As of November 23, 2019
The information that we collect, and how we use and share that information:
What Personal Information Do We Collect?
We collect information about you in various ways when you use our Website. We collect certain information you voluntarily provide to us, such as when you join to receive a newsletter or other information from us, participate in community forums, send us an email, provide or request information, participate in surveys, register for sweepstakes or contests or post blog comments or other content on the Website. Such information may include Personal Information, such as your name, email address, and phone number.
When you visit our Website, some information is also automatically collected. For example, we log information such as your Internet Protocol (IP) address, operating system, browser type, address of a referring Website, and your activity on the Website. We treat this information as Personal Information if we combine it with, or link it to, any of the identifying information mentioned above. Otherwise, it is used only in the aggregate.
We may also automatically collect certain information through the use of “cookies” or web beacons. Cookies are small data files stored on your hard drive at the request of a Website. Among other things, cookies help us improve our Website and your experience. If we link cookies to any personally identifying information, we will treat this information as Personal Information. We do not use “cookies” to obtain Personal Information about any of our visitors. If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions. Most Internet browsers allow you to set them to warn you before a cookie is stored or block cookies altogether. However, if you choose to remove or reject cookies, this could affect certain features on our Website. Web beacons are small, invisible graphic images that may be used on the Website or in emails relating to the Website to collect certain information and monitor user activity on the Website.
We may receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Website through a third party application, such as an App Store or social network Website (“SNS”) such as Facebook, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS username, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business and Services.
Billing Information and Transaction Information.
If you purchase a Product through the Platform (such as the App Store on iOS or Android), you will be required to provide us with your name, billing address and shipping address. We use this information to process and ship your Product order(s), and you authorize us to share this information with suppliers of the Product(s) that you order, so that they can process and ship your order(s).
Certain features and functionalities of the Platform may be based on your location. In order to provide these features and functionalities while you are using a mobile device, we may automatically collect geo-locational information from your mobile device or wireless carrier and/or certain third-party service providers. Collection of this information occurs only when the Platform is running on your mobile device. You may decline to allow us to collect such information by adjusting your browser settings, in which case we will not be able to provide certain features or functionalities to you.
We use Google Analytics to collect information about visitor behavior on the Website. The Google Analytics Demographics and Interest Reporting feature allows us to identify trends in the usage of the Website which may be published in reports for internal use and to develop the Website and content around our visitors’ interests. We use Remarketing with Google Analytics to advertise online and make ads more relevant.
Demographics and Interests data comes from the third-party DoubleClick cookie for web traffic. Google Analytics stores information about what pages you visit, how long you are on the Website, how you got here and what you click on. We therefore do not use this tool to collect or store your Personal Information, so this information cannot be used to identify who you are.
We have also turned on Remarketing with Google Analytics. Remarketing cookies will be used by third parties (including Google) to show our ads on Websites other than our own. We use Google Analytics’ Remarketing cookies to serve more relevant ads on third-party Websites based on your past visits to our Website or other Websites. Google operates the DoubleClick online ad serving product, providing advertisers, web publishers and direct marketers with the tools needed to plan, execute, and analyze marketing programs with greater ease and efficiency. Note: Cookies placed by Google for behavioral advertising, including the opt-out cookie, will appear as DoubleClick cookies.
Opt-out of Google Analytics
Using the Ads Settings (www.google.ca/settings/ads), you can opt-out of both Google Analytics for Demographics and Interest Reporting and Remarketing with Google Analytics. In addition, you can use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics. Google is a Network Advertising Initiative (NAI) member, which is an organization committed to transparency and choice. The NAI opt-out tool was developed in conjunction with the Digital Advertising Alliance (DAA) for the express purpose of allowing consumers to “opt out” of the Interest-Based Advertising delivered by members on Web pages using cookies.
We may use data we receive from advertising technology partners to match multiple devices associated with the same identifier as devices belonging to the same user or household. Where we are able to make such a match, we may use this information to deliver targeted advertisements across multiple devices on behalf of ourselves or third parties.
In an ongoing effort to better understand users of our Website, App and Platform and the products, we might analyze your information in aggregate form to operate, maintain, manage, and improve our Website, App, Platform or products. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our Website, App and Platform to current and prospective business partners and to other third parties for other lawful purposes.
Purpose of Collection and Use
What Personal Information Do We Share with Third Parties?
We cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as: intellectual property rights, fraud and other rights. Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can (and you authorize us to) disclose your name, city, state, telephone number, email address and User ID history without a subpoena. Without limiting the above, in an effort to respect your privacy, we will not otherwise disclose your Personal Information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or report suspected illegal activity. Further, we can (and you authorize us to) disclose your name, street address, city, state, zip code, country, phone number, email, and company name to proper authorities under confidentiality agreement, as we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity.
We may also share Personal Information with our vendors, consultants, and other service providers (“Service Providers”) who are engaged by or working with us in connection with the operation of the Website and who need access to such information to carry out their work for us. In some cases, the Service Provider may be directly collecting information from you. We may also share Personal Information with other third parties when you give us your consent. We are not responsible for the actions of Service Providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties, and we encourage you to become familiar with their privacy practices before disclosing information directly to any such parties. Nothing herein restricts the sharing of aggregated or anonymized information, which may be shared with third parties without your consent.
In the course of doing business, we may employ other companies to perform a variety of functions on our behalf. For example, at times we may retain third parties to analyze, update and correct data we collect on our Website, including Personal Information, to help us improve our products, our database and our Website. In addition, we may share Personal Information with agents, suppliers, fulfillment houses and other third parties to allow delivery of awards, information, products or services. These suppliers and other third parties may have access to your Personal Information if it is needed to perform their functions for us, but they are not authorized by us to use your Personal Information in any way other than the intended use.
You agree that we may use Personal Information about you to improve our marketing and promotional efforts, to analyze Website usage, improve our content and product offerings, and customize the Website’s content, layout, and services. These uses improve the Website and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Website.
Opt-Out for Direct Marketing; Email Management
You may opt out at any time from the use of your personal information for direct marketing purposes by emailing us at email@example.com. Please allow us a reasonable time to process your request.
You may manage your receipt of marketing and non-transactional communications by clicking on the “Manage Email Preferences” link located on the bottom of any Solid Starts marketing email and following the instructions found on the page to which the link takes you. You cannot opt out of receiving transactional e-mails related to your Registered User account or any Product orders.
Links to Other Websites
What Steps Do We Take to Protect Your Information Online?
Solid Starts takes reasonable measures to protect your Personal Information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission that can be guaranteed against any interception or other type of misuse. Notwithstanding the foregoing, we cannot guarantee the security of any information you disclose online, and you do so at your own risk.
To protect the confidentiality of Personal Information, you must keep your password, if one is required, confidential and not disclose it to any other person. You are responsible for all uses of our Website by any person using your password. Please advise us immediately if you believe your password has been misused. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Website or sending an e-mail to you. You may have a legal right to receive this notice in writing.
What Choices Do You Have Regarding the Use of Your Information?
You may “opt out” of receiving promotional emails from Solid Starts by following the instructions in those emails. You may also opt out of such emails by emailing us at firstname.lastname@example.org. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
You may provide information to us via a support request submitted through the Website. We will use this information to assist you with your support request and may maintain this information to assist you or other users with support requests. Please do not submit any information to us via a support submission, including confidential or sensitive information that you do not wish for us or our Service Providers to have access to or use in the future.
INFORMATION THAT YOU SHARE THROUGH THE PLATFORM
ACCESS TO YOUR PERSONAL INFORMATION
RETENTION OF PERSONAL INFORMATION
From time to time, portions of our Website may allow you to post information which other visitors to the Website will be able to access (such as on a “forum” or chat room). In the event that you choose to post information in this context, it becomes generally available to the public, and we have no ability to control or limit its use by visitors to our Websites. Therefore, we encourage you not to post any information you consider private or sensitive on our Website.
Important Note to Children under the ages of 13 and 18
If you are between ages 13 and 18, before providing your name, address, email address or any other Personal Information to anyone on the Internet, be sure to ask your parents’ or legal guardian’s permission.
Our Website is not intended for and we do not knowingly collect information from children under the age of 13. If you believe that your child has registered with our Website or that we have collected information from your child, please contact us immediately so that we can remove that information from our database.
IMPORTANT NOTICE TO NON-US RESIDENTS
The laws and regulations in different countries impose different requirements on the Internet and data protection. We are located in the United States, as are the servers that make our Website available worldwide. All matters relating to our Websites are governed by the laws of the State of New York and the United States. If you are located outside of the United States, please note that any information you provide will be transferred to the United States, which may not have privacy laws similar to those in your own country, and that by submitting the information you authorize this transfer. All Personal Information collected by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you explicitly consent to the storage of your Personal Information in these locations
Rights of Access, Rectification, Erasure, And Restriction
Visiting our Website from the European Economic Area (EEA)
The Legal Basis for Using European Personal Information
When we collect information about you through our Website, the legal basis on which we process your Personal Information is fulfillment of an agreement between us, namely, to provide you with products and services, to purchase or review products, and other information marketing our products. We may also send certain communications because we have a legitimate business interest in making such marketing communications to you. When we use your Personal Information outside of what is strictly necessary for that transaction, we are doing so toward our legitimate interest of informing you of related products and promotions.
To the extent that we transfer Personal Information from the EEA to a jurisdiction outside the EEA that has not been adduced by the European Commission as providing adequate data protections (such as the US), the basis for such transfer is the necessity of providing you with information, products, or services you have requested.
Rights for EEA Residents
In addition, if you are a resident of the EEA, you have the right to:
Find out if we use your Personal Information, to access your Personal Information, and receive copies of your Personal Information;
Withdraw any express consent that you have provided to the processing of your Personal Information at any time without penalty;
Access your Personal Information and have it corrected or amended if it is inaccurate or incomplete;
Obtain a transferable copy of some of your Personal Information which can be transferred to another provider when the Personal Information was processed based on your consent.
If you believe your Personal Information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
These provisions are intended to comply with the EU General Data Protection Regulation requirements.
Request your Personal Information be deleted or restricted under certain circumstances. For example, if we are using your Personal Information on the basis of your consent and have no other legal basis to use such, you may request your Personal Information be deleted when you withdraw your consent. If you wish to exercise any of these rights or raise a complaint on how we have handled your Personal Information, please contact us at email@example.com.
California residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their Personal Information for direct marketing purposes during the preceding calendar year and the categories of Personal Information shared with those third parties. If you are a California resident and wish to obtain that information, please submit your request by sending us an email at firstname.lastname@example.org with “California Privacy Rights” in the subject line.
Manage Your Personal Information; Unsubscribe
We offer you the ability to automatically review and change the information you submit to us by logging into the Website and entering in the new information yourself. Generally, we will not modify your Personal Information based on your request because it is very difficult to authenticate your account manually. You can change your User ID, email address, contact information and user preferences by accessing the preferences and setup section of the Website. You must promptly update your Personal Information if it changes or is inaccurate. Once posted, you may not be able to change or remove any public postings made on the Website including our chat rooms or other message areas.
Upon your request, we will deactivate your account and all associated information from our active databases. Such information will be deactivated as soon as reasonably possible based on your account activity and in accordance with our deactivation policy and applicable law.
HOW TO CONTACT US
E-mail us at: email@example.com.
Or write to us at:
Solid Starts LLC, c/o Jenny Best, 315 Flatbush Avenue #353, Brooklyn, NY 11217