Pink and Posey LLC Privacy Policy
Effective date: August 18, 2020
This Privacy Policy describes the data protection practices of Pink and Posey LLC (“PPLLC,” “we,” “us,” or “our”). PPLLC provides services to users throughout the world and is the data controller of your information. This Privacy Policy applies to all websites owned and operated by us or our affiliates under common ownership or control of PPLLC that link to this Privacy Policy (“Affiliates”), and related online and offline services thereto (including our social media pages)(collectively, the “Services”).
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
This Privacy Policy contains the following sections:
We obtain information about you through the means discussed below when you use our Services. The information we collect and the purposes for which we use it will depend to some extent on the specific Services you use and how you interact with PPLLC. The following section describes the categories of information about you that we collect and how we collect and use such information. See the following section for information regarding the purposes for which we collect information.
A.1. Contact and account registration information, e.g., name, email address, postal address, phone number, wireless device address, account username or screen name, and password
A.2. Demographic and statistical information, e.g., gender, interests, lifestyle information, and hobbies
A.3. Financial and transactional information, e.g., shipping address, credit or debit card number, verification number, and expiration date, and information about your transactions and purchases with us
A.4. User-generated content, e.g., photos, videos, audio, information about your events, any information you submit in public PPLLC forums or message boards, reviews you leave for vendors, and feedback or testimonials you provide about our Services
A.5. Customer service information, e.g., questions and other messages you address to us directly through online forms, by email, over the phone, or by post;
A.6. Communications with vendors and partners, e.g., your in-Services messages and calls to vendors and advertising partners, and information surrounding those messages such as the date/time of the communication, the originating number, the recipient number, the duration of a call, and your location as determined by your area code
A.7. Research, survey, or sweepstakes information, e.g., if you participate in a survey or sweepstakes, we collect information needed for you to participate (such as contact information), and to fulfill your prize
A.8. Information about others, e.g., if you use a “tell-a-friend” tool (or similar feature) that allows you to send information to another person, or invite them to participate in an event, web site, course or other property, or include their information within our products we will collect, at a minimum, the recipient’s email address. In providing this information, you represent that you are authorized to provide it.
A.9. Device information and identifiers, e.g., IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers
A.10. Connection and usage data, e.g., information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, whether you open an email and your interaction with email content, access times, error logs, and other similar information
A.11. Geolocation, e.g., city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and, with your permission in accordance with your mobile device settings, and precise geolocation information from GPS-based functionality on your mobile devices
A.12. Social media information, e.g., if you access the Services through a third-party connection or log-in, we may have access to information you provide to that social network such as your name, email address, friend list, photo, gender, location, and current city; and information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, Snapchat, Wordpress, and Twitter)
A.13. Other information, e.g., any other information you choose to directly provide to PPLLC in connection with your use of the Services
Purposes of Use: The following section provides additional information about the purposes and legal bases for collecting and using your information
A.1. Purpose: Communicate with you
A.2. Purpose: Provide the Services
A.3. Purpose: Personalize your experience
A.4. Purpose: Secure our Services and users
A.5. Purpose: Fraud detection and prevention, defending our legal rights and compliance with the law
Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.
We use a variety of online tracking and analytics tools (e.g., cookies, flash cookies, pixel tags, and HTML5) to collect and analyze information as you use the Services. Among other things, these technologies allow us to offer you a more tailored experience in the future, by understanding and remembering your particular browsing and usage preferences.
We may also use third-party web analytics services (such as those of Google Analytics, Coremetrics, Mixpanel, and Segment) on our Services to collect and analyze information collected through these technologies to assist us in auditing, research, or reporting; fraud prevention; and providing certain features to you. The types of tracking and analytics tools we and our service providers use for these purposes are:
The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
Third parties, whose products or services are accessible or advertised via the Services, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. We also allow other third parties (e.g., ad networks and ad servers such as Google and others) to serve tailored ads to you on the Services, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We sometimes provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.
We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Please note that if you exercise the opt out choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.
When using mobile applications from PPLLC or others, you may also receive tailored in-application advertisements. We may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. Each operating system, iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements.
You may review the support materials and/or the device settings for the respective operating systems to opt-out of tailored in-app advertisements.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for online advertising and analytics purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. Learn more about Do Not Track.
PPLLC will share the information collected from and about you as discussed above for various business purposes. The section below explains the categories of third parties with which we may share your information, and the categories of information we may share with each.
Third Parties With Which We Share Information and Why:
D.1. Our Affiliates. We may share information we collect within the PPLLC family of companies to deliver products and services to you, ensure a consistent level of service across our products and Services, and enhance our products, services, and your customer experience
D.2. Service Providers that Perform Services on our Behalf. We may share information with service providers, including billing and payment processing, sales, marketing, advertising, data analysis and insight, research, technical support and customer service, shipping and fulfillment, data storage, security, fraud prevention, and legal services providers.
D.3. Other Individuals, Services, and Vendors at Your Request. We will share your information with other individuals and services at your request. For example, if you communicate with a Vendor Member you connect with through the Services, we may share information, as well as the contents of your message, so that the Vendor Member may contact you pursuant to such Vendor Member’s privacy policy and applicable legal agreements. Categories of information shared
D.4. Third Party Partners for Marketing Purposes. We may share your information with partners whose offerings we think may interest you. For example, if you participate in a course or program, or register for certain of our Services, we may share information with our Affiliates and other third parties (organizations that have offerings we think may interest you, course participants, retailers, other program participants, or other third-parties) for their marketing and other purposes
D.5. Third Party Partners to Provide Co-Branded Products and Services. In some cases, we may share information with third-party partners to provide co-branded products or services, including contests, sweepstakes, and joint activities. For example, if you choose to interact with such co-branded products or services using your account information with us, we may share your account information with third parties as required to provide the co-branded product or service that you request, including any information required for contest prize fulfillment.
D.6. Third Parties for Legal Purposes. By using the Services, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of PPLLC , its agents and Affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
D.7. Third Parties in a Business Transaction. We may disclose or transfer information in connection with a corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets.
D.8. Third-Party Online Advertisers and Ad Networks. As discussed in the “Online Advertising” Section above, the Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use, and these technologies will collect certain information from your use of the Services to assist in delivering such ads.
Certain features of our Services make it possible for you to share comments publicly and privately with other Users, such as through our public forums, chat rooms, blogs, personal messages, review features, and message boards. You should be aware that any information you provide or post in these ways may be read, collected, and used by others who access them. While we do not have an obligation to monitor the content of messages sent using our Services, we reserve the right to, in our discretion. We encourage you to be cautious about the information you submit (e.g., choose a username that does not disclose your personal identity). Whenever you post something in our Services, social media and any other third party platforms we control, it may be impossible to remove all instances of the posted information, for example, if someone has taken a screenshot of your posting. You may be required to register with a third-party application to post a comment.
We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
You have certain rights with respect to your information as further described in this Section, in addition to any rights discussed elsewhere in this Privacy Policy.
Marketing Communications. You may instruct us not to use your information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.
Consumer Privacy Rights. Depending on the laws of your local jurisdiction, you may have certain rights and choices with respect to your information. For example, under local laws, you may be able to ask us to:
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We will let you know where this is the case or if certain rights don’t apply in your country or state of residence. We may request you provide us with information necessary to verify your identity before responding to your request as required or permitted by applicable law. If you are a California resident, please see the “Privacy Information for California Residents” section immediately below for information about your specific rights under California law.
Testimonials/Notable Quotes. On some of our Services, and with your consent, we post notable quotes or testimonials which may contain information such as your name, event type, city, state, and quote or testimonial. Requests for removal of a user testimonial can be done by contacting us as detailed in the “PPLLC Contact Information” section below.
If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, and other account information. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at [email protected].
California residents may opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that may include when we share your information with third parties to provide you with offers and promotions that we believe may be of interest to you. It also may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.
Depending on what Services you use, we may provide the following categories of personal information to third parties for these purposes:
If you would like to opt out of PPLLC's use of your information for such purposes that are considered a “sale” under California law, can submit a sale opt-out request by emailing us at [email protected]. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.
The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. If you would like to opt out of such sharing, please email us at [email protected].
Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and services of interest to you. In some circumstances, this sharing may qualify as a sale under Nevada law. If you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of such activity emailing us at [email protected]. Please note we may take reasonable steps to verify your identity and the authenticity of the request.
The Services may contain links, banners, widgets or advertisements (e.g., a “Share It!” or “Like” button) that lead to other websites, apps, or services not subject to this Privacy Policy (including other sites that may be co-branded with our brands). On some of our Services, you may also be able to register with or purchase directly from third-party retailers. We are not responsible for the privacy practices or the content of any other websites to which the Services link or which link to our Services. The privacy policies of these other sites will govern the collection and use of your information thereon, and we encourage you to read each such policy to learn about how your information may be treated by others.
The Services are intended for general audiences and not for children under the age of 13. If we become aware that we have collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without legally-valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
Our Services are targeted to individuals located in the United States and Canada. Please note that in providing services to you, your information will be transferred to the United States. Moreover, PPLLC may subcontract the processing of your data to, or otherwise share your data with, other members within the PPLLC group, trusted service providers, and trusted business partners located in countries other than your country of residence, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.
If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
We take a variety of physical, technical, administrative, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk.
When you sign up for an account, you may be required to establish a username and password. If you create an account with us, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. We are not responsible for any loss or damage arising from your failure to maintain the confidentiality of your password.
We store and maintain your information for the purposes for which it is processed by us. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
We reserve the right to amend this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review the Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.
If you have any questions or comments regarding our privacy practices, you can contact us at [email protected].
By mail: Pink and Posey LLC, 1209 Market Street, Kirkland, Washington, 98033.
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