What Information Do We Collect?
The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect, use, share, and/or display some of your Personal Information. We collect the following types of information from our users.
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual:
Postal address (including billing and shipping addresses)
Credit and debit card number
Social media account ID
Financial information required to invoice or pay you
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
Through the Site
We collect Personal Information through the Site, for example, when you sign up for a newsletter or make a purchase.
From Other Sources
We receive your Personal Information from other sources, such as publicly available databases;
Joint marketing partners, when they share the information with us
If you connect your social media account to your Site account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Site account.
Use of Personal Information
We and our service providers use Personal Information for legitimate business purposes, including:
Providing the functionality of the Site and fulfilling your requests.
To provide the Site’s functionality to you.
To respond to your inquiries and fulfill your requests.
To send administrative information to you, such as changes to our terms, conditions, and policies.
To allow you to send messages to a friend through the Site. By using this functionality, you are telling us that you are entitled to use and provide us with your friend’s name and email address.
We engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
To send you marketing communications that we believe may be of interest to you.
To facilitate social sharing functionality that you choose to use.
We engage in these activities with your consent, to the extent consent is required by applicable law.
Analysis of Personal Information for business reporting and providing personalized services.
To personalize your experience on the Site by presenting content, products, and offers tailored to you.
We provide personalized services either with your consent or because we have a legitimate interest.
Allowing you to participate in sweepstakes, contests or other promotions.
We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
Some of these promotions have additional rules, which could contain information about how we will use and disclose your Personal Information.
We use this information to manage our contractual relationship with you.
Aggregating and/or anonymizing Personal Information.
We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
Accomplishing our business purposes.
For data analysis, for example, to improve the efficiency of our Site.
For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
For fraud and security monitoring purposes, for example, to detect and prevent cyber attacks or attempts to commit identity theft.
For developing new products and services.
For enhancing, improving, or modifying the Site and our services.
For identifying usage trends, for example, understanding which parts of our Site are of most interest to users.
For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
For operating and expanding our business activities, for example, understanding which parts of our Site are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Disclosure of Personal Information
We disclose Personal Information:
To our third party service providers, to facilitate services they provide to us.
These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
To third parties like SendPulse, to permit them to send you marketing communications, consistent with your choices.
To third-party sponsors of sweepstakes, contests, and similar promotions.
By using the Site, you may elect to disclose Personal Information:
On message boards, chat, profile pages, blogs and other services to which you are able to post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
To identify you to anyone to whom you send a message via the Site.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
To comply with applicable law.
This can include laws outside your country of residence.
To respond to requests from public and government authorities.
These can include authorities outside your country of residence.
To cooperate with law enforcement.
For example, when we respond to law enforcement requests and orders.
For other legal reasons.
To enforce our terms and conditions; and
To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
In connection with a sale or business transaction.
We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual:
Server log files
Information collected through cookies, pixel tags, and other technologies
Demographic information and other information provided by you that does not reveal your specific identity
Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information
We and our service providers collect Other Information in a variety of ways:
Through your browser or device:
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type you are using. We use this information to ensure that the Site functions properly.
Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address can be identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
“Do Not Track” signals:
Using pixel tags and other similar technologies:
Pixel tags (also known as web beacons and clear GIFs) are used in connection with some Site pages and HTML-formatted email messages to, among other things, track the actions of Site users and email recipients, measure the success of our marketing campaigns and compile statistics about Site usage and response rates.
We collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We use your device’s physical location to provide you with personalized location-based services and content. We also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our service providers and/or marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we, our service providers and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
Information such as your preferred means of communication is collected when you voluntarily provide this information.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access or use the Site. For more information on our Parnters, please visit http://www.kargo.com/click-info/
You may receive advertisements based on information relating to your access to and use of the Site and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.
THIRD PARTY SITES OR SERVICES
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Please also be aware that we use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
Receiving marketing-related emails from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by clicking on the unsubscribe links provided in emails.
Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we not share your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by turning off this feature in any services we provide you.
Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes: If you would prefer that we not share your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt-out of this sharing by turning off this feature in any services we provide you.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that, if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access or change or delete your Personal Information
If you would like to request to review correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by writing to us at email@example.com or to Personal Information Request, free4allthemes, 3 Highlands close, Hounslow, United Kingdom, 3TW 4HA
In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
The length of time we have an ongoing relationship with you and provide the Site to you (for example, for as long as you have an account with us or keep using the Site);
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
USE OF SITE BY MINORS
The Site is not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Site you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you are located in the European Economic Area (comprised of the EU Member States, Iceland, Liechtenstein, and Norway, together “EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here https://ec.europa.eu/info/law/law-topic/data-protection_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below.
We ask that you not send us, and you not disclose, any sensitive Personal Information (for example, social security numbers, credit card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site or otherwise to us.
THIRD PARTY PAYMENT SERVICE
free4allthemes, 3 Highlands Close, Hounslow, United Kingdom, 3TA 4HA
Please note that email communications are not always secure; so please do not include credit card information or sensitive information in your emails to us.
ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA
If you are located in the EEA, you also may:
- Lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs.
What are my California privacy rights?
California’s “Shine the Light” law permits residents of California to request certain details about what personal information (as that term is defined in California Civil Code § 1798.83) a company shares with third parties for the third parties’ direct marketing purposes. Upon receipt of this notification, we will discontinue sharing your information for third party direct marketing purposes as soon as practicable.
The California Consumer Privacy Act, effective January 1, 2020, provides California “Consumers” with certain rights, as explained in our California Consumer Privacy Act Notice (“CCPA Notice”) below. Please review our CCPA Notice below for more information.
This CCPA Notice applies to “Personal Information” (also referred to herein as PI) of “Consumers” as defined by the California Consumer Privacy Act (“CCPA”).
We collect and share the following categories of PI from the corresponding sources and for the corresponding purposes set forth in the table below.
We do not knowingly “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a “sale” of your PI as defined by the CCPA. You can exercise control over browser-based cookies by adjusting the settings on your browser. Further, you can learn more about your choices regarding certain kinds of online interest-based advertising. We do not represent that these third-party tools, programs or statements are complete or accurate.
Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.
California Consumers have the right to exercise the privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.
Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
To make a request according to your rights to know or to request deletion of your PI set forth below, please email us at firstname.lastname@example.org, where you will find a form to complete so that we can verify your identity using your email address and browser ID and fulfill your request as required by the CCPA. For your specific pieces of information, if required by the CCPA, we will apply heightened verification standards, which may include a request to provide further information.
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of PI we have collected about you.
- The categories of sources from which we collected your PI.
- The business or commercial purposes for our collecting or selling your PI.
- The categories of third parties to whom we have shared your PI.
- The specific pieces of PI we have collected about you.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
- A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
- The categories of your PI we have sold.
- The categories of third parties to which we sold PI, by categories of PI sold for each third party.
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.
Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.