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Privacy Policy

MONEY PRODIGY PRIVACY POLICY

INTRODUCTION

This Privacy Policy provides you with details of how Frugal Confessions, LLC (“we”, “us” or our”) collects  and process your Personal Data (“Personal Data”) through your use of our site at https://www.moneyprodigy.com (the “Website”). This Privacy Policy only applies to this Website.  This Privacy Policy does not apply to information of any kind that we collect by means (including offline means) or from sources other than those specified herein. If you choose to use the Website, your use is hereby deemed acceptance of our practices described in this Privacy Policy.

We are the data controller and we are responsible for your Personal Data. We may revise and update this Privacy Policy at any time. Your continued usage of the Website will mean you accept those changes. By providing us with your data, you warrant to us that you are over 18 years of age.

Contact Details

Our full details are:

Full name of legal entity: Frugal Confessions, LLC

Email address: [email protected]

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected]

WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymized data.

We may process the following categories of Personal Data about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our Website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • User Data that includes data about how you use our Website and any online services together with any data that you post for publication on our Website or through other online services. We process this data to operate our Website and ensure relevant content is provided to you, to ensure the security of our Website, to maintain back- ups of our Website and/or databases and to enable publication and administration of our Website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our Website and our business.
  • Technical Data that includes data about your use of our Website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our Website, page views and navigation paths, details about the number of times you use our Website, time zone settings and other technology on the devices you use to access our Website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our Website and other online services, to administer and protect our business and Website, to deliver relevant Website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our Website and our business and to grow our business and to decide our marketing strategy.
  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant Website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
  • We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant Website content and advertisements to you (including Facebook ads or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Where we are required to collect Personal Data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your Personal Data as indicated herein. For more information on this please email us at [email protected] In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your Personal Data without your knowledge or consent where this is required or permitted by law.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences. At no time should you submit sensitive personal information to the Website. If you elect to submit such information to us, it will be subject to this Privacy Policy.

HOW WE COLLECT YOUR PERSONAL DATA

•     Information You Voluntarily Submit to the Website: The Website may collect personal information from you such as your name or email address. For example, you may voluntarily submit information to the Website by leaving a comment, subscribing to a newsletter, or submitting a contact form.  Personal Data may include, but is not limited to, your name, email address and phone number.

Our legal basis for processing this information is your consent, and by voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us, you acknowledge and agree that such Personal Data may be transferred and stored from your current location to our offices and servers and the authorized third parties referenced below.

•     Information We Collect from Others: The Website may receive information about you from other sources. For example, if you use a third-party software through the Website, they may transfer information to us for fulfillment. We do not control the data privacy or protection policies of third parties, and we are not responsible for the privacy practices of these third parties. Our legal basis for processing this information is our legitimate interests, namely monitoring and improving our services, and the legitimate interests of our customers.

•     Automatically-Collected Information: The Website automatically collects certain information about you and the device with which you access the Website. For example, when you use the Website, The Website will log your IP address, operating system type, browser type, referring Website, pages you viewed, and the dates/times when you accessed the Website. The Website may also collect information about actions you take when using the Website, such as links clicked.

•     Cookies: The Website may log information using cookies, which are small data files stored on your browser by the Website. The Website may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website.

LEGAL BASES FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

We are responsible as a “controller” of your Personal Data under the GDPR and below are the types of lawful basis that we will rely on to collect and process your Personal Data:

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected]
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
  • Consent means where you have consented to a certain use of your Personal Data.
  • Vital Interest means processing your Personal Data to protect the vital interests of the data subject or another natural person.

How to File a GDPR Complaint.

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

MARKETING COMMUNICATIONS 

Our lawful ground of processing your Personal Data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

Before we share your Personal Data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by clicking the unsubscribe link on any marketing message sent to you OR by emailing us at [email protected] at any time.

If you opt out of receiving marketing communications this opt-out does not apply to Personal Data provided as a result of other transactions, such as purchases, warranty registrations etc.

THIRD-PARTY USE OF PERSONAL INFORMATION

We may share your Personal Data with certain third parties as set forth below:

Third Party Vendors: We may share your information with third party vendors or service providers who help us provide our products or services or the Website, including database hosting and data processing services, and assist us in responding to requests by you for information that you request.

Parent Companies and Affiliates: We may share your information with a parent company, any subsidiaries, joint ventures, or other companies under a common control provided that we require them to honor this Privacy Policy.

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We may also share Personal Data with potential buyers. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Related Companies: We may also share your Personal Data with our related companies for purposes consistent with this Privacy Policy.

Third Parties with Permission: We may share your information with third parties to whom you ask us to send your information.

Agents, Consultants, and Related Third Parties: We, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our customer contracts.

The Website may share your information with third parties when you explicitly authorize us to share your information. Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider's use of your personal information is dictated by their respective privacy policies. The Website currently uses the following third-party service providers:

•     Google Analytics – this service tracks Website usage and provides information such as referring Websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics.

•     Quantcast – this service tracks Website usage and provides demographic information to us. This service may capture your personal information. 

  • ConvertKit – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications.

•     Mediavine – this service is used to manage our display advertisements. Please see the display advertising section for more information about data collection.

•     Grow – this service is used to all users to share Website content on user’s social channels.  Grow will connect using the user’s social channels, but no information is stored on the Website.

  • PAYMENT PROCESSOR – this service is used to serve our ecommerce platform. At no time is your banking information passed to the Website. We receive only information used for order fulfillment. 

•     OTHER THIRD-PARTY SERVICE PROVIDERS – DESCRIBE HOW YOU USE THE SERVICE PROVIDER AND WHAT INFORMATION YOU RECEIVE.

At this time, your personal information is not shared with any other third-party service providers. This list may be amended from time to time in the Website's sole discretion.

Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

WHERE YOUR DATA IS HELD

Personal Data may be held at our offices and those of our affiliates, parent or related companies, third party agencies, service providers, representatives and agents as described above (see: “Third Party Use of Personal Information”).

Some of these third parties may be based outside the European Economic Area.

DATA SECURITY

We have put in place security measures to prevent your Personal Data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your Personal Data only to those employees and partners who have a business need to know such data. They will only process your Personal Data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach if we are legally required to.

DATA RETENTION

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they stop being customers.

In some circumstances we may anonymize your Personal Data for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Furthermore, anonymous data may be provided to other parties for marketing, advertising, or other uses. Examples of this anonymous data may include analytics or information collected from cookies.

YOUR LEGAL RIGHTS

Under laws in certain countries in which we operate, customers and other visitors to our Website from those countries have a right to access Personal Data about themselves, and to amend, correct or delete Personal Data that is inaccurate, incomplete or outdated.  We will, upon request, provide you with confirmation regarding whether we are processing Personal Data about you, consistent with applicable law. In addition, upon your request, we will take reasonable steps to correct, amend, or delete your Personal Data that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Privacy Policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise inconsistent with applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Data that you request.

Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated within a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.

You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us as to which you have not instructed us to take such action. Please remember, however, that if we have already disclosed some of your Personal Data to third parties, we cannot access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.

Opt-out – If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications. You may also notify us at [email protected] to be removed from our mailing list.

Access – You may request access to the personal information we have about you by submitting a request to [email protected]

Amend – You may contact us at [email protected] to amend or update your personal information.

Forget – In certain situations, you may request that we erase or forget your Personal Data. To do so, please submit a request to [email protected]

Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions, or when required by law.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

THIRD-PARTY LINKS

This Website may include links to third-party Websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the Privacy Policy of every Website you visit.

COOKIES

The Website uses cookies to store visitors' preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, customize content based on visitors' browser type or other information that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics, as described herein.

What are cookies?

A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a Website can remember some information about your browsing activity on the Website.  The cookie will collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from third party site, the URL of the linking page.

In addition to cookies, the Website may use web beacons.  Web beacons allow us to count the number of users who have visited or accessed the Website and to recognize users by accessing our cookies. We may employ web beacons to facilitate Website administration and navigation, to track the actions of users of the Website, to compile aggregate statistics about Website usage and response rates, and to provide an enhanced online experience for visitors to the Website. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color.  A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF, and tracker GIF.

What are the different types of cookies and how do we use them?

Essential – These are cookies which are essential for the running of the Website. Without these cookies, parts of the Website would not function.  These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

Examples of how we may use essential cookies include:

  • Setting unique identifiers for each unique visitor, so that Website numbers can be analyzed.

Functional – These cookies are used to remember your preferences on the Website and to provide enhanced, more personal features. The information collected by these cookies is usually anonymized, so we cannot identify you personally.  Functional cookies do not track your internet usage or gather information which could be used for selling advertising.

Examples of how we may use functional cookies include:

  • Gathering data about visits to the Website, including numbers of visitors and visits, length of time spent on the Website, pages clicked on or where visitors have come from;
  • Eliminating the need for returning users to re-enter their login details.

Analytical Performance – Analytical performance cookies are used to monitor the performance of the Website, for example, to determine the number of page views and the number of unique users our Website has. We use this information to improve user experience or identify areas of the Website which may require maintenance.  The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.

Examples of how we may use analytical cookies include:

  • Measuring users’ behavior;
  • Analyzing which pages are viewed and how long for and which links are followed to better develop the Website.

Advertising – Behavioral advertising cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a Website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on Websites more relevant to you.  Although behavioral advertising cookies can track your activity around the internet, these cookies cannot identify you personally.  

Examples of how we may use advertising cookies include:

  • providing advertising to you and enabling us to manage our relationship with those advertisers by, for example, tracking how many unique users have seen a particular advertisement or followed a link in an advertisement.

Third Party cookies – You may notice on some pages of the Website that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own cookies on your device. We do not control the use of these third party cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them. Please check the third party Websites for more information about these cookies.

Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if you deactivate the setting of cookies in your Internet browser, not all functions of our Website may be entirely usable.

How can you manage or opt-out of cookies?

Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control cookies. In some cases, you can choose to accept cookies from the primary site, but block them from third parties. In others, you can block cookies from specific advertisers, or clear out all cookies. Deleting or blocking cookies may reduce functionality of the Website. To learn more about how to reject cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted cookies, you should contact the supplier of your web browser.

Opting out of Analytical Performance Cookies

If you would like to opt out of Analytics cookies, please do so by clicking on the links below:

Google Analytics: https://tools.google.com/dlpage/gaoptout.

Opting out of Behavioral Advertising Cookies

If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out. 

CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE

California Consumer Privacy Act (hereafter, “CCPA”) is a California privacy law that is effective as of January 1, 2020.

The privacy statements and sections present in this CCPA notice apply solely to Website users, visitors and customers (purchasers) who reside in the State of California (hereafter, “consumer”, “consumers”, “you”).

Under CCPA, California consumers have several added rights and privileges that serve to protect their personal information from being used in a way that the consumer does not agree with. This notice is in place to comply with the California Consumer Privacy Act (CCPA) of 2018 that went into effect as of January 1, 2020.

A consumer has the right to request and know what categories of information and what personal information we collect, how we collect it, and for what purpose we collect it. Please note that we are not required to:

•     Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

•     Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information.

CONSUMER’S RIGHT TO DEMAND DISCLOSURE

You have the right to demand that we disclose what categories of information we have or are collecting about you and what personal information we have collected or are collecting about you.

In an effort to maintain full compliance, we are disclosing the categories of information that we generally collect from and/or about consumers.

As a consumer, you are free to request disclosure of your information at no extra charge to you if you make such requests no more than twice (2) during a twelve (12) month period.

General Information We Collect

We generally collect personal information, as listed under CCPA, in the form of your first name and email address when you use an optin form, and what Google Analytics collects.

We collect the consumer information stated above through Google Analytics and opt-in forms.

You have the right to request disclosure of the personal information we collected about you by contacting us at: [email protected]

CONSUMER’S RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

Under CCPA, a consumer has the right to contact the business that collected personal information about the consumer and request deletion of that information.

There are certain limited circumstances under which the business does not have to comply and delete the information, as follows:

1.    Complete the transaction for which we collected the personal information, 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.

2.    Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3.    Debug products to identify and repair errors that impair existing intended functionality.

4.    Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5.    Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6.    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.

7.    Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8.    Comply with a legal obligation.

9.    Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

CONSUMER’S RIGHT TO DEMAND DISCLOSURE IN CASE OF SALE

As a consumer, you have the right to request full disclosure if a business sells or transfers your personal information for a business purpose. You have the right to know what specific information has been sold or transferred, to whom, and for what business purpose.

We do not sell personal information we collect from consumers.

However, in the event we do so within the next twelve (12) months, you will be given the option to opt out if you do not wish for your personal information to be sold.

The consumer has the right to request that we disclose what category of information we sold, the specific pieces of information we sold, to whom we sold it, and for what business purpose we sold it. Consumers can make this request by contacting us at: [email protected]

CONSUMER’S RIGHT TO REQUEST THAT A BUSINESS DOES NOT SELL THEIR INFORMATION

Under CCPA, a consumer has the right to request that a business that collected personal information about the consumer does not sell that information to anyone.

In our efforts to comply with the CCPA, you can find a “Do Not Sell My Personal Information” link in the footer of our Website. If there is a field asking for your email address, please be sure to include the same email you opted in with.

If and when you select “Do Not Sell My Personal Information,” you will be marked as an opt out. Therefore, you can be sure that your personal information and other general data collected about you will never be sold.

OUR BUSINESS WILL NOT DISCRIMINATE AGAINST ANY CONSUMER

If you choose to exercise your right and request that we never sell your information, in accordance with CCPA, we will not and cannot discriminate against you for choosing to exercise your right.

We will not discriminate against you for exercising any of your CCPA 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; or

•     Suggest that you may receive a different price or rate for goods or services or a different level or      quality of goods or services.

SECURING YOUR PERSONAL INFORMATION

Under CCPA, a business that collects or receives personal information about a consumer must implement and maintain reasonable security procedures and practices.

If a business experiences a data breach, then it will be held liable if it did not implement and maintain reasonable security procedures and practices.

We do our due diligence and maintain reasonable security procedures and practices to make sure that the consumer data and private information we collect is safe and secure.

Here are the security practices we have in place to protect consumer data:

  • All the systems containing consumer information (such as our email service provider) are password protected.
  • The passwords are considered strong and are not easy to figure out.
  • Only one (1) person knows the password.
  • To make our Email Service Provider database even more secure, we change the password every six (6) months.
  • Our computers are protected from third-party access by having an additional password layer before a user can start working on the computer.
  • In addition to the statements above, we take reasonable precautions on a daily basis to protect consumer information from unauthorized use, modification, destruction, and disclosure.

CHILDREN UNDER 16

We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. 

CONTACT US

If you wish to exercise your rights under CCPA and make requests for disclosure or deletion of your personal information or disclosure about sale of information, you can contact us directly and make a verifiable request. You can also contact us at any time if you are not happy about the way we are handling your data.

Please keep in mind that we do not have to comply with requests if you make them more than twice during a twelve (12) month period.

Make your requests by contacting us at: [email protected]. The verifiable consumer request must:

•     Provide sufficient information that allows us to reasonably verify you are the person about            whom we collected personal information or an authorized representative.

•     Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To respond to your request or provide you with personal information, we must verify your identity or your authority to make the request.  We will only use personal information provided in a verifiable request to verify the requestor's identity or authority to make the request.  For instructions on exercising sale opt-out rights, please refer to the Do Not Sell My Personal Information Page.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.  However, you may change your mind and opt back in to personal information sales at any time by e-mailing us at [email protected]  Consumers who opt-in to personal information sales may opt-out of future sales at any time.

We will respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.

CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE
We do not knowingly collect any information from anyone under 13 years of age. Our Website, products and services are all directed to people who are at least 16 years old or older. We require that anyone under 18 years of age participate and use our Website, products or services only with parental permission and supervision.

We do not intend to collect any personal information from children under the age of 18. If a parent or guardian of a child who has provided us with such personal information would like the information deleted from our records, he or she should contact us at the email address listed at the bottom of this policy statement. We will then use best efforts to delete the child's personal information from our files.

If we become aware that personally identifiable information regarding a child under the age of 13 has been collected at the site, we will use such information for the sole purpose of contacting a parent or guardian of the child to obtain verifiable parental consent. If we cannot obtain consent after a reasonable time, or if when contacted a parent or guardian requests that we do not use or maintain such information, we will make reasonable efforts to delete it from our records. Upon request by a parent or guardian, we will provide a description of the specific types of personal information collected from a child who is under the age of 13.

If we become aware that personally identifiable information regarding a child under the age of 13 has been collected at the site, we will use such information for the sole purpose of contacting a parent or guardian of the child to obtain verifiable parental consent. If we cannot obtain consent after a reasonable time, or if when contacted a parent or guardian requests that we do not use or maintain such information, we will make reasonable efforts to delete it from our records. Upon request by a parent or guardian, we will provide a description of the specific types of personal information collected from a child who is under the age of 13.

ADVERTISING

Display Ads

We may use third-party advertising companies to serve content and advertisements when you visit the Website, which may use cookies.  No personally identifiable information is shared with the Website's ad providers.  If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit http://www.networkadvertising.org/managing/opt_out.asp.

The Website uses Mediavine to manage all third-party advertising on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a Website can remember some information about your browsing activity on the Website. The cookie may collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from a third-party site, the URL of the linking page.

First party cookies are created by the Website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the Website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at www.allaboutcookies.org/manage-cookies/.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Website.

The Website may collect IP addresses and location information to serve personalized ads and pass it to Mediavine. If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit http://www.networkadvertising.org/managing/opt_out.asp. You may also visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/# to learn more information about interest-based advertising. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

Mediavine partners with the following data processors:

  1. Pubmatic. You may find Pubmatic’s privacy policy through this link. The data collected on the Website may be transferred to Pubmatic and its demand partners for interest-based advertising. Statistical information and other non-cookie technologies (such as eTags and web or browser cache) may be used by third parties on this Website. Browser settings that block cookies may have no effect on these technologies, but you may clear your cache to delete such trackers. Data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected.
  2. Criteo. You may find Criteo’s privacy policy through this link. The data collected on the Website may be transferred to Criteo and its demand partners for interest-based advertising. Criteo may collect, access, and use non-identifying data to improve the Criteo Technology and other Criteo products, programs, and/or services. This non-identifying data may include on-site user behavior and user/page content data, URLs, statistics, or internal search queries. The non-identifying data are collected through the ad call and stored with a Criteo cookie for a maximum period of 13 months.
  3. Pulsepoint. You may find Pulsepoint’s privacy policy through this link.
  4. LiveRamp. You may find LiveRamp’s privacy policy through this link. When you use the Website, we share information that we may collect from you, such as your email (in hashed, de-identified form), IP address or information about your browser or operating system, with LiveRamp Inc, and its group companies (‘LiveRamp’). LiveRamp may use a cookie on your browser and match your shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email, in-app, etc.) by third parties unaffiliated with our Website. These third parties may in turn link further demographic or interest-based information to your browser. To opt out of LiveRamp’s targeted advertising, please go here: https://liveramp.com/opt_out/.
  5. RhythmOne. You may view RhythmOne’s privacy policy through this link. RhythmOne uses cookies and similar tracking technologies (such as mobile device identifiers and digital fingerprinting) to provide its services. RhythmOne may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit the following webpage: http://www.networkadvertising.org/managing/opt_out.asp.
  6. District M. You may find District M’s privacy policy through this link.
  7. YieldMo. You may find YieldMo’s privacy policy through this link. If you want to opt out of receiving interest based ads from Yieldmo or exercise your right under the California Consumer Privacy Act (“CCPA”) to opt-out of the sale of your personal information, you may do so through this link.
  8. The Rubicon Project. You may find Rubicon’s privacy policy through this link. If you want to opt out of receiving interest based ads from Rubicon or exercise your right under the California Consumer Privacy Act (“CCPA”) to opt-out of the sale of your personal information, you may do so through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page.
  9. Amazon Publisher Services. You may find Amazon Publisher Services’ privacy policy through this link.
  10. AppNexus. You may find the AppNexus privacy policy through this link.
  11. OpenX. You may find OpenX’s privacy policy through this link.
  12. Verizon Media formerly known as Oath. You may find Verizon Media’s privacy policy through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising.
  13. TripleLift. You may find TripleLift’s privacy policy through this link. To opt out of receiving interest-based advertising (including retargeting) from TripleLift’s services through the use of cookies in your current browser and for more information on what it means to opt-out, please go to www.triplelift.com/consumer-opt-out.
  14. Index Exchange. You may find Index Exchange’s privacy policy through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising.
  15. Sovrn. You may find Sovrn’s privacy policy through this link.
  16. GumGum. You may find GumGum’s privacy policy through this link. GumGum may (i) use place and use cookies on end users’ browsers or use web beacons to collect information about end users who visit such Publisher Websites and (ii) link such collected end user information to other end user information provided by third parties in order to deliver targeted Advertisements to such end users.
  17. Digital Remedy. You may find Digital Remedy’s privacy policy through this link.
  18. MediaGrid. You may find MediaGrid’s privacy policy through this link. MediaGrid may collect and store information about end-user interactions with this Website through cookies, advertising IDS, pixels and server-to-server connections. MediaGrid was receive the following information: the page an End-User has requested and the referring/exit pages; Timestamp information (i.e., the date and time the End-User has visited the page); IP address; mobile device identifier; device model; device operating system; browser type; carrier; gender; age; geolocation (including GPS coordinates); clickstream data; cookie information; first-party identifiers'; and hashed email addresses; demographic and inferred interest information; and post-conversion data (from both online and offline behaviour). Some of this data is gathered from this Website and others is gathered from advertisers. MediaGrid uses this data to provide its services. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising or review their privacy policy for more information.
  19. RevContent – You may find RevContent’s privacy policy through this link. RevContent may collect information about your browser or device, including browser type, IP Address, device type, user agent string, and operating system. RevContent also collects information about the Websites you visit through their services, such as date and time of access and specific pages accessed and the content and ads you click on. You may opt-out of any personalization track by opting-out of RevContent’s data collection.
  20. Centro, Inc. – You may find Centro’s privacy policy through this link. You may find opt-out information for Centro’s services through the privacy policy link.
  21. 33Across, Inc. – You may find 33Across’s privacy policy through this link. To opt-out of personalized advertising, please visit https://optout.networkadvertising.org/?c=1.
  22. Conversant. LLC – You may find Conversant’s privacy policy through this link. Conversant uses information that does not directly identify you, such as information about your browser type, time and date of visit, your browsing or transaction activity, the subject of advertisements clicked or scrolled over, and a unique identifier (such as a cookie string, or a unique advertising identifier provided by your mobile device) during your visits to this and other Websites and apps in order to provide advertisements about goods and services likely to be of greater interest to you. Conversant may use technologies such as cookies and other tracking technologies to collect this information. To learn more about interest-based advertising, or to opt-out, you can visit www.youronlinechoices.eu or https://www.networkadvertising.org/.

Retargeting Ads

From time to time, the Website may engage in remarketing efforts with third-party companies, such as Google, Facebook, or Instagram, in order to market the Website. These companies use cookies to serve ads based on someone's past visits to the Website. This means, after visiting the Website, you may see an ad for our services. However, your personally identifiable information is not used by any remarketing service other than to present you offers from us. We use the following third-party service providers for remarketing:

Facebook: Opt-out of Facebook remarketing here

Google: Opt-out of Google remarketing here

Sponsored Content Tracking Pixels

This Website may engage in sponsored campaigns with various influencer networks, brands, and agencies. All sponsored content is duly disclosed in accordance with the FTC's requirements. From time to time, these sponsored campaigns utilize tracking pixels (aka web beacons), which may contain cookies to collect data regarding usage and audience. This information is collected by the sponsoring company to track the results of the campaign. As stated above, these pixels may capture your IP address on behalf of the content sponsor. No personally identifiable information collected by the Website is used in conjunction with these tracking pixels.

Affiliate Program Participation

The Website may engage in affiliate marketing, which is done by embedding tracking links into the Website. If you click on a link for an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commissions. 

We are a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and linking to Amazon.com. As an Amazon Associate, I earn from qualifying purchases. This program utilizes cookies to track visits for the purposes of assigning commission on these sales.

Newsletters

On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows us to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.

ARBITRATION

This Privacy Policy will be governed and construed in accordance with the laws of the State of Texas. Any controversy or claim arising out of or relating to the Privacy Policy, or the breach thereof, shall be settled by arbitration administered by the American Arbitration Association (“AAA”) under its Commercial Arbitration Rules, and judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. The place of any such arbitration shall be in or near El Paso, Texas. The parties also agree that the AAA Optional Rules for Emergency Measures of Protection shall apply to the proceedings.

OTHER TERMS AND CONDITIONS

Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with us.  Please refer to those agreements as needed.

Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) protect, in an emergency, the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations in connection with credit risk reduction and fraud protection.

Changes to Our Privacy Policy

The Website may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and will notify you by email in advance of any changes, provided Website has your email address. Please review this policy periodically, and especially before you provide any Personal Data. Your continued use of the Website after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

CONTACT INFORMATION

At any time, please contact us at [email protected] for questions related to this Privacy Policy.

Last updated: March 31, 2021.