Privacy Policy

SCOPE AND APPLICATION Florida Word (“Company name” or “we”), wants you to be familiar with how we collect, use and disclose information from and about you. This Privacy Policy describes our practices in connection with information collected through services such as websites, mobile sites, applications (“apps”), and widgets (collectively, the “Company Services”). California residents, please see the California Consumer Privacy Act Notice in Section 8 below. Consumers in Virginia, Colorado, Connecticut and states with other similar privacy laws, please see Section 9 below. By using Company Services, you agree to the terms and conditions of this Privacy Policy.

The Company Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 13 years of age.


This Privacy Policy applies to all users, including both those who use the Company Services without being registered with or subscribing to a Company Service and those who have registered with or subscribed to a Company Service. This Privacy Policy applies to Company’s collection and use of your personal information (i.e., information that identifies a specific person, such as full name or email address). It also describes generally Company’s practices for handling non-personal information (for example, interests, demographics, and services usage).


COLLECTION OF INFORMATION

Depending on your interactions with us, Company and our service providers may collect the following information from and about you:


Registration Information is the information you submit to register for a Company Service, for example, to create an account, post comments, receive a newsletter, or enter a giveaway. Registration Information may also include, for example, name, email address, zip code, and phone number.


Public Information and Posts consist of comments or content that you post to the Company Services and the information about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public Information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.


Activity Information. When you access and interact with the Company Services, Company and its service providers may collect certain information about those visits. For example, in order to permit your connection to the Company Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the Company Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other transactional information for that device.


Cookies and other tracking technologies (such as browser cookies, pixels, beacons, local storage, and other mechanisms) use various approaches to collect and store data. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Company’s websites, apps and other services use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or app can access information when you make subsequent requests for pages from that service. These technologies may also be used to collect and store information about your usage of the Company Services, such as pages you have visited, search history, and the video and other content you have viewed.


Other parties that support the Company Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate Company Services usage statistics, may also use these technologies to collect similar information when you use the Company Services or other parties’ services. Those parties may also use these technologies, along with activity information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer. Company does not control these technologies and their use is governed by the privacy policies of parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, including your choices with respect to them, see the section entitled “To deliver relevant advertisements,” below.


Your browser may be initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, and to block cookies altogether. Please consult the “Help” section of your browser for more information, including on how to clear data from local storage and, depending on your browser, how to turn off other data collection by the browser. For more information about Google Analytics, please review the site “How Google uses data when you use our partners’ sites or apps,” located at http://www.google.com/policies/privacy/partners/. To opt out of Google Analytics specifically, please go to https://tools.google.com/dlpage/gaoptout. Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the Company Services.


Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services, advertising technology companies, advertisers, commercially available sources, and information from our Company Affiliates or business partners.


Depending on your interactions with us, Company may not have collected information from you for each of the categories above.


‘Do Not Track’. At this time we do not respond to the ‘Do Not Track’ signal, as we await the work of interested stakeholders and others to develop standards for how the ‘Do Not Track’ signal should be interpreted.


USE AND DISCLOSURE

We may use and disclose some or all of the information we collect from and about you for the following purposes:


To provide the Company Services. We use information we collect from and about you to provide the Company Services. This may include:


to measure, maintain and improve those Company Services and features and to develop new products and services, including conducting research and quality and safety assurance measures;

to improve your experience with both online and off-line Company Services by delivering content you will find relevant and interesting, including advertising and marketing messages;

to perform identity verification;

to allow you to comment on content, and participate in online games, contests, other promotions, or rewards programs;

to provide you with customer support and to respond to inquiries;

to make inferences and predictions about your potential areas of interest in order to provide you with content and advertising that is more interesting, personalized, and relevant to you;

to maintain our facilities and infrastructure;

to comply with internal policies, including accounting, audit, and other internal functions; and

to maintain records, and conduct risk and security controls and monitoring.

To allow service providers to assist us in providing and managing the Company Services. Information we collect from and about you may be made available to certain service providers, such as contractors, analytics and other measurement companies, and agents or sponsors, who help us analyze and understand your use of the Company Services, and manage and/or provide the Company Services.


To deliver video content. In the ordinary course of our business, we may share information that we collect from or about you with other parties in order to process your requests and fulfill your orders for video content offered through the Company Services, including to provide you with access to localized content and video content recommendations.


To provide co-branded services and features. We may offer co-branded services or features, such as contests, sweepstakes or other promotions together with other companies (“Co-Branded Services”). These Co-Branded Services may be hosted on Company Services or on that other party’s service. By virtue of these relationships, we may share information you submit in connection with the Co-Branded Service with that party. That other party’s use of your information will be governed by its privacy policy.


To deliver relevant advertisements. Company and our service providers may use information we collect from and about you as described in this Privacy Policy to deliver and measure relevant, more personalized ads to you when you use the Company Services or another service (on any of your devices). As noted above, advertising technology companies and advertisers may use cookies and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and information about the different devices and/or browsers you use and your activity on such devices and browsers, to assist them in delivering advertising that is more relevant to your interests. To find out more about advertising networks and similar entities that use these technologies, see https://youradchoices.com/. If you wish to opt out of tailored advertising in desktop and mobile browsers, please visit http://optout.aboutads.info/#/ or http://optout.networkadvertising.org/# on each of your devices and browsers. To opt out in mobile apps, you may use your device’s setting to opt out of ads personalization or similar settings or download and use the AppChoices app at https://youradchoices.com/appchoices. To opt out on connected TVs, please use the setting “opt out of ads personalization,” “Interest-based Ads,” or equivalent settings on your device. Please note that opting out does not mean that you will stop seeing all ads.


To contact you. Company may periodically send promotional materials or notifications related to the Company Services. If you want to stop receiving promotional materials, you can follow the unsubscribe instructions at the bottom of each email. There are certain service notifications and other non-promotional emails that you may not opt-out of, such as notifications of changes to the Company Services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.


To share with business partners. Company may share information we collect from and about you as described in this Privacy Policy with business partners to permit them to send you marketing communications consistent with your choices.


To protect the rights of Company and others. There may be instances when Company may use or disclose information we collect from and about you as described in this Privacy Policy, including situations where Company has a good faith belief that such use or disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Company, our Company Affiliates or their employees, agents and contractors (including enforcement of our agreements and our Terms of Service); (ii) protect the safety, privacy, and security of users of the Company Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.


To complete a merger or sale of assets or other corporate transaction. If Company sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in an acquisition, reorganization, merger or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), or other corporate transaction, Company may transfer or disclose information we collect from and about you as described in this Privacy Policy to the party or parties involved in the transaction as part of that transaction.


Depending on your interactions with us, Company may not have collected, used, or disclosed information from or about you in each of the categories above, and to the extent that Company has disclosed information from or about you, it may not include all of the information that we collect from and about you as described in this Privacy Policy.


Please note that when the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with other parties, to the extent permitted by applicable law.


SECURITY

Company uses commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft and unauthorized use, disclosure, or modification. However, no one can guarantee the complete safety of your information.


USER ACCESS AND CONTROL

If you would like to access personal information we hold about you, delete, or correct personal information you have previously provided, email [email protected], and submit a request. Please note that, for security reasons, we will ask you to verify your identity in order to proceed with your request. If you would like to suppress or otherwise limit our use of your personal information, you may contact us as outlined in Section 7. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to suppress or limit. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that, subject to applicable law, in some cases we may not comply with your request where we may require your information in order to comply with applicable law, or to protect, enforce or defend our rights or employee rights, or those of a Company Affiliate.


If you are a resident of California, please see the section entitled “California Consumer Privacy Act Notice,” below, for more information about the rights you have under California law. If you are a consumer in Virginia, Colorado, Connecticut, or other state with similar privacy laws, please see the section entitled “For Consumers in Virginia, Colorado, and Connecticut, and Other U.S. States with Similar Privacy Laws,” below, for more information about your rights under Virginia, Colorado, Connecticut, and other similar laws.


If you are under 18 and a registered user of the Company Services, you may ask us to remove content or information that you have posted to the Company Services by contacting us as outlined in Section 7 below. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.


You may request that we not share your personal information on a going-forward basis with Company Affiliates or unaffiliated third parties for their direct marketing purposes by contacting us as outlined in Section 7 below. We will try to comply with your request(s) as soon as reasonably practicable and consistent with applicable law.


OTHER IMPORTANT INFORMATION

Updates to Privacy Policy. Company may modify this Privacy Policy. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Company Services.


Location of Data. The Company Services are hosted in and managed from the United States. If you are a user located outside the United States, you understand and consent to having any personal information processed in the United States or in any other country in which we have facilities or in which we engage service providers. The United States and other countries’ data protection laws may not be the same as those in your jurisdiction.


Linked Services. The Company Services may be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. Company is not responsible for the privacy practices of unaffiliated companies, and once you leave the Company Services or click an advertisement, you should check the applicable privacy policy of the other service.


In addition, Company is not responsible for the privacy or data security practices of other organizations, such as Facebook, Instagram, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the Company Services.


Data Retention. We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.


Remember that even after you cancel your account, or if you ask us to delete your personal information, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services. Because of the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, for fraud detection or to comply with applicable law or our internal security or recordkeeping policies. It may not always be possible to completely remove or delete all of your information due to technical constraints or contractual, financial or legal requirements.


Deidentified Information. To the extent we process “deidentified” personal information, as defined under applicable law, we will maintain and use that information in deidentified form and will not attempt to reidentify the information except as permitted by applicable law.


CONTACT US

If you have questions about this Privacy Policy, please contact us at:


Email: [email protected]


CALIFORNIA CONSUMER PRIVACY ACT NOTICE

This California Consumer Privacy Act Notice Section provides information for California residents.


Under the CCPA, and for purposes of this Section, “Personal Information” generally means information that identifies, relates to, or describes a particular California resident and includes the categories listed below. This Section 8 provides details about the categories of Personal Information of California residents that we have collected, disclosed, or “sold” or “shared” during the last 12 months, as well as rights California residents have under California law.


Categories of Personal Information Collected, Disclosed, and/or Sold or Shared:


The categories of Personal Information that we have collected, disclosed, and/or “sold” or “shared” are below, along with the categories of third parties to whom each category of Personal Information was disclosed, and/or “sold” or “shared.” Please note that we disclose some categories of Personal Information in connection with certain types of advertisements, which could be considered “selling” or “sharing” under the CCPA. Also, depending on the California resident’s interactions with us, Company may not have collected, disclosed, or “sold” or “shared” each (or any) of these categories of Personal Information about each individual. Additionally, we do not knowingly “sell” or “share” Personal Information of minors under 16 years of age.


Category of Personal Information Collected Categories of Third Parties to Whom Personal Information Is Disclosed Categories of Third Parties to Whom Personal Information is “Sold” or “Shared”

Identifiers, such as name, IP address, email address, and online and device identifiers Service providers,


Company Affiliates,


and other providers or partners that support our operational business purposes Advertising technology companies; advertisers


For the purpose of targeted advertising

Personal information, as defined in the California Customer Records law, such as contact information Service providers,


Company Affiliates,


and other providers or partners that support our operational business purposes N/A

Characteristics of protected classifications under California law, such as age Service providers,


Company Affiliates,


and other providers or partners that support our operational business purposes Advertising technology companies; advertisers


For the purpose of targeted advertising

Commercial information, such as purchase history Service providers,


Company Affiliates,


and other providers or partners that support our operational business purposes Advertising technology companies; advertisers


For the purpose of targeted advertising

Internet or network activity information, such as browsing history and interactions with our websites, mobile, or connected TV applications (collectively, “Company Digital Properties”) Service providers,


Company Affiliates,


and other providers or partners that support our operational business purposes Advertising technology companies; advertisers


For the purpose of targeted advertising

Geolocation data, such as device location Service providers,


Company Affiliates,


and other providers or partners that support our operational business purposes N/A

Audio, electronic, visual and other similar information, such as photographs and video Service providers,


Company Affiliates,


and other providers or partners that support our operational business purposes N/A

Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics Service providers,


Company Affiliates,


and other providers or partners that support our operational business purposes Advertising technology companies; advertisers


For the purpose of targeted advertising


Please note that the CCPA definitions of “sale” and “share” do not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other similar transaction involving all or any portion of our business.


Sources of Personal Information. We collect Personal Information directly from California residents themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to a Company Digital Property); joint marketing, co-branding, co-promotional, or advertising partners, including advertising technology companies and advertisers; Company Affiliates; and sources of demographic and other information. Depending on the individual’s interactions with us, Company may not have collected Personal Information from each (or any) of these categories of sources.


Purposes. We may use Personal Information and/or disclose it to third parties for the following purposes:


to operate, manage, and maintain our business, including in connection with a sale, acquisition, reorganization, merger, transfer of all or a part of our business, or other corporate transaction (e.g., a bankruptcy or similar proceeding);

to provide our products and services;

to accomplish our business purposes and objectives, including:

– developing, improving, repairing, and maintaining our products and services;


- personalizing, advertising, and marketing our products and services;

 

- conducting research, analytics, and data analysis;

 

- maintaining our facilities and infrastructure;

 

- quality and safety assurance measures;

 

- conducting risk and security controls and monitoring;

 

- detecting and preventing fraud;

 

- performing identity verification;

 

- performing accounting, audit, and other internal functions;

 

- complying with law, legal process, and internal policies;

 

- maintaining records; and

 

- exercising and defending legal claims.

Depending on the California resident’s interactions with us, Company may not have used Personal Information collected about that resident for each of these purposes, and to the extent that Company has disclosed Personal Information about that resident, it may not include all of the Personal Information collected about that resident.


Sensitive Personal Information. We do not process “sensitive” Personal Information for purposes other than those specified in the CCPA Regulations section 7027(m) (such as to provide the services and for security purposes).


Data Retention. We will retain Personal Information from or about you as reasonably necessary and proportionate to achieve the purpose(s) for which the Personal Information was collected or processed as outlined in this Section 8 unless a longer retention period is required or allowed by law.


Financial Incentives. In exchange for signing up for our newsletters, visiting certain websites, or liking specific advertisers or posts on social media, we are offering you the opportunity to enter certain prize giveaways, and/or obtain bonus entries in such giveaways. The opportunity to opt-in to these benefits will be provided on the entry page for the applicable giveaway. You can opt-out of our use of your email address for the described purpose at any time by clicking “UNSUBSCRIBE” at the bottom of any email we send to you. You can unlike any posts or advertisers at any time using the tools provided by the relevant social media platform.


Company receives financial benefit through the promotion of its content to subscribers in its newsletters and through advertising sponsorships in the newsletters and in connection with the advertiser participation in giveaways. We do not assign a separate monetary value to personal information we collect in connection with these offers. Company estimates the value of the information, if any, will depend on the extent to which the user engages with our content or with the advertiser.


California Rights. If you are a California consumer, you have the following rights:


(1) Right to Know. You have the right to request that we disclose to you the following information:


The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;

The specific pieces of Personal Information we collected about you for the applicable time period;

The business or commercial purpose for collecting, disclosing, or selling Personal Information about you;

The categories of Personal Information about you that we sold and the categories of third parties to whom we sold that Personal Information; and

The categories of Personal Information about you that we otherwise shared or disclosed and the categories of third parties with whom we shared or disclosed that Personal Information.

To make a request for your Personal Information, email [email protected]. You will need to provide your name and email address, along with other details about your request. You will then receive verification instructions by email. For certain requests, you will be asked to authenticate to your account as part of the verification process, if you have an account/profile with us. But you do not need to have an account/profile to submit a request. In some circumstances, we may need additional information from you to verify your identity or proceed with your request.


You can use an authorized agent to submit a request for your Personal Information.  In addition to verifying your identity, as described above, we also will need to verify your authorized agent’s ability to act on your behalf (e.g., by receiving a copy of your signed permission).  Once verification is complete, we may communicate directly with you for privacy and security reasons.

 

Please note that, in some instances, we may decline to honor your request where, for example, we are unable to verify your identity or an exception to this right applies.

(2) Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you.


To request deletion, email [email protected]. You will need to provide your name and email address, along with other details about your request.  You will then receive verification instructions by email.  For certain requests, you will be asked to authenticate to your account as part of the verification process, if you have an account/profile with us.  But you do not need to have an account/profile to submit a request.  Please note that you also will be asked to separately confirm that you would like to proceed with your deletion request.  In some circumstances, we may need additional information from you to verify your identity or proceed with your request.

 

 You can use an authorized agent to submit a request for deletion.  In addition to verifying your identity, as described above, we also will need to verify your authorized agent’s ability to act on your behalf (e.g., by receiving a copy of your signed permission). Once verification is complete, we may communicate directly with you for privacy and security reasons.  

 

 Please note that, in some instances, we may decline to honor your request where, for example, we are unable to verify your identity or an exception to this right applies. 

(3) Right to Request Correction. You have the right to request that we correct inaccurate Personal Information we collected about you.

To make a request for correction, email [email protected].  You will need to provide your name, email address, and the Personal Information you would like to have corrected, along with other details about your request.  You will then receive verification instructions by email.  For certain requests, you will be asked to authenticate to your account as part of the verification process, if you have an account/profile with us.  But you do not need to have an account/profile to submit a request.  In some circumstances, we may need additional information from you to verify your identity or proceed with your request.

 

You can use an authorized agent to submit a request for correction of inaccurate Personal Information. In addition to verifying your identity, as described above, we also will need to verify your authorized agent’s ability to act on your behalf (e.g., by receiving a copy of your signed permission).  Once verification is complete, we may communicate directly with you /for privacy and security reasons.

 

Please note that, in some instances, we may decline to honor your request where, for example, we are unable to verify your identity or an exception to this right applies.

(4) Right to Opt-Out of Sale or Sharing. As noted above in this section, we share some categories of Personal Information in connection with certain types of advertisements.


You can opt out of the sale and sharing of your Personal Information by emailing [email protected]. If you have an account/profile with us, your preference will apply to the device(s) connected to your logged-in account or profile for the Company Services.  If you do not have an account, or choose not to log-in to your account on a device, you will need to select your preference on each device.  For mobile and connected TV apps, you may visit "Your Privacy Choices" in Account/Settings for more information and to exercise your choices.  If you have enabled a global privacy control feature on your device, we process opt-out preference signals in a frictionless manner.

(5) Right to be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.


Email [email protected] for metrics regarding the requests Company received during the previous calendar year for: Requests to Know, Requests to Delete, and Requests to Opt Out of “Sales.”


FOR CONSUMERS IN VIRGINIA, COLORADO, CONNECTICUTAND OTHER U.S. STATES WITH SIMILAR PRIVACY LAWS

Depending on where you live, you may have certain additional rights regarding your personal information. This section provides information for consumers residing in Virginia, Colorado, and Connecticut, in connection with the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (the “CDPA”), and other states with similar privacy laws. Under the VCDPA, the CPA and the CDPA, and for purposes of this Section, “Personal Data” generally means information that identifies, relates to, or describes a particular consumer residing in Virginia, Colorado, Connecticut, or other state with similar privacy laws and includes the categories listed below. We and our advertising partners use certain Personal Data to deliver online advertisements to you on your devices tailored to your interests. This may be considered “selling” under Colorado and Connecticut law and “targeted advertising” under Virginia, Colorado, and Connecticut law. This Section 9 provides details about the categories of Personal Data of consumers in Virginia, Colorado and Connecticut and other states with similar privacy laws that we have collected, disclosed, processed for purposes of targeted advertising, or “sold”, as well as rights consumers in Virginia, Colorado, Connecticut, and other states with similar privacy laws have under their states’ laws.


Categories of Personal Data Collected or Disclosed, or Processed for Targeted Advertising:


The categories of Personal Data that we collected disclosed, processed for purposes of targeted advertising (under the Virginia law) or “sold” (under the Colorado and Connecticut laws) are below, along with the purposes for processing, and categories of third parties to whom each category of Personal Data was disclosed or “sold” or processed for the purpose of targeted advertising. Please note that we process some categories of Personal Data in connection with targeted advertising, which could be considered “selling” under the Colorado and Connecticut laws. Additionally, depending on the consumer’s interactions with us, Company may not have collected, disclosed, processed, processed for purposes of targeted advertising, or “sold,” each (or any) of these categories of Personal Data, for each listed purpose. Additionally, we do not knowingly sell or process Personal Data of children under 13 years of age.


Category of Personal Data Collected/Processed Purposes for Processing Categories of Third Parties to Whom Personal Data Is Disclosed Categories of Third Parties to Whom Personal Data is Sold or Processed for Targeted Advertising

Identifiers, such as name, IP address, email address, and online and device identifiers To provide the Company Services,


To allow service providers to assist us in providing and managing the Company Services,


To deliver video content,


To provide co-branded services and features,


To deliver relevant advertisements,


To contact you,


To share with our Company Affiliates,


To share with business partners (consistent with your choices) Service providers (like hosting providers, content delivery networks, email marketing platforms),


Company Affiliates,


and


Other partners or providers that support our operational business purposes advertising technology companies,


advertisers


Virginia: Processed for targeted advertising


Colorado and Connecticut: Sold for purposes of targeted advertising

Personal information, such as contact information To provide the Company Services,


To allow service providers to assist us in providing and managing the Company Services,


To provide co-branded services and features,


To contact you,


To share with our Company Affiliates,


To share with business partners (consistent with your choices) Service providers (e.g., that help with order fulfillment, contest or sweepstakes providers),


Company Affiliates,


and


Other partners or providers that support our operational business purposes N/A

Characteristics of protected classifications, such as age To provide the Company Services,


To allow service providers to assist us in providing and managing the Company Services,


To deliver relevant advertisements,


To share with our Company Affiliates, Service providers (like contest or sweepstakes providers), Company Affiliates,


and other providers or partners that support our operational business purposes advertising technology companies, advertisers


Virginia: Processed for targeted advertising


Colorado and Connecticut: Sold for purposes of targeted advertising

Commercial information, such as purchase history To provide the Company Services,


To allow service providers to assist us in providing and managing the Company Services,


To deliver relevant advertisements,


To share with our Company Affiliates,


To share with business partners (consistent with your choices), Service providers (e.g., in connection with order fulfillment and payment services),


Company Affiliates,


and other providers or partners that support our operational business purposes advertising technology companies, advertisers


Virginia: Processed for targeted advertising


Colorado and Connecticut: Sold for purposes of targeted advertising

Internet or network activity information, such as browsing history and interactions with our websites, mobile, or connected TV applications (collectively, “Company Digital Properties”) To provide the Company Services,


To allow service providers to assist us in providing and managing the Company Services,


To deliver relevant advertisements,


To share with our Company Affiliates, Service providers (like analytics providers),


Company Affiliates,


and other providers or partners that support our operational business purposes advertising technology companies,


advertisers


Virginia: Processed for targeted advertising


Colorado and Connecticut: Sold for purposes of targeted advertising

Geolocation data, such as device location To provide the Company Services,


To allow service providers to assist us in providing and managing the Company Services,


To share with our Company Affiliates. Service providers,


Company Affiliates,


and other providers or partners that support our operational business purposes N/A

Audio, electronic, visual and other similar information, such as photographs and video To provide the Company Services,


To allow service providers to assist us in providing and managing the Company Services,


To share with our Company Affiliates. Service providers (e.g., in connection with customer support),


Company Affiliates,


and other providers or partners that support our operational business purposes N/A

Inferences drawn from any of the Personal Data listed above to create a profile or summary about, for example, an individual’s preferences and characteristics To provide the Company Services,


To allow service providers to assist us in providing and managing the Company Services,


To deliver relevant advertisements,


To share with our Company Affiliates. Service providers (like analytics providers),


Company Affiliates,


and other providers or partners that support our operational business purposes advertising technology companies,


advertisers


Virginia: Processed for targeted advertising


Colorado and Connecticut: Sold for purposes of targeted advertising


Please note that we may process Personal Data in each of the above categories in order to protect the rights of the Company and others, and/or to complete a merger or sale of assets or other corporate transaction. For more details about our purposes for processing, please see the Use and Disclosure section above.


Please note that, under Virginia law, the definition of “sale” is the exchange of information for monetary consideration and does not include, for example, the transfer of Personal Data as an asset that is part of a merger, bankruptcy, or other similar transaction involving of all or any portion of our business. We do not “sell” Personal Data as defined under Virginia law.


As noted above, the definition of “sale” under Colorado and Connecticut laws is different than the definition of that word under Virginia law. We and our advertising partners use certain Personal Data to deliver online advertisements to you on your devices tailored to your interests, which could be considered “selling” under the Colorado and Connecticut laws. The Colorado and Connecticut laws’ definitions of “sale,” however, do not include the transfer of Personal Data as an asset that is part of a merger, bankruptcy, or other similar transaction involving all or any portion of our business.


Consumer Rights under Virginia, Colorado, Connecticut, and other similar laws. If you are a consumer in Virginia, Colorado, Connecticut, or other state with a similar privacy law, you have the following rights:


(1) Right to Access and Portability. You have the right to confirm whether we are processing Personal Data concerning you, and to request that we disclose to you the Personal Data we collected from you, including in a portable form.



To confirm whether or not we are processing your personal data, please email [email protected].  You will need to provide your name and email address, along with other details about your request.  You will then receive verification instructions by email.   For certain requests, you will be asked to authenticate to your account as part of the verification process, if you have an account/profile with us.  But you do not need to have an account/profile to submit a request.  In some circumstances, we may need additional information from you to verify your identity or proceed with your request. 

 

You can use an authorized agent to submit a request for your Personal Data. In addition to verifying your identity, as described above, we also will need to verify your authorized agent’s ability to act on your behalf (e.g., by receiving a copy of your signed permission).  Once verification is complete, we may communicate directly with you for privacy and security reasons.

 

Please note that, in some instances, we may decline to honor your request where, for example, we are unable to verify your identity or an exception to this right applies.

(2) Right to Request Deletion. You have the right to request that we delete Personal Data we collected from you or about you.


To make the request, please email [email protected].  You will need to provide your name and email address, along with other details about your request.  You will then receive verification instructions by email.  For certain requests, you will be asked to authenticate to your account as part of the verification process, if you have an account/profile with us.  But you do not need to have an account/profile to submit a request. Please note that you also will be asked to separately confirm that you would like to proceed with your deletion request.  In some circumstances, we may need additional information from you to verify your identity or proceed with your request.

 

You can use an authorized agent to submit a request for deletion.  When submitting a request online, your authorized agent should select the "Other" option on the form and, in the field provided, include your name, your email address, and whether or not you have an account/profile with us.  In addition to verifying your identity, as described above, we also will need to verify your authorized agent’s ability to act on your behalf (e.g., by receiving a copy of your signed permission).  Once verification is complete, we may communicate directly with you for privacy and security reasons.

 

Please note that, in some instances, we may decline to honor your request where, for example, we are unable to verify your identity or an exception to this right applies.

(3) Right to Request Correction. You have the right to request that we correct inaccurate Personal Data we collected about you.


To make a request for correction, please email [email protected]  You will need to provide your name, email address, and the Personal Data you would like to be corrected, along with other details about your request.  You will then receive verification instructions by email.  For certain requests, you will be asked to authenticate to your account as part of the verification process, if you have an account/profile with us.  But you do not need to have an account/profile to submit a request.  In some circumstances, we may need additional information from you to verify your identity or proceed with your request.

 

You can use an authorized agent to submit a request for correction of inaccurate Personal Data.  When submitting a request online, your authorized agent should select the "Other" option on the form and, in the field provided, include your name, your email address, and whether or not you have an account/profile with us.  In addition to verifying your identity, as described above, we also will need to verify your authorized agent’s ability to act on your behalf (e.g., by receiving a copy of your signed permission).  Once verification is complete, we may communicate directly with you for privacy and security reasons.

 

Please note that, in some instances, we may decline to honor your request where, for example, we are unable to verify your identity or an exception to this right applies.

(4) Right to Opt-Out of Targeted Advertising (in Virginia, Colorado, and Connecticut) and/or “Sale” (in Colorado and Connecticut). We process and share some categories of Personal Data in connection with targeted advertising. In Colorado and Connecticut, this processing may be considered a “sale.” Consumers residing in Virginia, Colorado, Connecticut, and states with similar privacy laws can opt out of targeted advertising and/or “sale” by emailing [email protected]. If you have an account/profile with us, your preference will apply to the device(s) connected to your logged-in account or profile for the Company Services. If you do not have an account, or choose not to log-in to your account on a device, you will need to select your preference on each device.


(5) Right to Appeal. If we decline to take action in response to a personal data rights request, consumers in Virginia, Colorado, and Connecticut, and states with similar privacy laws may request an appeal, by notifying us through our privacy rights portal by following the instructions provided with the response to the request.


(6) Right to be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the laws of Virginia, Colorado, Connecticut and other states with similar privacy laws.

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