Last Updated: 09/01/2022
SECTION 1 - INFORMATION WE COLLECT
Contact and account information, such as your first and last name, address, email address, and phone number. If you create an account with us, we will also collect your username and password.
- When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.
SECTION 2 - HOW WE COLLECT AND USE PERSONAL INFORMATION
We may collect personal information as follows:
- to maintain, administer, and service the Site and to offer and provide the services;
- to process transactions and fulfill orders;
- to provide customer service, including to contact and communicate with you in connection with the services and to address and respond to inquiries or requests;
- to develop and improve the Site and services, including to better tailor the features, performance, and support of our Site and services, for research, statistical, and analytics purposes, and for marketing and advertising purposes, including to send you marketing communications;
- to make inferences drawn from your use of the Website, which may be used to enable interest-based advertising;
- for security purposes and for fraud, loss, and other crime prevention purposes, to assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights, interests, and property, or the rights or safety of third parties;
- for debugging purposes to maintain and improve the Site;
- to enforce agreements or to comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.
SECTION 3 - HOW WE MAY SHARE INFORMATION
Vendors and Partners: We share personal information with our vendors, consultants, payment processors, and other technology and service providers who need access to such information to carry out work on our behalf in the provision of the services, including for technical and processing functions, technical and customer support and communications, analytics, and for our direct marketing and advertising purposes.
Legal and Compliance: We may share personal information with government entities and agencies, regulators, law enforcement, and other third parties, including to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or pursuant to legal process, and to establish or exercise our legal rights or for fraud- or crime-prevention purposes.
Protection of Rights and Interests. We may share personal information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company or other third parties, and to investigate, detect, or prevent against fraud or other illegal activity.
We automatically collect the Internet Protocol (“IP”) address associated with your computer when you visit our Website, and we also collect device information and usage information, as described above. This information is used to help us administer the Website, remember your preferences, and diagnose technical problems. We also analyze the information for aggregate trends about how our Website is used and to help improve our Website.
Cookies, as well as other tracking technologies, such as HTML5 local storage and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data. We may also use web beacons or “pixels,” and in certain circumstances may collect IP address, screen resolution, browser software, and operating system types, clickstream patterns, dates and times that our site is accessed, the referring site from which you linked to our Website, and other categories of data related to interactions with our Website.
Third Party Cookies and Tracking
We use third-party service providers to assist us in collecting and understanding usage information and serving advertising. Most browsers can be set to detect browser cookies and to let a user reject them, but refusing cookies may affect usability and functionality of our Website. To learn more about browser cookies, including how to manage or delete them, refer to the “Tools,” “Help,” or similar section of your web browser.
We and our third parties, as well as other companies not affiliated with us, including ad networks, web analytics companies, and social networking platforms, may use tracking technologies, such as those described above, to collect information about your online activities over time and across our and other websites. We and they may use this information to infer your interests, to deliver targeted advertisements, such as those based on your browsing activities, and to measure the effectiveness of our advertising.
As with most sites, we do not honor “do not track” signals transmitted by web browsers as there is no industry standard for implementing such programs. For more information about third-party advertisers and how to prevent them from using your information, visit the NAI’s consumer website at http://www.networkadvertising.org/choices or http://www.aboutads.info/choices/. If you do want to opt out using these tools, you need to opt out separately for each of your devices and for each web browser (such as Chrome, Edge Firefox, Safari or others) that you use on each device.
SECTION 5 – LINKS TO THIRD-PARTY SITES
SECTION 6 - SOCIAL NETWORK WIDGETS
Our Sites may include social network sharing widgets that may provide information to their associated social networks or third-parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. If you use social network tools or visit social networking sites, we encourage you to read their privacy disclosures to learn what information they collect, use, and share.
SECTION 7 – INFORMATION ABOUT CHILDREN
Our site is not intended for children under the age of 13, and we do not knowingly collect personal information from individuals under the age of 13 years. If you become aware that an individual under 13 years of age has provided us with their personal information please contact us at firstname.lastname@example.org. If we become aware that an individual under 13 years has provided us with their information we will take steps to promptly remove the data as permitted by law.
SECTION 8 - DATA SECURITY
To protect your personal information, we implement technical, and organizational measures to help protect against improper access, use, alteration, or destruction of personal information. Please note, however, that we cannot fully eliminate security risks associated with the storage and transmission of personal information.
SECTION 9 – UPDATING YOUR COMMUNICATIONS PREFERENCES AND WITHDRAWING CONSENT
If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these e-mail communications. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices. If you have opted-in to receiving SMS/text messages from Adina Eden, you may opt-out at any time by following the instructions in the message and texting “STOP.” For additional assistance with unsubscribing to these communications, you may also contact us as at email@example.com.
Please note that if you do not provide consent, if you withdraw your consent or object to processing, or if you choose not to provide certain personal information, we may be unable to provide some or all of the services.
SECTION 10 – DATA RETENTION
We retain personal information for as long as is necessary to fulfill the purposes for which we obtained the personal information, including to provide the services, or for such longer period as may be required or permitted by applicable law. We will also retain personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and policies. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the purposes for processing your personal information and associated legal bases; (iii) the existence of a legal obligation as to the retention period; (iv) our contractual obligations; and (v) the advisability of retaining the information in light of our legal position (for example, applicable statutes of limitations, litigation, or regulatory investigations).
SECTION 11 – TRANSFER OF DATA TO U.S.
Please note that if you are visiting the Site from outside of the United States, your information may be transferred to, stored, and/or processed in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. If you are located outside of the United States, the transfer of personal information may be necessary to provide you with the requested information and services and/or to perform any requested transaction. By accessing the Site, you acknowledge and consent to the transfer of your information to our facilities in the United States.
SECTION 12 - ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act (CCPA) provides California residents with certain rights regarding their personal information. This section provides additional information regarding our collection and sharing of personal information under the CCPA, describes your CCPA rights, and explains how to exercise them.
Categories and Sources of Personal Information We Collect and Share
Categories of personal information we collect
Categories of sources from which the personal information is collected
Business or commercial purpose for collecting or selling personal information
Categories of third parties with whom we share personal information
Specific pieces of personal information we have collected
Sale of Personal Information
The CCPA requires businesses to disclose to California consumers if their personal information is “sold” as defined under the CCPA and to provide a mechanism for those consumers to opt-out of the sale of their personal information. We may share certain information such as a unique identifier (e.g., your device ID) with third parties for targeted advertising and online behavioral advertising purposes, which may be interpreted to be a “sale” as it is broadly defined under the CCPA. You can opt-out of the “sale” of your personal information by submitting your request here, or by accessing the “Do Not Sell My Personal Information” link available at the bottom of our Website. For additional information regarding your rights under the CCPA, see the following CCPA Privacy Rights section.
CCPA Privacy Rights
California residents have certain rights with respect to their personal information. You may be entitled by applicable law to exercise the following rights with respect to your personal information:
Right to Know and Access Information: You have the right to request what personal information we maintain about you. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business. This may include what personal information we collect, use, or disclose about you. We may not fulfill some or all of your request to access as permitted by applicable law.
Deletion of Information: You have the right to request that we delete your personal information. Depending on the scope of your request, we may refrain from granting your request, as permitted by applicable law. For example, we may be legally required to retain your information in our business records. You may submit a deletion request using the methods provided below.
Authorized Agent: California residents may use an authorized agent to exercise a privacy right on their behalf. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right listed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. To exercise rights on behalf of one of our users, please contact us at the contact information with supporting verification information, which includes a valid Power of Attorney in the State of California, proof that you have access to the consumer’s interface, and proof of your own identify.
How to Exercise Your Rights
To exercise the rights described above, you may submit your request at the below link or by contacting us using one of the following methods:
- Submit Your Request Online: Please click here
- Toll-Free Phone: 1-888-706-7859
- Mailing Address: Adina Eden, 1416 Avenue M, STE 501, Brooklyn, NY 11230
Your exercise of the rights described in this section is subject to certain exemptions and exclusions under the law. We will respond to authorized and verified requests as soon as practicable and as required by law. To protect your privacy and security, we may take steps to verify your identity in order to respond to your request. Should we need to collect additional personal information from you in order to verify your identity, we will only use that information for identity verification purposes, and shall delete it as soon as practicable after processing the request. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we deny or restrict your request and notify you of any reasons why we are unable to honor your request.
California “Shine the Light” Rights
If you are a resident of California, you may request certain information regarding our disclosure of personal information (if any) to third parties for those third parties' direct marketing purposes. To make such a request, please contact us at Adina Eden, 1416 Avenue M, STE 501, Brooklyn, NY 11230.
SECTION 13 - ADDITIONAL EU/EEA/UK DISCLOSURES
Subject to applicable law, individuals in the European Union (EU), European Economic Area (EEA), and United Kingdom (UK) have certain rights regarding your personal information, including the right to request confirmation from us as to whether or not we are processing your personal information. Where we are processing your personal information, subject to applicable law, you may also have the right to:
Request access to, modification of, or correction of your personal information. You have the right to request access to, modification of, or correction of your personal information. If you have registered for an account, you can also make changes to your personal information within your account settings.
Request deletion of your personal information. You have the right to request that we delete the personal information that we have collected about you.
Request restriction of processing. You have the right to request that we restrict processing of your personal information in certain circumstances, such as where you believe that the personal information we hold about you is inaccurate or our processing is unlawful.
Data portability. In certain circumstances, you may have the right to receive the personal information concerning you that you provided to us or to request that we transmit your personal information to another data controller.
Lodge a Complaint. You have the right to lodge a complaint with a supervisory authority.
To exercise your rights, submit your request here or contact us as at firstname.lastname@example.org. Your exercise of the rights described in this section is subject to certain exemptions and exclusions under the law. We will respond to authorized and verified requests as soon as practicable and as required by law. To protect your privacy and security, we may take steps to verify your identity in order to respond to your request. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we deny or restrict your request and notify you of any reasons why we are unable to honor your request.
Basis for Processing Personal Information
SECTION 15 - QUESTIONS AND CONTACT INFORMATION
For more information or if you have questions or concerns about our privacy practices, contact our Privacy Compliance Officer at email@example.com or by mail at:
Re: Privacy Compliance Officer
1416 Avenue M
Brooklyn, NY 11230