WHAT INFORMATION DO WE COLLECT?
(A) INFORMATION YOU PROVIDE TO US
Personal Information and Demographic Information.
We may ask you to provide us with certain categories of information such as: (1) personal information, which is information that could reasonably be used to identify you personally, such as your name, e-mail address, date of birth and physical address (“Personal Information”); and (2) demographic information, such as information about your family and pets (“Demographic Information”). We may collect this information through various forms and in various places through the Services, including account registration forms, contact us forms, or when you otherwise interact with us.
(B) INFORMATION WE COLLECT AS YOU ACCESS AND USE OUR SERVICES
In addition to any Personal Information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Services (“Usage Information”). This Usage Information may include the browser that you are using, the URL that referred you to our Services, all of the areas within our Services that you visit, and the time of day, among other information. We may use Usage Information for a variety of purposes, including to enhance or otherwise improve the Services. In addition, we collect your IP address or other unique identifier (“Device Identifier”) for your computer or other device used to access the Services (any, a “Device”). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information or a Device Identifier with your Personal Information, we will treat it as Personal Information.
A few of the methods that may be used to collect Usage Information include, without limitation, the following (and subsequent technology and methods hereafter developed):
A cookie is a data file placed on a Device when it is used to access the Services. A Flash cookie is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. Cookies and Flash Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. If you choose to disable cookies or Flash cookies on your Device, some features of the Services may not function properly.
Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our web and mobile pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web or mobile page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count users of the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
(C) INFORMATION THIRD PARTIES PROVIDE ABOUT YOU
(D) INFORMATION YOU PROVIDE ABOUT A THIRD PARTY
If you send someone else a communication from the Services, such as sending an invitation to a friend, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality through our Services, your e-mail address may be included in the communication sent to your friend. Your friend may contact us at 866-263-3834 to request that we remove your friend’s information from our database.
(E) INFORMATION COLLECTED BY MOBILE APPLICATIONS
Certain aspects of the Services may be provided through an application on your mobile, tablet computer or similar device (“Mobile Application”). You agree that we may collect and use technical data and related information, including but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to such Mobile Applications.
When you use any of our Mobile Applications, the Mobile Application may automatically collect and store some or all of the following information from your mobile device (“Mobile Device Information”), including without limitation:
Your preferred language and country site (if applicable)
Your phone number or other unique device identifier assigned to your mobile device
The mobile device manufacturer and model of your mobile device
The IP address of your mobile device Your mobile operating system
The type of mobile Internet browsers you are using
Information about how you interact with the Mobile Application and any of our web sites to which the Mobile Application links, such as how many times you use a specific part of the mobile application over a given time period, the amount of time you spend using the Mobile Application, how often you use the Mobile Application, actions you take in the Mobile Application and how you engage with the Mobile Application
Information to allow us to personalize the services and content available through the Mobile Application
We may use information automatically collected by the Mobile Application (including the Mobile Device Information) in the following ways:
- To operate and improve our Mobile Applications, other Services, our company’s services, and tools;
- To create aggregated and anonymized information to determine which Mobile Application features are most popular and useful to users, and for other statistical analyses;
- To customize the content or services on the Mobile Application for you, or the communications sent to you through the Mobile Application (if any)
- We may associate your unique device identifier or Mobile Application usage information with any personally identifiable information you provide, but we will treat the combined information as personally identifiable information.
For purposes of your use of any of our Mobile Applications and the services offered through any Mobile Application, the Mobile Application may also collect certain information about you (including Personal Information) that you knowingly supply to the Mobile Application such as the following:
- Your user name and any password required by the Mobile Application
- Mailing or other address
- Zip code
- Telephone number
- Email address
- Photos uploaded by you
HOW DO WE USE THE INFORMATION COLLECTED?
Use of Information by Us.
Please note that information submitted to the Services via a “contact us” or other similar function may not receive a response.
HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?
(A) WHEN YOU AGREE TO RECEIVE INFORMATION FROM THIRD PARTIES.
(B) THIRD PARTIES PROVIDING SERVICES ON OUR BEHALF.
We may use third party vendors to perform certain aspects of the Services, such as hosting the Services, designing and/or operating the Services’ features, tracking the Services analytics, and enabling Green Thumb Foods to send you special offers or performing other administrative services. We may provide these vendors with access to user information, including Personal Information, to carry out the services they are performing for you or for us. While we may use third party analytics service providers to evaluate and provide us with information about the use of the Services and viewing of our content, we do not share Personal Information with these analytics service providers, but they may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to information about you, including non-personally identifiable information.
(C) CO-BRANDED SERVICES.
Certain aspects of the Services may be provided to you in association with third parties (“Co-Branded Services”) such as sponsors, charities and political organizations and may require you to disclose Personal Information to them. Such Co-Branded Services will identify the third party. If you elect to register for products and/or services through the Co-Branded Services, you may be providing your information to both us and the third party. Further, if you sign-in to a Co-Branded Service with a username and password obtained through our Services, your Personal Information may be disclosed to the identified third parties for that Co-Branded Service and will be subject to their posted privacy policies.
(D) SWEEPSTAKES, CONTESTS AND PROMOTIONS.
We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
(E) ADMINISTRATIVE AND LEGAL REASONS.
(F) BUSINESS TRANSFER.
We may share your information, including your Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our shares and/or assets or other corporate change, including, during the course of any due diligence process.
WHAT IS ONLINE BEHAVIORAL ADVERTISING AND HOW CAN I OPT-OUT?
We contract with third-party advertising networks, publishers and other entities to advertise our products and services on websites not affiliated with us. Some of these ads are online behavioral advertising – which serve advertisements that are more likely to be of interest to you using non-personal behavioral information. Such ads may contain cookies that allow monitoring of websites (including our own websites that are part of our own Services) and your response to our advertisements. Cookies placed by these companies do not collect Personal Information. We limit companies that place our ads from using information for any purpose other than to assist us in our advertising efforts.
From time to time our consumer products business may adopt the use of the Advertising Options Icon on behaviorally targeted ads. For any of our behaviorally targeted ads that are part of a “network advertising” service, you should see a small symbol Image removed.(also called an icon) attached to a banner ad or other targeted advertising that can be clicked open for information about why and how you are receiving a particular ad. This icon is part of the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising. For more information see www.aboutads.info.
If you prefer to not receive targeted advertising, you can opt-out of some network advertising programs that use your information. To do so please visit the NAI Opt-Out Page.
Please note that if you opt out, you may still receive online advertising from us. Opting out from a specific advertising provider means that the ads you do receive will not be based on your preferences or behavior.
In order for behavioral advertising opt-outs to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new Device, access our Services from a different device, login under a different screen name, or change web browsers, you will need to opt-out again. If your browser has scripting disabled, you do not need to opt out, as online behavioral advertising technology does not work when scripting is disabled. Please check your browser's security settings to validate whether scripting is active or disabled.
Please note that even if you choose to remove your information (opt-out), you will still see advertisements while you're browsing online. However, the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.
WHAT ABOUT INFORMATION I DISCLOSE PUBLICLY?
(A) USER GENERATED CONTENT AND PUBLIC INFORMATION.
(B) NAME AND LIKENESS.
DOES THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SITES APPEAR ON THE SERVICES?
The Services may contain content that is supplied by a third party, and those third parties may collect web site usage information and your Device Identifier when web pages from any online Services are served to your browser. In addition, when you are using the Services, you may be directed to other sites or applications that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. For example, if you “click” on a banner advertisement, the “click” may take you away from one of our websites onto a different web site. These other web sites may send their own cookies to you, independently collect data or solicit Personal Information and may or may not have their own published privacy policies. We encourage you to note when you leave our Services and to read the privacy statements of all third party web sites or applications before submitting any Personal Information to third parties.
HOW DO I CHANGE MY INFORMATION AND COMMUNICATIONS PREFERENCES?
WHAT ABOUT CONSENT TO TRANSFER INFORMATION TO THE UNITED STATES?
The Services are operated in the United States and intended for users located in the United States and Canada. If you are located anywhere outside of the United States, please be aware that information we collect, including, Personal Information, will be transferred to, processed and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Services or providing us with any information, you consent to this transfer, processing and storage of your information in the United States.
WHAT SHOULD PARENTS KNOW ABOUT CHILDREN?
Any of our online Services are general audience web sites or applications, and we do not knowingly collect any Personal Information from children younger than the age of thirteen (13). We will delete any Personal Information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed Personal Information to us, please contact us at 866-263-3834.
WHAT ABOUT SECURITY?
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Sites and provide us with your information at your own risk.
If there are any material changes in the way we treat Personal Information, we will notify you by sending a notice to the primary email address specified in your communication preferences or by placing a prominent notice on our online Services prior to the change becoming effective.
WHAT ABOUT SOCIAL MEDIA FEATURES AND WIDGETS?
Your California Privacy Rights
Effective January 1, 2020
INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (”personal information”). Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Other Information excluded from the CCPA’s scope.
In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, device identifier, email address, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, address, or telephone number.
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity.
Browsing history, information on a consumer’s interaction with a website, application, or advertisement.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from calls you make to our customer service center or from forms you complete.
Indirectly from you. For example, from observing your actions on our Website.
USE OF PERSONAL INFORMATION
We may use, or disclose the personal information we collect for one or more of the following purposes:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To perform services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services.
To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, or via email.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To audit related to our current interactions with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
To debug to identify and repair errors that impair existing intended functionality.
For short-term, transient uses, but your personal information will not be disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
To undertake internal research for technological development and demonstration.
To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance our services or devices.
For any other commercial purposes, including any purpose to advance your commercial or economic interests, such as by inducing you to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Identifier, California Customer Records personal information categories, Internet or other similar network activity.
We disclose personal information for a business purpose to the following categories of third parties:
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
We do not sell your personal information to third parties for their direct marketing purposes.
Sales of Personal Information
We do not sell your personal information, and we will not sell personal information except as described in this Notice or if we provide you with notice and a right to opt-out of such sale.
YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
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 (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
The categories of personal information about you that was sold; and
The categories of personal information about you that was disclosed for a business purpose.
We do not provide these access and data portability rights for business-to-business personal information shared for a commercial purpose between two companies.
DELETION REQUEST RIGHTS
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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.
We do not provide these deletion rights for business-to-business personal information shared for a commercial purpose between two companies.
EXERCISING ACCESS, DATA PORTABILITY AND DELETION RIGHTS
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Calling us at 866-263-3834
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
Identify which of the following CCPA rights you wish to exercise:
A request to know the categories of personal information we collected about you.
A request to know the categories of sources for the personal information we collected about you.
A request to know our business or commercial purpose for collecting or selling that personal information.
A request to know the categories of third parties with whom we share that personal information.
A request to know the specific pieces of personal information we collected about you.
A request to delete the personal information that we have collected from you.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We do not sell the personal information of California consumers, including consumers that are less than 16 years of age, unless the consumer (in the case of consumers between 13 and 16 years of age) or the consumer’s parent or guardian (in the case of consumers who are less than 13 years of age) has affirmatively authorized the sale of the consumer’s personal information.
You may also contact the service provider that collects data on our websites to exercise your CCPA rights, which may include opting out of the collection of your PII: https://www.amobee.com/trust/consumer-opt-out/.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. We will provide you with a notice of financial incentive explaining any price or service difference. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
To learn more about your opt out choices more generally and how to opt out of tailored advertising across a number of services, please visit the NAI Consumer Opt Out webpage.