Last Reviewed: January 1, 2020
Effective Date: January 1, 2020
INFORMATION WE COLLECT
We may collect a variety of Personal Information from you or about you or your devices from various sources, as described below.
A. Personal Information
When you engage us for our Services or use our Services, we may collect different types of Personal Information depending on the Services and your relationship with us. This may include, but is not limited to:
· Email Address
· First and last name
· Phone Number
· Address, City, State, Province, ZIP/Postal code
· Usage Data
B. Usage Data
To help us understand how you use our Services and to help us improve them, we automatically collect usage data about your interactions with our Services
Usage Data may include, but is not limited to, information such as:
· Your Device’s Internet Protocol address (e.g. IP address)
· Browser type
· Browser version
· The pages of our Service that You visit
· The time and date of Your visit
· The time spent on those pages
· Unique device identifiers
· Other diagnostic data.
TRACKING TECHNOLOGIES AND COOKIES
We and third-party service providers use various processes and technologies to collect and store information, including cookies, pixel tags, clickstream data or similar technologies. We and our third-party service providers, such as, analytics and advertising partners, to collect and track information and to improve and analyze our Services.
A cookie is a small file containing a string of characters that is sent to your device when you visit a website. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. Learn more about cookies here.
- Strictly necessary cookies – These cookies enable services you have specifically asked for. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies certain services you have asked for cannot be provided
- Performance cookies – These cookies collect information on the pages visited. These cookies collect information about how users use a website, for instance which pages users go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. They are only used to improve how the website works.
- Functionality cookies – These cookies remember choices you make to improve your experience. These cookies allow the website to remember choices you make and provide enhanced, more personal features. The information these cookies collect may be anonymized and they cannot track your browsing activity to other websites.
- Targeting cookies or advertising cookies – these cookies collect information about your browsing habits in order to make advertising relevant to you and your interests
You have options to remove or disable cookies from your browser at any time. Please click here to learn more about how you can manage cookies for your browser.
DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL INFORMATION
Third-party service providers have access to your Personal Information only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party service providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
B. Email Marketing
We may use Email Marketing Service Providers to manage and send emails to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
Campaign Monitor is an email marketing sending service provided by the Campaign Monitor Pty Ltd.
Twitter advertising service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
Facebook advertising service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
Bing Ads advertising service is provided by Microsoft Inc.
You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Google Ads advertising service is provided by Google Ads Inc.
You can find instructions on how to block Google Ads interest-based ads by following their instructions: https://support.google.com/ads/answer/2662922?hl=en
D. Usage, Performance and Miscellaneous
We may use third-party service providers to provide better improvement of our Service.
We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.
The reCAPTCHA service may collect information from You and from Your Device for security purposes.
HOW WE USE INFORMATION WE COLLECT
We use the information we collect from you or about you or your devices:
· To provide, maintain, improve, and enhance our Services;
· To provide customer care and support;
· To provide you with updates and other information relating to our Services, provide information that you request, and respond to comments and questions;
· For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you, including interest-based ads and targeted ads;
· To facilitate transactions, billing and payment;
· To de-identify and aggregate information collected through our Services and use it for lawful purpose;
· To comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law;
· To detect, investigate and prevent potentially prohibited or illegal activities, including fraud, and respond to trust and safety issues that may arise;
· For any purpose with your consent.
We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the personal information.
The personal information processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to us, in some cases, the personal information may be accessible to certain types of persons in charge, involved with the operation of our Services (administration, sales, marketing, legal, system administration) or external parties (such as third-party service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as service providers to process on behalf of us (i.e. data processors).
THIRD PARTY WEBSITES:
Your information shall be processed and stored for as long as required by the purpose they have been collected for.
· Personal information collected for purposes related to the performance of a contract between us and you shall be retained until such contract has been fully performed.
We may be allowed to retain your information for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain your information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, your personal information shall be either deleted or anonymized.
California residents may have additional rights and choices. Please see Your Rights Under California Privacy Law section below for more information.
YOUR RIGHTS UNDER EUROPEAN PRIVACY LAW / ONLY FOR THOSE LOCATED IN THE EUROPEAN UNION
Our Services are solely for and directed to those located in the United States, and our website is maintained in the United States. If you are located outside of the United States, please do not attempt to use our Services or provide your Personal Information to us on our website or through our Services.
If you are located in the European Union, you have the right to do the following:
· Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
· Object to processing of your information. You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent.
Where Personal Information is processed for a public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.
· Access to your information. You have the right to learn if Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Personal Information undergoing processing.
· Verify and seek rectification. You have the right to verify the accuracy of your Personal Information and ask for it to be updated or corrected.
· Restrict the processing of your Personal Information. You have the right, under certain circumstances, to restrict the processing of your Personal Information. In this case, we will not process your Personal Information for any purpose other than storing it.
· Have your Personal Information deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us.
· Receive your Personal Information and have it transferred to another company. You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another company without any hindrance. This provision is applicable provided that the Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
· Lodge a complaint. You have the right to bring a claim before your component data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection right in accordance with applicable data protection laws.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
YOUR RIGHTS UNDER CALIFORNIA PRIVACY LAW / ONLY FOR CALIFORNIA RESIDENTS
This section is adopted to comply with the California Consumer Privacy Act of 2018 (CCPA) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this section. For the purpose of this section, Personal Information means 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.
A. Your Rights and Choices
· The categories of Personal Information we have collected about you.
· The categories of sources for the Personal Information we have collected about you.
- Our business or commercial purpose for collecting or selling your Personal Information.
- The categories of third parties with whom we share your Personal Information.
- The specific pieces of Personal Information we have collected about you (also referred to as data portability).
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
B. Information We Collect
In the past twelve (12) months, we collected the following categories of Personal Information regarding California residents:
- Identifiers (names, physical addresses, email addresses, phone numbers, online identification numbers, and online account names)
- Demographic information (age, race, gender, marital status, religious affiliation, military/veteran status, and national origin/ancestry)
- Posts and profiles on social media platforms
- Professional or Employment related information
- Inferences drawn from other personal information
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from documents that our clients provide to us related to the Services for which they engage us or wish to engage us.
- Indirectly from you. For example, when you open an email from us or submit an online form.
- Directly and indirectly from activity on our website. For example, your usage details on our website collected automatically.
- From third parties such as data partners. For example, we may receive demographic data, from data partners.
- From publicly available government records
- From information made freely available by individuals via a variety of online platforms
C. Use of Personal Information
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, updates, newsletters, and other notices concerning our products or services, or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- For targeted marketing and political consulting services we provide to our customers
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
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, 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 providers to:
- Complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty or product recall conducted with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, 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 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.
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:
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 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. 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 will not discriminate against you for exercising any of your California privacy 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.
ADDITIONAL RIGHTS UNDER CALIFORNIA’S SHINE THE LIGHT LAW / ONLY FOR CALIFORNIA RESIDENTS
ADDITIONAL INFORMATION ABOUT INFORMATION COLLECTION AND PROCESSING
Your Personal Information may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of our Services.
You declare to be aware that we may be required to reveal Personal Information upon request of public authorities.
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
We do not support “Do Not Track” requests and signals.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of your consent, we shall collect new consent from you, where required.
The data controller of your Personal Information, meaning the company that determines the purposes and means of the processing of Personal Information, including the security measures concerning the operation and use of the Services is:
Unearth Campaigns LLC
555 Capitol Mall, Suite 640
Sacramento, CA 95814
Email: [email protected]