wish to opt-out of third-party interest-based advertising, please visit http://www.networkadvertising.org and http://www.aboutads.info/choices for details on how to do so. Additionally, users of mobile devices can follow the below instructions:
(a) Android Users. For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up: Open your Google Settings app > Ads > Enable “Opt-out of interest-based advertising.”
(b) iOS Users.
(i) iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting.
(ii) iOS 6: Go to your Settings >Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting.
4. HOW INFORMATION IS USED AND SHARED.
(a) You authorize us to use the Personal Information, Payment Information, Geolocational Information, and the Other Information (collectively, the “Information”):
(i) to provide you with the Platform, respond to your inquiries, process transactions, and payments, communicate with you, authenticate users, and otherwise facilitate your relationship with us;
(ii) for insights, such as to identify trends and make inferences about you and your interactions with us, such as to analyze your behavior and preferences, and to evaluate and improve the Platform;
(iii) to comply with legal obligations, including keeping records required by law or to document our compliance with laws or to provide information to law enforcement; and
(iv) for internal business and operational purposes, such as: (A) internal business administration, such as to manage user accounts, including keeping general records of users, sales, customer care, and other interactions; (B) auditing related to our interactions with you; (C) security purposes, such as to protect genuine users and our business from fraud, to minimize the risk of false details being used, and to avoid abuse by fraudsters; (D) to comply with contractual obligations (including when you subscribe); (E) to improve or develop the Platform (including our marketing activity more generally), and enhancing or personalizing your experience (such as building profiles about you or how you interact with us); and (F) for internal research and quality assurance.
(b) We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of services. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
(c) In an ongoing effort to better understand our users, the Platform, and our services, we may analyze certain Information in anonymized and aggregated form to operate, maintain, manage, and improve the Platform and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the Platform and these services to current and prospective business partners and investors and to other third parties for other lawful purposes.
(d) We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
(e) As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
(f) To the extent permitted by law, we may also disclose the Information:
(i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or
(ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.
5. ACCESSING AND MODIFYING INFORMATION AND COMMUNICATION PREFERENCES. If you have provided us Personal Information or Payment Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. We may use your Personal Information to send you updates (by email, text message, telephone, or post) about the Platform and new services.
We have a legitimate interest in processing your Information for promotional purposes (see Section 4 above). This means we do not usually need your consent to send you promotional communications. However, where permission is necessary, we will ask for this consent separately and clearly. We will always treat your Information with the utmost respect and will not sell it with unaffiliated third parties for marketing purposes without your consent.
You have the right to opt-out of receiving promotional communications at any time by:
• Contacting us at email@example.com;
• Using the “unsubscribe” link in emails or “STOP” number in texts; or
• Updating your marketing preferences on your profile page.
We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify Information in our databases. You cannot opt-out of receiving transactional emails related to the Platform (e.g., requests for support).
6. HOW WE PROTECT YOUR INFORMATION. We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should, therefore, take special care in deciding what information you send to us via email.
7. IMPORTANT NOTICES TO NON-U.S. RESIDENTS. The Platform and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Platform, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.
8. APP STORES; EXTERNAL WEBSITES. Your app store (e.g., iTunes or Google Play) may collect Information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.
9. CHILDREN. The Platform is not directed to children under the age of 16. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 16. We ask that minors (under the age of 16) not use the Platform. If a child under the age of 16 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.
10. DO NOT TRACK SIGNALS. We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
11. PERSONAL INFORMATION WE SOLD OR DISCLOSED FOR A BUSINESS PURPOSE. As of the date written above, we have not sold any Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household to any third party.
13. HOW LONG YOUR INFORMATION IS KEPT. We will keep your Information while you use the Platform. Thereafter, we will keep your Information for as long as is necessary:
• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.