NOTICE AT COLLECTION
HOW WE COLLECT AND USE PERSONAL INFORMATION
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CATEGORIES OF PERSONAL INFORMATION |
EXAMPLES |
BUSINESS PURPOSES FOR COLLECTION, USE, AND DISCLOSURE |
TYPES OF VENDORS OR THIRD PARTIES WITH WHOM THIS PERSONAL INFORMATION IS SHARED, SOLD, OR DISCLOSED |
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Unique Identifiers |
Real name, alias, address, unique personal identifier, online identifier, IP address, email address, account name, advertising ID, loyalty or gift card ID |
-Provide information, products and services -Security, credit or fraud prevention -Provide customer service and assess satisfaction -Personalize customer experience -Improve products and services -Auditing an interaction -Improve marketing and customer communications -Comply with legal requirements |
Disclosed -Service Providers -Contractors -Affiliates Shared or Sold -Online advertising partners -Analytics providers -Vendors -Business partners |
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Contact and Financial Information |
Name, address, telephone, email, credit card number, debit card number, or any other financial information |
-Complete transactions -Other services and discounts -Process claims -Prevent fraud -Track purchase history |
Disclosed -Card processor and Service Providers -Contractors -Vendors -Gift card provider Shared or Sold -None |
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Characteristics of Protected Classifications |
Name, address, telephone, email, credit card number, debit card number, or any other financial information |
-Provide you with goods and services -Invite participation in surveys and feedback -Customer service communications -Improve promotions -Verify or maintain the quality or safety of a service or device |
Disclosed -Service Providers -Contractors Shared or Sold -Business partners -Marketing providers -Analytics providers -Social media -Affiliates -Vendors |
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Commercial Information |
Records of products or services purchased, or considered, or other purchasing or consuming histories or tendencies, derived data |
-Provide you with goods and services -Invite participation in surveys and feedback -Customer service communications -Improve promotions -Verify or maintain the quality or safety of a service or device |
Disclosed -Service Providers -Contractors Shared or Sold -Business partners -Marketing providers -Analytics providers -Social media -Affiliates -Vendors |
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Internet or Other Electronic Activity |
Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement, derived data |
-Provide you with information, goods and services -Security, credit or fraud prevention -Invite participation in surveys and feedback -Customer service communications -Improve promotions -To monitor click through rate |
Disclosed -Service Providers -Contractors Shared or Sold -Business partners -Marketing providers -Analytics providers -Social media |
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Geolocation Data |
Device location |
-Provide you with goods and services -Customer service communications -Improve promotions |
Disclosed: -Service Providers Shared or Sold: -Business partners -Marketing providers -Analytics providers -Social media |
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Inferences Drawn from Other Categories to Create a Profile |
Profile reflecting preferences, characteristics, derived data |
-Provide you with goods and services -Customer service communications -Improve promotions |
Disclosed -Service Providers Shared or Sold -Business partners -Marketing providers -Analytics providers -Social media -Affiliates -Online advertising partners |
CATEGORIES OF SOURCES FROM WHICH Unsubscribed HAS COLLECTED PERSONAL INFORMATION
- Directly from you
- Your browser or device
- Unsubscribed subsidiaries
- Our business partners and affiliates
- Third parties you direct to us share information with us
- Information generated or derived from your online browsing and usage activity
- Social networks
CATEGORIES OF RECIPIENTS TO WHOM PERSONAL INFORMATION IS DISCLOSED FOR BUSINESS PURPOSES
Unsubscribed shares Personal Information with service providers and governmental authorities and permits our service providers to collect Personal Information directly from visitors and customers when providing services to Unsubscribed. Generally, we do not disclose Personal Information to service providers that do not agree to acceptable data protection agreement terms.
We provide the categories of Personal Information listed above to service providers for the following purposes: payment processing, gift card processing, customer service, advertising and marketing, email services, mobile messaging services, mail services, data analytics, shipping, warehousing, anti-fraud services, legal and advisory, computer and data infrastructure, telecommunications, auditing, and building products and services for us.
Categories of Personal Information Sold or Shared
- Internet or other electronic network activity (e.g., “cookies” or other tracking tags, etc.)
- Identifiers (e.g., name, mailing address, email address, phone number, etc.)
- Commercial Information (e.g., products or services purchased, purchase history, etc.)
Categories of Third Parties to Whom Personal Information was Sold or Shared
- Advertising Networks
- Merchant Partners
- Marketing Partners
The purpose of selling or sharing this Personal Information (as defined under applicable US state laws) is for advertising partners to help us tailor and target our marketing and advertising efforts.
In order to opt-out of selling and sharing, please click on the “Do Not Sell or Share My Personal Information” link, which is available at the footer of our website.
COLLECTION, PROCESSING, AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION
Unsubscribed does not use or disclose Sensitive Personal Information of consumers for purposes other than those identified in the CCPA.
CALIFORNIA CONSUMER RIGHTS
Under the California Consumer Privacy Act found at California Civil Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), California Consumers have the right to request:
- The deletion of the Personal Information (as defined in the CCPA) we have about them;
- The correction of inaccurate Personal Information we have about them;
- To Know and Access your Personal Information, including information about (1) the categories of Personal Information collected, sold, shared with third parties, or disclosed by us; (2) purposes for which categories of Personal Information are collected, sold or shared with third parties by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed Personal Information; and (5) specific pieces of Personal Information we have collected about them;
- The opt-out of the “sale” or “sharing” of Personal Information: California consumers have the right to opt out of the “selling” and “sharing” of their Personal Information, and can do so by clicking the “Do Not Sell or Share My Personal Information” link, which can also be found in the footer of our website.
- Certain Marketing Partners, such as Data Cooperatives, help us identify lookalike audiences of prospective consumers of our service to send our catalog to potential consumers who are similar to our current customers. If you wish to opt-out of such sale or share, you will need to provide your physical address in order to identify you and honor your request.
- Because sharing and selling also occurs via cookies and tracking technologies (“Cookies”), the link will also direct you to the Cookie Preferences Center in the footer of our website to opt-out of such Cookies. Opting-out of “sales” and “sharing” will not stop marketing and advertising, but it may be less tailored and useful for you. Even after you opt-out, we will continue to disclose your Personal Information with our service providers.
California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed above. When you make a request, we may require that you provide information and follow procedures to verify the request before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request (including your email and physical address) to information we already have on file to verify your identity. If we are able to verify your identity, we will begin to process it. If we cannot verify your identity, we may ask you for additional information to help us verify your request. If we still cannot verify your identity, we will notify you with further explanation.
We will respond to your request within the 45-day time period required by applicable law. We reserve the right to extend that time to 90 days in order to complete your request. However, we may not always be able to fully comply with your request, and we will notify you in that event. To make requests, California consumers may contact us through our Data Privacy Request or call us at 1-(877)787-5800. Consumers will be required to submit their name, email address, and request-related information. We may also ask you to confirm information such as your order history or account settings so that we may verify the request. Please provide as much of the requested information as possible to help us verify your identity. We will use information received in a request only for the purposes of responding to your request.
The CCPA permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a signed document addressing this topic or a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agency must follow the process described above to make a request, and we will additionally require you and your authorized agent to verify his/her own identity. Additionally, we may confirm the agent’s authority with the California consumer about whom the request was made.
GLOBAL PRIVACY CONTROL
You may opt out of the sharing of your Personal Information through an opt-out preference signal setting in your browser. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. Please note that the GPC signal will only apply to the device and browser you are currently using, and any other devices or browsers where you have logged in. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use.
Additionally, if you clear cookies from your browser after submitting an opt-out request, you will clear the cookie we used to honor your request. For this reason, you will have to submit a new opt-out request.
Please also note that you may also need to submit a request via the “Do Not Sell or Share My Personal Information” link in order to properly identify you and opt-out of the sale or share with Data Cooperatives.
DE-IDENTIFIED INFORMATION
Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.
INFORMATION RETENTION
Please refer to Section 7. "Information Retention” of the Notice, above
CALIFORNIA PRIVACY RIGHTS - CALIFORNIA MINORS
As stated in our Privacy Notice, our websites, mobile/tablet sites, web pages, social media presence, marketing campaigns, applications, our stores and other Unsubscribed controlled digital properties that link to this Policy (collectively, our “Platforms”) are “general audience” websites and not directed toward children.
Certain areas of our Platforms may contain interactive features that allow registered users to post content or information (the “Interactive Services”). If any of our Interactive Services are either: (1) directed toward California residents under the age of eighteen (18); or (2) if Unsubscribed has actual knowledge that a registered user of the Interactive Services is a California resident under the age of eighteen (18), Unsubscribed will permit such registered user to remove (if applicable) or request that Unsubscribed remove or anonymize such content or information as posted by the registered user, to the extent required by California Business and Professions Code § 22581.
If you are under the age of eighteen (18) and would like to request the removal or anonymization of content or information you have posted on or to our Interactive Services, please send your request to privacy@unsubscribed.com.
NOTICE OF FINANCIAL INCENTIVE
We may offer new customers with discounts, special offers, and promotions like discounts in connection with you opting in to receive marketing emails. Because this may involve the collection of Personal Information and offering of certain benefits, they might be interpreted as a “financial incentive” program under California law or a “bona fide loyalty program” under Colorado law. Under the California law, the value of your Personal Information to us is related to the discounted products, or other benefits that you obtain or that are provided, less the expense related to offering those products to these new customers.
Participation in a financial incentive program is completely at your own discretion and you can opt-in by providing your email address and clicking “subscribe,” which you may revoke at any time by following the instructions in the removal instructions in the marketing emails that you receive.
CALIFORNIA SHINE THE LIGHT
California Shine the Light under California Civil Code §1798.83. California law permits customers in California to request certain details about how their personal information is shared with third parties, and in some cases affiliates, if personal information is shared for those third parties’ or affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at privacy@unsubscribed.com. Please allow 30 days for a response.
ADDITIONAL RIGHTS AND PROVISIONS FOR COLORADO, CONNECTICUT, OREGON, TEXAS, UTAH, VIRGINIA RESIDENTS
This section applies to Colorado, Connecticut, Oregon, Texas, Utah and Virginia Consumers as defined by the Connecticut Data Privacy Act (“CTDPA”), Colorado Privacy Act (“CPA”), Oregon Consumer Data Privacy Act (“OCPA”), Texas Data Privacy and Security Act (“TDPSA”), Utah Consumer Privacy Act (“UCPA") and Virginia Consumer Data Protection Act (“VCDPA”) that use our Platforms. Capitalized terms defined in the CTDPA, CPA, OCPA, TDPSA, UCPA and VCDPA that are used in this section shall have the same meaning as in the CTDPA, CPA, OCPA, TDPSA, UCPA and VCDPA.
This section describes our collection, use, and disclosure of Personal Data. You can learn more about the Personal Data we process and the purpose for processing such Personal Data in Section 1. Collection and Use of Personal Information, above. You can also learn more about our disclosure of Personal Data and the categories of third parties we disclose Personal Data to in Section 2. Sharing of Information, above. To view the categories and the purposes of how Unsubscribed processes Personal Data please see Section 10, Additional Rights and Provisions for California, Colorado, Connecticut, Oregon, Texas, Utah, and Virginia residents.
Unsubscribed does not use or disclose sensitive Personal Data of consumers for purposes other than those identified in the CTDPA, CPA, OCPA, TDPSA, UCPA and VCDPA. We may Process your Personal Data for a Sale or Targeted Advertising. You have the right to opt-out of the Processing of your Personal Data for a Sale or Targeted Advertising, as described below.
If you are a Colorado, Connecticut, Oregon, Texas, Utah or Virginia Consumer, subject to certain conditions and restrictions set out in the CTDPA, CPA, OCPA, TDPSA, UCPA, VCDPA and other applicable laws, you have the following rights with regard to your Personal Data:
- Right to Access. You have the right to know the Personal Data that we may hold about you and access such Personal Data. If you live in Oregon, you also have a right to request a list of specific third parties to which Unsubscribed has disclosed your personal data. If you live in Oregon, you also have a right to request a list of specific third parties to which Unsubscribed has disclosed your Personal Data.
- Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information.
- Right to Delete. You have the right to request that we delete Personal Information that we have collected from or obtained about you.
- Right to Opt-Out of Sales. You have the right to opt-out of the Sale of Personal Information. You can opt-out of the Sale of your Personal Information by submitting a request to us as set forth below.
- Right to Opt-Out of Targeted Advertising. You may request that we stop disclosures of your Personal Information for Targeted Advertising via cookies and tracking technologies by visiting our Cookie Preferences Center in the footer of our website. You can opt out of other types of Targeted Advertising by submitting a request to us as set forth below.
- Right to Opt-Out of Profiling. You have the right to opt-out of our processing of Personal Information for the purposes of profiling. Our profiling does not result in decisions that produce legal or similarly significant effects and therefore, we do not offer a way for you to submit such a request.
- Right to Appeal. If you are unsatisfied with our actions related to the exercise of one of your privacy rights above, you may appeal our decision.
Consumers may submit their Data Subject Access Requests via our Data Privacy Request. Consumers may also opt-out of Sales and Targeted Advertising via a GPC browser signal. Please note that, depending on the nature of your request, you may be asked to provide information to verify your identity before your request can be processed. We will confirm receipt of your request and respond to your request as soon as we reasonably can and no later than legally required.
You may exercise your privacy rights under the CTDPA, CPA, OCPA, TDPSA, UCPA and VCDPA no more than twice in a 12-month period. If you choose to exercise any of the privacy rights described above, you will not receive discriminatory treatment from us.
If you make a privacy rights request, we will retain the Personal Data provided to us to fulfill your request for our record keeping purposes.
DE-IDENTIFIED INFORMATION
Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.
12. CONTACT US
As it relates to questions you might have about this Notice or if you have a concern that Unsubscribed may have failed to adhere to this Notice, please contact us as follows:
Please note, the role and department responsible for compliance with the obligations under this Notice is: Assistant General Counsel, Privacy: Legal Department, privacy@unsubscribed.com.
Unsubscribedc/o Legal Department
77 Hot Metal Street
Pittsburgh, PA 15203
Attention: Assistant General Counsel, Privacy
Tel: 1.888.232.4535
E-mail: privacy@unsubscribed.com