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This Privacy Notice ("Privacy Notice" or "Notice") describes how we collect, use, share, manage or disclose or generally process your personal information as a visitor or customer when you visit or use our websites, mobile apps, applications, digital services, or any related products, services, sites, features or functionalities (each a "Service", collectively the "Services") that link to this Privacy Notice, and how Leaf Group collects, uses, shares, processes and manages your personal information.
We collect and use your personal information and in accordance with applicable data protection and privacy laws ("Data Protection Laws"), to keep it secure and recognize and respect your privacy rights. We have included below specific provisions relevant to users in different regions.
We use the terms "personal data" and "personal information" interchangeably in this Privacy Notice, and they mean any information about a living individual from which that individual can be identified. By "processing", we refer to any operation or set of operations performed upon personal data, which means anything that is done to, or with, personal data, including simply collecting, using, storing or deleting those data, but also organizing, structuring, altering, combining with other data, transmitting or disseminating.
It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. This Privacy Notice supplements any other notices and privacy policies and is not intended to override them. By using the Services, you acknowledge that you have read this Privacy Notice and you understand how we collect, share or generally process your personal data and what your privacy rights are, as described in this Notice.
Where our Services may include third-party content and links to other third-party websites, we are not responsible for the privacy practices or the content of these third-party websites. You are encouraged to review the privacy policies of the different websites that you visit.
Leaf Group Ltd., or one of its wholly-owned subsidiaries/affiliates, including Society6, LLC, Saatchi Online, Inc., Deny Designs, Other Art Fairs Ltd. and Other Art Fairs Australia Pty. Ltd., is the controller of your personal data as it relates to this Privacy Notice — including for the purposes of UK and EU data protection legislation. When we use the terms "Leaf Group", "we", "us", or "our" in this Privacy Notice, we are referring to the relevant company that is responsible for processing your personal data in the applicable context. This Privacy Notice does not apply to personal data that Leaf Group processes solely on behalf of another organization.
If you have any questions about this Privacy Notice or our processing activities, you can contact us via the details below. If you wish to exercise any of your privacy rights, please use the appropriate web form linked in Sections 10, 11, 12 or 13, as applicable.
Controller name | Email address | Mailing address |
---|---|---|
Leaf Group Ltd. | All users (UK and EU users included): [email protected] | All users: Attn: Legal Department 1655 26th Street - Santa Monica, CA 90404 – UNITED STATES UK users may also contact us at: 4th Floor, 15 D’Arblay Street, London, W1F 8DZ – UNITED KINGDOM |
Society6, LLC | All users: [email protected] UK and EU users may also contact: [email protected] | All users: Attn: Legal Department 1655 26th Street - Santa Monica, CA 90404 – UNITED STATES UK users may also contact us at: Data Protection Representative (UK) Limited, BPM 335368, 372 Old Street, London EC1V 9AU, UNITED KINGDOM EU users may also contact us at: DataRep, The Cube, Monahan Road, Cork, T12 H1XY, REPUBLIC OF IRELAND |
Saatchi Online, Inc. | ||
The Other Art Fairs Ltd. | All users (UK and EU users included): [email protected] | All users: Attn: Legal Department 1655 26th Street - Santa Monica, CA 90404 – UNITED STATES UK users may also contact us at: The Other Art Fair, 4th Floor, 15 D’Arblay Street, London, W1F 8DZ – UNITED KINGDOM |
The Other Art Fairs Australia Pty. Ltd. | [email protected] | All users: Attn: Legal Department 1655 26th Street - Santa Monica, CA 90404 – UNITED STATES |
Deny Designs |
Account Data You Directly and Voluntarily Provide to Us. We collect and process some or all of the following personal information you make available to us if you register, download or use the Services, enroll in our mailing lists or text message campaigns, apply for a job, interact with customer support, make a purchase, or otherwise communicate with us through the Services:
User Profile Data. In certain circumstances, we may offer you the option to create an account with the Services. By creating an account, you are also creating a user profile that is visible to other users. By default, this user profile will only include your name (however, on saatchiart.com it will also include your likes and followers), but you can choose to include additional information, such as the pages you follow, your likes and interests. You may be able to adjust your account settings through your user account so that certain profile information is no longer visible to other users of the Services. We note that, even if you adjust your settings so that information in your user profile remains private, we will still be able to access and view the information you provide as part of your user profile.
Personal Contacts. In some cases, and with your consent, we collect personal information that you provide about others, including first and last name, email address, and phone number of your personal contacts, such as when you send your contacts benefits, coupons, or discounts. We will use the information you provide to fulfill your requests, including (if applicable) sending them a text message, and we will not send marketing communications to your contacts unless they have a separate relationship with us and have affirmatively consented to receive such communications. Such functionality is implemented in all jurisdictions where legally permissible. By using this functionality, you acknowledge and agree that both you and your contacts are based in jurisdictions where it is legally permissible and that you have your contacts’ consent for us to use their contact information to fulfill your request.
Artist Data (on Saatchiart.com). If you are accessing the Services as a current or potential affiliate artist on the saatchiart.com website, we ask you to provide your name, legal name, a copy of a government-issued ID, contact information, address and financial information. You may also voluntarily provide us with more information in the Biography, Education, Events and Exhibitions sections of our website, which could include employment information.
Weight, Height, and Activity Level. If you use the "MyPlate Calorie Counter" mobile app, we may collect and track this information in order to operate this service.
Public Data You Post Through the Services. If you post information on your user profile or other public areas of the Services, such as reviews, comments, and user content, that information may be collected and used by us, other users of the Services, and the public generally. We strongly recommend that you do not post any information through the Services that allows strangers to identify or locate you or any other person, or that you otherwise do not want to share with the public.
You may choose to voluntarily submit other information to us through the Services that we do not request, and, in such instances, you are solely responsible for such information.
In addition to the information you provide to us, where legally permitted the Services automatically collect and process information from your device or browser. This information includes your:
Information once "de-identified" (or "anonymized") to the standard required by applicable law is not subject to this Privacy Notice and we may treat it as non-personal information, which means we could use it without restrictions nor obligation to you, except as prohibited by applicable law.
In addition to information we collect from you – either directly from you (see Section 2 above) or automatically through our Site (see Section 3 above) – we may also combine it with information we receive about you, which consists of information collected offline or from third-party sources such as data aggregators, email acquisition, email identity and email marketing companies, marketing platforms, customer relationship management data platforms and customer data platforms and offline print catalogs, in order to help us tailor our communications to you, improve our services, better understand your interests, preferences, propensity to buy from your visits and past transactions on any of our websites, visits of other partner websites and certain offline activities such as whether you have recently refinanced a mortgage or made a recent purchase of real estate.
Some of the information received about you may come from consumer data resellers and includes information that combines your personal information with those companies’ own records and records they themselves obtained from other sources.
In this section, we set out the business and commercial purposes for which we use personal information that we collect when you use the Services.
For EEA, UK and Swiss personal data – please refer to sub-section 10.2 below for the legal bases for processing.
For EEA, UK and Swiss personal data – please refer to sub-section 10.2 below for the legal bases for processing.
For EEA, UK and Swiss personal data – please refer to sub-section 10.2 below for the legal bases for processing.
For EEA, UK and Swiss personal data – please refer to sub-section 10.2 below for the legal bases for processing.
The Services are supported through advertising. From time to time we work with third-party companies, advertisers and advertising networks, to enable them to collect certain information regarding how you engage with our websites and to provide advertising through the Services.
We may allow third-party companies, including advertisers, ad networks, and advertising services providers, to serve advertisements, provide other advertising services, or collect personal information when you visit the Services. We provide these companies with the ability to collect personal information about how you interact with the Services and, if applicable, your mobile device.
This personal information includes the unique device or advertising ID associated with your device and imprecise location information (only the country, state and, on some of our websites, the city where you connect from), in order to help analyze and serve targeted advertising on the Services and elsewhere (including third-party sites and applications).
In addition, we share with these third-party providers personal information that is pseudonymized (information that only identifies you indirectly), which may consist of the following data:
all of which are collected during your visit to the Services in order to provide advertisements about goods and services likely to be of interest to you on our websites, but also on websites of third-party companies.
For EEA, UK and Swiss personal data – please refer to sub-section 10.3 below for the legal bases for processing.
For EEA, UK and Swiss personal data – please refer to sub-section 10.3 below for the legal bases for processing.
To opt out of Matched Ads, please contact the applicable technology service listed below. California and Virginia residents may also opt out of the use of their personal information for interest-based advertising, including Matching Ads, by following the instructions in Sections 12 and 13, respectively.
To opt out of targeted advertising: for information about how tracking works for targeted advertising purposes, and to opt out of the collection of personal information for the purposes described above by companies participating in the Digital Advertising Alliance Self-Regulatory Program, you can visit:
To opt out of this type of advertising by third parties that are members of the Network Advertising Initiative ("NAI"), please visit:
We are not responsible for such technology service’s failure to comply with your opt-out instructions.
For EEA, UK and Swiss personal data – please refer to sub-section 10.3 below for the legal bases for processing.
We also work with third-party analytics companies to help us understand and analyze how you use our Services and assist us with delivering to you relevant marketing messages and advertisements.
These analytics companies (e.g., Google Analytics) collect information about the content you view and your system information as well as imprecise location information (only the country, state and, on some of our websites, the city where you connect from).
Neither they, nor we, do collect precise geolocation information about your visits from your devices, such as GPS coordinates, WiFi, radio frequency location and RFID, Bluetooth, or latitude and longitude information).
For EEA, UK and Swiss personal data – please refer to sub-section 10.3 below for the legal bases for processing.
We disclose the personal information you provide or that we collect in some circumstances to the following third parties:
These companies provide what is called a "cooperative database", which is a type of database that holds information about customers and their transaction histories through which many companies, such as ours, will contribute information to the database in return for aggregate information on the customers other companies have provided. None of the companies that participate in these cooperative databases reveal which company has collected that data, so none of the participating companies are able to identify which company the data is associated with. Each email and mailing address is then associated with specific business categories (e.g., home decor, artwork, etc.) based on customers’ transaction histories. The participating companies, like ours, are then able to process, using data mining and other marketing targeting techniques, the email and mailing addresses in relation to the specific business categories they want to target in their direct mailing. Such databases are generally used for promotional mailings, credit card fraud detection, digital media targeting, business intelligence or fighting e-mail spam. In our case, these databases are used for promotional mailings and direct mail campaigns: this means that, from time to time, we share our customers’ email and mailing addresses and related transactional information, such as your purchase history, amounts paid and products ordered, with cooperative database and marketing companies for promotional mailings and direct mail campaigns. These types of marketing campaigns are mainly carried out in relation with our Saatchiart.com and Society6.com websites. Some of the third-party vendors who receive your personal information from us may resell it for their own direct marketing purposes, and the direct marketing purposes of other third-party marketing companies.
If you prefer to opt-out of the use of your email and mailing addresses for the above purposes, please let us know at [email protected].
If you are directed to the Services through a third party, we share certain information back with that third party, which may include personal information such as name, email and value of purchase depending on the type of relationship or Services utilized.
We have no control over, and assume no responsibility for any share functionality or the content, privacy policies, or practices of any third-party site or application. We encourage you to review the privacy policies and settings on the social media sites or applications with which you interact to make sure you understand the personal information that may be collected, used, and shared by those sites. You are subject to the policies of those third parties when and where applicable.
We will disclose your personal information to these third parties:
You should be aware that, following disclosure to any third party, your personal information may be accessible by others to the extent permitted or required by applicable law.
We use our own cookies, pixel tags, JavaScript, software development kits ("SDKs"), device identifiers and other tracking technologies on our websites or allow third-party companies, such as advertisers and advertising networks, to use the same technologies.
These technologies recognize your computer, mobile or other device and your actions online over time, collect personal information about you and your activities on the Services and do so across different websites and platforms, digital or marketing channels and email in order to deliver to you targeted electronic advertisements.
We or these third-party companies may link two or more devices or browsers believed to belong to the same user or household and use it for advertising-related purposes.
These third-party companies such as advertisers, advertising networks may use cookies, but also other tracking technologies such as pixel tags to recognize your computer, mobile or other device and your actions online over time, collect personal information about you and your activities on the Services and reach out to your computer, mobile or other device them across different websites and platforms, digital or marketing channels and email in order to deliver targeted electronic advertisements to an individual user. Third-party companies may link two or more devices or browsers believed to belong to the same user or household for advertising-related purposes.
We do not have access to the information located in the cookies, pixel tags and other tracking technologies that third-party partners ask us to place on our websites, nor have control over them, except to take them off our websites, which generally happens once we terminate our agreement with them.
You can control the use of cookies and other tracking technologies by using the "Cookie Settings" link that is located at the bottom of all our website homepages, by changing your privacy preferences through your browser, mobile or other device, or by using a setting or extension in your browser or device that is called "Global Privacy Control":
If you are a California or Virginia resident: you may exercise your right to opt-out of sales or sharing through preference signals. Please refer to section 12 ("California Privacy Rights") and section 13 ("Virginia Privacy Rights") below to exercise your rights with respect to cookies and other tracking technologies.
If you are located in the EEA, the United Kingdom or Switzerland, please refer to sub-section 10.5 and, more generally, to section 10 ("European Privacy Rights") below to exercise your rights with respect to cookies and other tracking technologies.
Blocking all cookies and other tracking technologies will affect your online experience and may prevent you from enjoying the full features offered through our Services.
The Services are not intended for children under age 16. We do not knowingly collect or distribute personal information from or about children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected].
In this section, we clarify the rules that are applicable to you, as a user, website visitor or customer using our Services and if you are located in the European Economic Area ("EEA") (which includes the European Union member states, Iceland, Norway and Liechtenstein), the United Kingdom, and Switzerland.
We also identify the legal bases on which we rely to use your personal data and acknowledge your right to access and control your personal data in accordance with applicable Data Protection Laws, which include but are not limited to the Regulation (EU) 2016/679 (the European Union General Data Protection Regulation, or "GDPR"), the United Kingdom GDPR ("UK GDPR"), the Swiss Act on Federal Data Protection ("FADP") and the Directive 2002/58/EC ("e-Privacy Directive") and other relevant national legislation implementing it ("e-Privacy Laws"), together, the "European Privacy Laws".
If required by the European Privacy Laws, we will seek your consent to these activities and provide the ability for you to withdraw your consent via a cookie consent management platform or other appropriate means. Please see our Cookie Notice for further details.
For details please refer to section 7.2 of this Privacy Notice.
Where we disclose the personal data you provide, or that we collect, to cooperative database and marketing companies for promotional mailings and direct mail campaign purposes, we will seek your consent to these activities if it is required by the European Privacy Laws.
For general explanations, please refer to section 8 of this Privacy Notice.
If required by the European Privacy Laws, we will seek your consent to these activities and provide you with the ability to withdraw your consent via a cookie consent management platform or other appropriate means. Please see our Cookie Notice for further details.
We may transfer your personal data outside of the EEA, the United Kingdom or Switzerland, including to servers, databases or cloud storage facilities located in the United States. We put adequate safeguards in place when we transfer your personal data internationally. This includes only transferring personal data to countries that have been deemed to provide an adequate level of protection for personal data by the applicable regulatory authority, or by otherwise using an appropriate safeguard to ensure the ongoing protection of personal data, such as standard contractual clauses approved by the applicable regulatory authority. You may request further information on the safeguards we use by contacting us via the contact details in Section 1 of this Privacy Notice.
Additionally, although the EU-US and Swiss-US Privacy Shield Frameworks have been ruled invalid and we do not rely on them to legally validate our international transfers, we continue to keep to the commitments that we made when we certified to these two Frameworks regarding the collection, use, and retention of personal information we receive from individuals or companies in the EEA, the United Kingdom and Switzerland and that is transferred to the United States.
If you have a concern about our handling of your personal data, please get in contact with us first so we can try to resolve your query using our contact details in section 1 of this Privacy Notice.
If however you feel we have not dealt with your concern and that we are failing to meet our legal obligations, the GDPR gives you the right to lodge a complaint with a supervisory authority. You can do so with your local data protection authority: the Information Commissioner's Office in the United Kingdom or the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
Under Nevada law, Nevada residents may submit a request directing us not to make certain disclosures of personal information we maintain about them. As a Nevada resident, you have the right to direct us not to sell any "covered information" (as that term is defined by Chapter 603A - Security and Privacy of Personal Information, Section NRS 603A.340) that we have collected or will collect about you. If you wish to exercise this right, you can visit the following page: USA Consumer Privacy Rights Web Form.
The chart below summarizes the personal information we collect and use by reference to the categories of personal information specified in the CPRA. It describes our current practices as well as our practices during the 12 months preceding the effective date of our Privacy Notice (January 1, 2023). Information you voluntarily provide to us, such as in free-form webforms or posts on some of our websites, may contain additional categories of personal information not described below. More information regarding the sources from which we collect personal information can be found in Section 2 of our Privacy Notice titled "Personal Information that We Collect from You", Section 3 titled "Information We Automatically Collect from Your Device or Browser", and Section 4 titled "Information We Collect from Third Parties about You". Business and commercial purposes for which we collect your personal information can be found in Section 5 of our Privacy Notice titled "How We Use Your Personal Information". Categories of recipients with whom personal information is shared or sold can be found in Section 7 of our Privacy Notice titled "Third Parties to Whom We Disclose Your Personal Information".
Categories of Personal Information | Collected in the last 12 months | Categories of sources from which information is collected | Business or commercial purposes for collection, use, selling, and sharing | Disclosed for business purposes to the following categories of third parties | Sold or shared to the following categories of third parties |
---|---|---|---|---|---|
Personal and online identifiers (such as first and last name, email address, or unique online identifiers) | Yes. | All categories described above in Sections 2, 3, and 4. | All purposes described above in Section 5. | All categories listed above in Section 7. | All categories listed below under section D. |
Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered) | Yes (concerns only our marketplace websites: saatchiart.com, society6.com and theotherartfair.com) | All categories described above in Sections 2, 3, and 4. | All purposes described above in Section 5. | All categories listed above in Section 7. | All categories listed below under section D. |
Geolocation data | Yes: only imprecise geolocation data (IP address, country, state, city) | All categories described above in Sections 2, 3, and 4. | All purposes described above in Section 5. | All categories listed above in Section 7. | All categories listed below under section D. |
Audio, electronic, visual, thermal, olfactory, or similar information: only visual information consisting of mobile device motion sensors and camera ("View in Your Room" feature on the society6.com or saatchiart.com mobile app or the saatchiart.com website) | Yes. | All categories described above in Sections 2, 3, and 4. | All purposes described above in Section 5. | All categories listed above in Section 7. | N/A |
Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement) | Yes. | All categories described above in Sections 2, 3, and 4. | All purposes described above in Section 5. | All categories listed above in Section 7. | All categories listed below under section D. |
Inferences drawn from the above information about your predicted characteristics and preferences | Yes. | All categories described above in Sections 2, 3, and 4. | All purposes described above in Section 5. | All categories listed above in Section 7. | All categories listed below under section D. |
Characteristics of protected classification under California or federal law (race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, marital status, sex, age and sexual orientation) | Yes: only sex (gender identity) (through the "MyPlate Calorie Counter" mobile app and the Livestrong.com website) | All categories described above in Sections 2, 3, and 4. | All purposes described above in Section 5. | All categories listed above in Section 7. | N/A. |
Employment and education information | Yes: educationfield in artists’ profiles on saatchiart.com and in reader surveys. | All categories described above in Sections 2, 3, and 4. | All purposes described above in Section 5. | All categories listed above in Section 7. | Affiliates not under the Leaf Group brand; partner programs; service providers. |
Categories of personal information described in Section 1798.80(e) of the California Civil Code | Yes: only name, address, telephone number, physical characteristics or description, passport number, driver's license or state identification card number | Consumers (artists who register on saatchiart.com). | All purposes listed below under section E. | Service providers and contractors | No. |
Other information about you that is linked to the personal information above | Yes. | All categories described above in Sections 2, 3, and 4. | All purposes described above in Section 5. | All categories listed above in Section 7. | All categories listed below under section D. |
Some of the personal information we collect may be considered sensitive personal information (as described in the CCPA). For further details of the sensitive personal information we collect (if any) and how we obtain this information, please review the section entitled "Personal Information that We Collect from You" above.
We collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CPRA or without the purpose of inferring characteristics about consumers. We do not sell or share sensitive personal information.
Our retention periods for each category of personal information, including sensitive personal information, are based on our business needs and legal requirements. We retain personal information only for as long as is reasonably necessary for us to fulfill the purpose for which it was collected, and as otherwise to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. If we continue to retain your personal data in accordance with a legal obligation, any further processing of your data will be limited to compliance with such legal obligation.
Where required by applicable law, we shall delete your personal information when we are requested to do so. Even if we delete your personal information from our active databases, some or all of the personal information you provided may be required in order for the Services to function properly and it may remain in backup storage or records retention archival media (not to be used for any other purpose) until it is permanently deleted in accordance with our standard retention schedules.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal obligations.
We sell or share the categories of personal information designated above to the categories of third parties listed below:
You may request the following from us:
In addition, you have the right to correct or delete the personal information we have collected from you. These rights apply to sensitive personal information.
To exercise any of the above rights, please contact us using the following information and submit the required verifying information online at the following USA Consumer Privacy Rights Web Form. We will confirm receipt of your request within 10 business days and respond to your request within 45 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
To the extent we "sell" or "share" your personal information as those terms are defined under the CPRA, you have the right to opt-out of the sale or sharing, which you can exercise through:
Note that when you submit an opt-out, except as provided below, your opt-out will only apply to sales and shares of personal information through tracking technologies from the specific browser or mobile device from which you submitted the opt-out because the connection between your browser identifiers and other personal information we have about you is not known to us. Opt-outs also apply to any pseudonymous profiles we maintain associated with your browser or device. If you want the opt-out to also apply to other personal information we have about you (such as your contact information), please use the link and provide your contact information as requested or make sure you are logged into your account when submitting the opt-out.
Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We reserve the right to deny your requests if we cannot verify your identity.
You may designate an authorized agent to make a CPRA request on your behalf. We will require proof of your consent to designating such an agent and verification of your identity as described above. Requests must be submitted through one of the designated methods above.
We do not knowingly sell the personal information of minors under 16 years of age.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
Financial incentives, as defined under the CPRA, include "programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them. Although we do not consider our discounts and offerings to be a "financial incentive," each may be interpreted to be one under California law.
We may offer discounted prices to consumers who sign up for our offerings and voluntarily provide us with certain requested personal information to be used in accordance with this Privacy Notice.
You can opt-in by submitting the requested personal information. You can withdraw your consent at any time by emailing us using the contact information below with "Opt-out of Financial Incentives" in the subject line. We generally do not treat consumers differently if they exercise a privacy right under California law. However, you will need to provide some personal information in order to receive certain discounts or benefits. In such circumstances, we offer a price difference that is reasonably related to the value of your data to us in connection with the discount or benefit.
The price differences reflected in our discounts and offerings are provided based upon our reasonable determination of the estimated value of the data you provide to us, which takes into consideration a number of factors, including, among other things, our estimates regarding the anticipated revenue generated from such data and the actual and anticipated expenses that we incur in the collection, storage, and use of such data in connection with our discounts and offerings. If you choose to withdraw from our discounts and offerings or choose not to create an account with us, you can still continue to use our website as a guest user.
Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in section 1 above and specify that you are making a "California Shine the Light Request." We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
Virginia provides additional rights to Virginia residents through the Virginia Consumer Data Protection Act ("VCDPA"). This section addresses those rights and applies only to Virginia residents.
You have the following rights under the VCDPA:
You can visit the following page in order to exercise any of the above rights for some or all of our websites: USA Consumer Privacy Rights Web Form.
To exercise your right to opt out of processing your personal data for purposes of targeted advertising, the sale of your personal data, or profiling, clicking on that Web Form will only remove your email address from our marketing mailing lists. If you want to block all targeting cookies used for targeted advertising and profiling, as well as opt out of the sale of your personal data, please click on the "Cookie Settings" or "Manage Preferences" link available in the footer section of our websites.
We will respond to your request within 45 days. If you have an account with us, we may require you to use the account to submit the request. We may require specific information from you to help us confirm your identity and process your request.
If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected] and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.
We provide industry-standard physical, electronic, and procedural safeguards to protect personal data we process and maintain. For example, we take reasonable measures to limit access to this data to authorized employees and contractors who need to know that information in order to operate, develop or improve our Services. Please be aware that, although we endeavor to provide reasonable security for data we process and maintain, no security system can prevent all potential security breaches. As a result, we cannot guarantee or warrant the security of any information you transmit on or through the Services and you do so at your own risk. We have also put in place procedures to deal with any personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
Our retention periods for each category of personal information, including sensitive personal information, are based on our business needs and legal requirements. We retain personal information only for as long as is reasonably necessary for us to fulfill the purpose for which it was collected, and as otherwise to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. If we continue to retain your personal data in accordance with a legal obligation, any further processing of your data will be limited to compliance with such legal obligation.
Where required by Data Protection Laws, we shall delete your personal information when we are requested to do so. Even if we delete your personal information from our active databases, some or all of the personal information you provided may be required in order for the Services to function properly and it may remain in backup storage or records retention archival media (not to be used for any other purpose) until it is permanently deleted in accordance with our standard retention schedules.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal obligations.
If you do not agree to such changes following such notice, you should discontinue your use of the Services prior to the time the modified Privacy Notice takes effect. If you continue using the Services after the modified Privacy Notice takes effect, the modified Privacy Notice will govern any further processing of your personal data.