Effective Date: August 1,2020
I. INFORMATION WE COLLECT
Information Provided by You.
Registration and Membership. We will collect personal information from you when you visit our Site, sign up for our Services, interact with our Site, register with us, or use various features of our Site. We only collect your personal information as described herein and for the purposes described herein. In order to register on our Site, you must first complete the registration form providing contact information (such as name, email, and address). To become a member, you must also provide billing information (such as credit and/or debit card account information).
Surveys and Sweepstakes. From time to time, we may request information from users or members via surveys or sweepstakes. Participation in these surveys or sweepstakes is completely voluntary, and you therefore have a choice whether or not to disclose this information. Contact information may be used to notify the winners, award prizes, and file winners as required by law. Survey information will be used for purpose of the survey, including for the monitoring or improvement of the use and satisfaction of the Site.
Information Collected About Your Use of the Site and Services.
Web Logs. Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) in order to improve security, analyze trends, and administer the Site. We may track your movement within the Site and through our offers on affiliate websites, the pages from which you were referred, access times, and browser types. This information may include the browser you are using, the Internet address from which you linked to our Site, the operating system of your computer, the unique IP address of the computer you used to access our Site, and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness of our Site, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather broad demographic information.
Cookies. To help make sure you receive information that is relevant to you, our Site and advertisements on affiliate sites use data “cookies.” We use session cookies to make it easier for you to navigate our Site. A session ID cookie expires when you close your browser. We use persistent cookies to differentiate visitors to our Site from registered users and members, to customize the content of certain sections of the Site, and to enable us to track and cater to the interests of users, in order to enhance their experience on the Site. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Cookies help us learn which areas of our Site are useful and which areas need improvement. You may configure your browser to prevent cookies from being set on your computer. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site may be limited, and you may not be able to use certain features of the Site.
Web Beacons. Our web pages contain “web beacons.” Web beacons allow us to count users that have visited a web page or opened an email that contains a web beacon and collect other types of aggregate information. Using this information, we are able to measure the effectiveness of our advertising and how visitors use our Site. This allows us to learn what pages are most attractive to our visitors, which parts of our Sites are the most interesting, and what kind of offers our registered users like to see. Some of the web beacons that are in place on our Site are used only by us, and other web beacons are from our affiliates, vendors, and advertisers, which use this data to assist us in analyzing how our offers and Site are accessed and used.
Ad Serving. You may see certain ads on other websites because we work with advertising partners to engage in remarketing and retargeting activities. We and third parties may collect information about your online activities over time on our website to provide you with advertising about offers tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. For example, we may use Remarketing with Google Analytics Remarketing, Demographics and Interest Reporting and Google Display Network Impression Reporting. You can learn more about interest-based advertising and about the options available to limit these third parties’ collection and use of your information by visiting http://optout.aboutads.info/#!/ and http://optout.networkadvertising.org/#!/ .
Supplemental Information. We may supplement information you give us with information from other sources, such as information to validate or update your address, payment card, or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to enable us to fulfill our products and services, to target our communications so that we can inform you of products, services, and offers that may be of interest, and for internal business analysis or other business purposes. In the event that additional information is requested from a member to support a claim made under a specific benefit provided, we will use this information to validate the nature of the claim. This may include contacting the retailer where a purchase was made to verify that an item was purchased, the amount paid, if a benefit was utilized, or if an item has been returned.
II. HOW WE USE YOUR INFORMATION
We use your personal information for enrollment and billing purposes; to verify customer membership; to fill customer orders; to process and issue payments; and for any other purposes identified or implied at the time of collection or described in this Policy. If we have trouble processing an order or payment, the information may be used to contact you. When you provide us with information in connection with a particular activity or otherwise register for our Services or provide your contact information, including an email address or telephone number in connection with that activity, product, or service, you agree that this action constitutes a purchase or inquiry establishing a business relationship with us. You consent to us communicating with you regarding future information about our Services using the information you provided to us. With your consent, we may contact you with pre-recorded calls and calls and text messages to your mobile telephone number (including use of automated dialing equipment). We may also use any information that you provide to us to inform you of other company products and services, including reaching out to you if you started but did not complete a product registration process (where permissible).
Service Providers. We may use third-party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending emails, processing and approving orders, order fulfillment, processing and issuing payments, sweepstakes administration, and state filings. We may also work with third parties to serve ads to you as part of a customized campaign on other websites or platforms. We may share your personal and account information with these third parties for those limited purposes. Our third party service providers are required to agree with our privacy standards, and when required, provide information regarding their compliance to relevant privacy and security standards. Our service providers may be located outside of your country of residence, in which case that country’s courts, governments or law enforcement agencies could obtain disclosure of your information in accordance with that country’s laws.
Strategic Partners. We have entered into agreements with third-party-affiliated companies to enable us to provide our Services in connection with sales our members have made with those companies, such as shipping fees charged by those companies. In certain situations, we may provide your information to those companies informing them of your membership or to investigate a claim or inquiry regarding any benefit you may make pertaining to our Services and your interactions with those companies.
Other Uses: We may use your personal information to contact you about the Services on our Site for which you have expressed an interest; for example, if you have contacted customer service or made an inquiry. Unless prohibited by law, we may also use information you provide to us, such as your email address, when you start, but do not finish, the registration process for the Services.
Announcements. We may send you service-related announcements and emails from time to time relating to your account. These include emails such as order confirmations, renewal/expiration notices, and payment-card problem notifications. We may also send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if any service is temporarily suspended for maintenance, the delivery of a service is delayed, or if there is some service issue with something you might have requested, we might send you a notice. Even if you have opted out receiving marketing communications from us, please be aware that we may still contact you with these service-related messages.
Legal Matters; Safety. We may, without your express consent, access and disclose your information, any communications sent or received by you, and any other information that we may have about you or your account as may be permitted or required by law (including, but not limited to, court order or subpoena), or to prevent or investigate suspected fraud, violations of our Terms and Conditions, or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information in situations that we believe to be emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat.
III. ACCESS TO YOUR INFORMATION
Security. It is our intent to protect against the loss, misuse, or alteration of information that we have collected from you or received from a partner. We use a variety of current technologies and processes intended to protect our customer data. We limit the information we provide to outside companies with whom we contract to only what they need to carry out their responsibilities. It is our practice to use encryption whenever we receive or transmit sensitive data.
We protect the personal information within our custody or control with appropriate organizational, technological and physical safeguards. We store personal information in electronic and physical files that are secure, and our security measures include secure on- and off-site storage, restricted access to records and data processing equipment, password protocols, and encryption and security software. We conduct audits and monitor compliance with our privacy practices. For example, when you enter credit card information on our registration or order forms, we encrypt that information using Secure Sockets Layer technology (SSL). You can easily determine when you’re sending data securely by looking at the Web address (URL) in your browser window: The first few letters will change from “http” to “https” when you are transmitting information protected by SSL encryption (the “s” in “https” stands for “secure”).
However, despite our efforts, no system can completely guarantee that there will never be unauthorized access to your personal information, and your use of the Site indicates that you are willing to assume this risk.
V. CHOICE AND OPT OUT
Where applicable, we will seek your express consent to contact you, including by way of a commercial electronic message such as email or a text message. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the message, for example by clicking “Unsubscribe”. You can also remove your information from our database so as not to receive future promotional communications or to close your account by emailing us at firstname.lastname@example.org.
Please note that changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personal information removed from our database. We will endeavor to comply with your request as soon as reasonably possible.
Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the products or services we provide to you, or if you contact us with an inquiry.
VI. IMPORTANT DISCLOSURES, PRACTICES, AND CONTACT INFORMATION
Children’s Privacy. The Site is not directed or intended for children under 13 years of age. We do not knowingly collect Personal Information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide Personal Information on the Site.
Your California Privacy Rights. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the address referenced below.
A California consumer who has joined secretsbyshani.com may make the following requests as relates to their personal data under the rules of California Civil Code Section 1798.100 , using a process called an Individual Rights Request:
- Access: A consumer may request that Freeshipping.com disclose information collected about the consumer by secretsbyshani.com
- Correct: Once a consumer has access to their information, the consumer may request correction of their information maintained by secretsbyshani.com
- Delete: A consumer has a right to request deletion of personal information that secretsbyshani.com collected from the consumer
See below for the metrics required by Section 1798.185 of the California Civil Code (CCPA)
|Consumer Requests – Freeshipping.com|
|Reporting Period||Type||Number of Requests||Fulfuilled (%)*||Denied(%)**||Avg.Number of Days to Fulfill Requests|
|2019||Request to Know||0||N/A||N/A||N/A|
|Request to Opt-out †||0||N/A||N/A||N/A|
|Request to Delete||3||3 (100%)||0(0%)||7|
|† : This site does not sell consumer data; this metric is included in this table as required by law.|
|* : This site fulfills deletion requests through anonymization.|
|** :Requests may be denied for any of the reasons outlined in the CCPA, including but not limited to fraud prevention.|
|These metrics are provided as required under Section 1798.185 of the California Civil Code.|
SbS & Co.
Copyright (c), 2020, SbS & Co. All rights reserved.