Privacy Policy Statement

Transcription

1 Last revised: July, 2015 Privacy Plicy Statement The Clrx Cmpany (cllectively, we, us, ur ) prvide this Privacy Plicy Statement ( Privacy Statement ) t infrm yu f ur practices regarding the cllectin, use and disclsure f infrmatin that yu prvide t us r that we cllect frm yu thrugh ur websites and ther nline r mbile services, applicatins r advertisements that link t this Privacy Statement (cllectively hereinafter, ur Prperties ). Befre using ur Prperties r prviding infrmatin t us, please carefully review this Privacy Statement. By using ne f ur Prperties, including registering fr an accunt r accessing ne f ur Prperties, yu agree that we may cllect and use yur infrmatin in accrdance with this Privacy Statement, as revised frm time t time. What s Cntained in this Privacy Statement Highlights f Our Practices What Infrmatin We Cllect Persnal Infrmatin Device Infrmatin Aggregate and Statistical Infrmatin Hw We Use the Infrmatin We Cllect Infrmatin Sharing and Disclsure Yur Califrnia Privacy Rights Interest Based Advertising Accessing and Updating Yur Infrmatin Opting Out f Cmmunicatins Security Websites Nt Cvered by this Statement Children Under the Age f 13 Crss-Brder Data Transfers Cntacting Us Changes t this Privacy Statement Highlights f Our Practices This sectin is intended t prvide yu with a basic verview f the privacy practices described in this Privacy Statement. Fr cmplete details n ur practices, please read this entire Privacy Statement. Infrmatin We Cllect: We cllect infrmatin abut yu frm a variety f surces, including: Infrmatin yu prvide t us directly, such as when yu fill ut a registratin r cntact frm; Infrmatin autmatically cllected when yu visit r use ur Prperties, such as infrmatin n hw yu were referred t ur site and what yu d n ur site; and Infrmatin frm third parties, such as ur vendrs, advertising netwrks and business partners as well as scial netwrks in which yu participate. Read mre abut what infrmatin we cllect Hw We Use Yur Infrmatin: We use the infrmatin we cllect t fulfill yur requests, cnduct transactins with yu, cmmunicate with yu abut ur prducts and ther matters, manage ur Prperties, and cnduct research and analysis. We and ther parties may display behavirally targeted advertising t yu acrss the Internet based n yur use f ur Prperties.

2 We d nt sell r rent yur persnal infrmatin t third party marketers. We may cmbine all the infrmatin we cllect abut yu. Read mre abut hw we use yur infrmatin Hw We Share Yur Infrmatin: We may share yur infrmatin: With ur third party service prviders that assist r supprt ur business peratins, such as fulfillment, research, marketing and technlgy; With ur affiliates, retailers and third party business partners fr research, analysis and ther purpses, but nt fr their direct marketing purpses; With ther parties in an aggregated frm that cannt identify yu; If all r part f ur business is sld t anther cmpany; T prtect and defend ur r ther parties rights, safety and prperty; and When required by law and/r gvernment authrities. Read mre abut hw we share yur infrmatin Yur Chices: If yu have pted in t receive cmmunicatins frm us, we may send yu s, text messages r ther cmmunicatins cntaining newsletters, special ffers and ther infrmatin. Yu can stp receiving prmtinal messages by fllwing the instructins cntained in such cmmunicatin, r if applicable, by lgging int the cmmunicatin preference center n the website assciated with yur accunt. We may participate in interest-based advertising initiatives that result in advertisements targeted t yu based n yur nline behavir.. Read mre abut updating yur infrmatin and pting ut f cmmunicatins What Infrmatin We Cllect Back t tp We aim t prvide yu infrmatin abut hw yur persnal infrmatin will be used at specific data cllectin pints thrughut ur websites. The types f infrmatin we may cllect abut yu include: Persnal infrmatin: We may cllect persnal infrmatin thrugh yur use f the Prperties, such as when yu register fr ur Prperties, subscribe t receive ur cmmunicatins, update yur accunt infrmatin, enter cntests r sweepstakes, respnd t surveys, rate r review prducts, make purchases, cntact us with questins r cmments, apply fr a jb, cnnect with us thrugh scial netwrks, submit user generated cntent r participate in ur nline frums, prmtins and scial media platfrms. Prviding yur persnal infrmatin t us is vluntary, hwever, if yu d nt prvide sme r all f the infrmatin we request, we may nt be able t prvide yu with certain prducts, services, r infrmatin. This persnal infrmatin can include data attributes like yur full name, username, passwrd, address, telephne number, physical r billing mail addresses, date f

3 birth and ther infrmatin yu may prvide t us, as well as credit card numbers r, in sme limited cases natinal ID numbers. It may als include ther persnally identifiable infrmatin we have cllected frm yu, such as yur attitudes and pinins abut and usage f ur prducts, demgraphics, interests, husehld r lifestyle infrmatin, jb descriptin, satisfactin with ur website and newsletters, yur purchasing behavir r histry and yur brwsing, dwnlading and ther internet activity. Additinally, it may include a resume r curriculum vitae r ther infrmatin yu submitted in cnnectin with a jb applicatin r inquiry. If yu have cntacted us n behalf f a business r ther entity, we may als cllect yur wrk cntact infrmatin and details abut yur business r entity that yu prvide t us. In sme instances, we may cmbine yur infrmatin with ther infrmatin abut yu, such as cmbining yur name with yur gegraphic lcatin r yur brwsing r purchasing histry. We als may cmbine persnal infrmatin with infrmatin we receive abut yu frm utside surces. Fr example, we may btain cmmercially available demgraphic infrmatin abut yu frm third parties, receive device infrmatin frm mbile applicatins r advertisements, match yur prfile with infrmatin abut yu prvided by retailers r data brkers, r purchase r similar lists frm third parties fr advertising and marketing purpses. Device infrmatin we cllect thrugh ur Prperties: Server lg files: An Internet Prtcl (IP) address is a number that is autmatically assigned t the cmputer that yu are using by yur Internet Service Prvider and is identified and lgged autmatically in ur server lg files whenever yu visit ne f ur Prperties, alng with the time f the visit and the page(s) that were visited. We use IP addresses fr purpses such as ruting visitrs t the apprpriate website fr the visitr s cuntry, calculating usage levels, helping diagnse server prblems, and administering ur Prperties. If yu accessed ne f ur Prperties using a mbile device like a smartphne, we may als cllect yur phne s unique device ID and ther similar mbile device data. Ckies and similar technlgies: A Ckie is a small text file cntaining a randm and unique alphanumeric identifier that ur Prperties may transfer t yur cmputer's hard drive thrugh yur web brwser that enables ur systems t recgnize yur brwser. We emply technlgies like Ckies, web beacns, clear GIF, pixel r Internet tag technlgies t uniquely identify yur accunt, r the IP address assciated with yur Internet device. We als permit third parties t gather infrmatin n ur websites, including fr advertising purpses, thrugh these technlgies, as described belw. Ckies and the ther technlgies mentined abve prvide infrmatin related t the ways cnsumers interact with ur advertising r ur Prperties, like brwser type, brwsing behavirs, user web requests, pages and cntent viewed, the number f new visits r lg-ins, search engine referral, affiliate referrals, traffic driven by banner ads r ther prmtins, which items are placed in shpping carts and which are abandned, cnversins and what purchases were made and zip cdes. These technlgies can cntain r stre persnal and ther infrmatin (such as if yu have previusly registered n ur Prperties r cnsented t the retentin f certain persnal infrmatin) and allw web brwser servers t recgnize return visits t ur Prperties and imprve web brwsing navigatin r the quality and delivery f certain features r custmized cntent thrugh ur Prperties. Sme Ckies (knwn as persistent ckies ) will remain n yur cmputer r Internet device until yu delete them, while thers (knwn as sessin ckies ) are autmatically erased when yu exit yur Internet brwser. Yu can set yur cmputer r Internet device t accept r reject mst Ckies, r t ntify yu in mst situatins that a Ckie is ffered s that yu can decide whether t accept it. Sme f ur Prperties als ffer a ckie cnsent tl that allws yu t blck Ckies.

4 Hwever, if yu blck Ckies, certain features n ur Sites may nt functin. Additinally, even if yu blck r delete Ckies, nt all tracking will necessarily stp. Flash LSOs: We and ur third-party service prviders may use Flash Lcal Strage Objects ( Flash LSOs ) in certain situatins, including t recgnize yu and remember yur preferences r ther details abut yur visit. Flash LSOs are different frm brwser Ckies because f the amunt and type f data stred. In additin, yu generally cannt cntrl, delete r disable the acceptance f Flash LSOs frm yur brwser. Fr mre infrmatin n Flash LSOs, and t learn hw t cntrl them, click n the supprt page fr yur Flash player and chse Glbal Strage Settings Panel and fllw the instructins. T see the Flash LSOs n yur cmputer nw, g t yur Flash player s Website Strage Settings Panel and fllw the instructins t review and, if yu chse, t delete any specific Flash LSO. Third-party applicatins and APIs: We als ffer and deliver services, cntent r interactive features thrugh and/r using third party applicatin prgramming interfaces (API), gadgets, extensins that are hsted n ur Prperties r thrugh ther third party websites, r scial netwrking platfrms. When yu participate in these services, and subject t yur cnsent where required by applicable law, prducts, applicatins, r therwise cnnect with, r accept r allw third party applicatins, netwrks, platfrms r services thrugh ur Prperties and/r ne f ur services r prducts, yu are authrizing thse third parties t receive yur infrmatin and additinally t ptentially share any r all f yur infrmatin with us, based n yur privacy r ther settings n the particular third party netwrk r platfrm. Any persnal r ther infrmatin we receive by these means will be treated and/r prcessed accrding t this Privacy Statement. Lcatin data: Sme f ur Prperties may allw yu t submit infrmatin abut yur general lcatin, such as yur zip cde r address, in rder t lcate stres that sell ur prducts r prvide ther lcatin-related services. With yur cnsent, sme f ur Prperties als may capture and recrd certain precise ge-lcatin r glbal psitining data frm yur device in rder t prvide lcatin-related functinality. We may link such lcatin data t ther infrmatin that yu prvide t us r that may be accessed in cnnectin with yur use f ur Prperties. If we cmbine any lcatin infrmatin with persnal infrmatin, we will treat the cmbined infrmatin as persnal infrmatin as lng as it is cmbined. Aggregate and statistical infrmatin we cllect thrugh ur Prperties: De-identified infrmatin: We may cnduct surveys and therwise cllect infrmatin that des nt uniquely identify any individual. This might include demgraphic infrmatin like age and incme range, gender, educatin, husehld size and marital status, as well as infrmatin frm which identifying particulars have been remved. If this infrmatin des nt persnally identify yu, we may cllect, use and disclse such infrmatin fr any purpse, such as research t imprve ur prducts r advertising. Website analytics: We may wrk with third-party service prviders wh use the technlgies described in this Privacy Statement abve t cnduct website analytics t help us track and understand hw visitrs use ur Prperties. Back t tp Hw We Use the Infrmatin We Cllect We may use the infrmatin we cllect abut yu fr purpses such as t: cmplete transactins yu have requested r fulfill rders yu have placed; respnd t r fllw-up n yur cmments, reviews, inquiries and ther requests;

5 deliver targeted advertising, cmmunicatins, prduct slutins r cntent, as well as services yu have requested; cnduct research and analysis related t ur business, prducts r Prperties; imprve ur prducts, services r Prperties and tailr them t yur usage r preferences; cmmunicate with yu abut cntests, sweepstakes, lyalty r rewards prgrams, cupns, rebates, prmtins r ther matters which yu have entered r jined r fr which yu have requested infrmatin; implement scial netwrking features yu have activated; publish yur reviews, cmments, phts, vides and ther cntent yu have psted t ne f ur interactive r user-generated features; cmmunicate with yu abut yur accunt r yur use f ur Prperties; enfrce the terms f use f ur Prperties r therwise manage ur business; and if yu have pted-in t receive news, special ffers r ther infrmatin frm us r ne f ur brands by r text message, send yu prmtinal messages we think will be f interest t yu. If yu n lnger want t receive these direct marketing cmmunicatins, yu may pt-ut f such cmmunicatins by the methds describe in the Opting Out f Cmmunicatins sectin belw. Back t tp Infrmatin Sharing and Disclsure We d nt sell r rent yur persnal infrmatin t third parties. Frm time t time, we may share yur persnal infrmatin with ur affiliates, retail partners and ther third party business partners (and their service prviders), such as in the fllwing circumstances: t cnduct research and/r analysis regarding prducts, cnsumers and ther matters; t allw us t better understand yur interests, activities, demgraphics and prfile; t prevent such parties frm sending prmtinal messages n ur behalf t peple wh have asked us t nt send such messages; r if yu have pted-in t receive prmtinal cmmunicatins frm us, send a tailred prmtinal cmmunicatins t yu jintly ffering a prduct r service. We will require these parties t maintain the cnfidentiality f yur persnal infrmatin, and will nt authrize them t use the persnal infrmatin we prvide fr their direct marketing purpses, unless we have explicitly given yu the ptin t pt-in t such disclsure and use. Sme f these parties are lcated in cuntries that d nt prvide an equivalent level f prtectin as yur hme cuntry. We have taken apprpriate measures t allw and secure the transfer f yur persnal infrmatin t these recipients fr the purpses described abve and in rder t cmply with lcal data privacy laws, including by entering int data transfer agreements based n the Mdel Cntractual Clauses f the Eurpean Cmmissin. We rely n third party service prviders t perfrm a variety f services n ur behalf, and we may disclse yur persnal infrmatin t such service prviders, such as fulfillment services, sweepstakes and cntest administratrs, lyalty and rebate prgram peratrs, technical supprt prviders, custmer service prviders, delivery services, e-cmmerce prviders, credit card prcessers and research and analytics prviders. Hwever, we d nt authrize these third parties t use yur data fr purpses ther than fr which it has been prvided, and d nt authrize these third parties t disclse that infrmatin t unauthrized parties r use that infrmatin fr their direct marketing purpses.. T find ut mre infrmatin abut ur plicies and practices with respect t service prviders utside f yur cuntry f residence, please cntact us using the methds listed belw under Cntacting Us. Additinally, we will use and disclse persnally identifiable infrmatin we believe t be necessary r apprpriate: (a) under applicable law, including laws utside yur cuntry f residence; (b) t cmply with legal prcess; (c) t respnd t requests frm public and gvernment authrities including public and gvernment authrities utside yur cuntry f

6 residence; (d) t enfrce ur terms and cnditins; (e) t prtect ur peratins r thse f any f ur affiliates; (f) t prtect ur rights, privacy, safety r prperty, and/r that f ur affiliates, yu r thers; and (g) t allw us t pursue available remedies r limit the damages that we may sustain. In additin, we may transfer persnal infrmatin and ther infrmatin t a third party in the event f any rerganizatin, merger, sale, jint venture, assignment, transfer r ther dispsitin f all r any prtin f ur business, brands, affiliates, subsidiaries r ther assets. We may ffer cmmunity features and public interactive frums thrugh ur Prperties, like discussin bards, prduct reviews, chat rms, frums, wikis, scial netwrking platfrms and blgs. When yu participate in such fferings, yur username and ther persnal infrmatin yu chse t prvide r cmmunicate in these public spaces may be seen by thers, and yu shuld exercise cautin when disclsing such infrmatin and realize that infrmatin yu pst culd remain viewable in cached r archived webpages r cpied and stred by ther users even after yu remve it. We cannt cntrl the actins f ther users f ur Prperties, and we are nt respnsible fr the results f yur pstings. Furthermre, when yu participate in these interactive features, yu may be agreeing t terms f use that, amng ther things, allw us t use yur name and ther infrmatin in ur marketing and advertising. We may share aggregated, statistical r annymus infrmatin that des nt identify yu with third parties. Fr example, we may disclse the number f visitrs t ur websites, the number f peple wh have dwnladed a particular cupn r the number f peple frm a certain state wh purchased a prduct frm ne f ur e-cmmerce websites. We ccasinally partner with ther cmpanies t run jint prmtins r ffer yu separate third party prmtins. When yu prvide infrmatin fr these prmtins, please nte whether yu are prviding yur infrmatin directly t that party t use fr their wn marketing purpses. In such instances, their use f yur infrmatin will be gverned by such party s wn privacy plicy. Back t tp Interest-based Advertising We may place r recgnize a unique Ckie n yur brwser when yu visit ur Prperties fr purpses f serving yu targeted advertising (als referred t as nline behaviral advertising ). We als allw third-party cmpanies t place their wn Ckies n yur brwser when yu visit ur Prperties, s that they can cllect persnally identifiable infrmatin abut yur nline activities ver time and acrss different sites and serve custmized advertisements t yu as yu brwse the Internet. While sme brwsers have a d nt track feature that lets yu tell websites that yu d nt want t have yur nline activities tracked, these features are nt yet unifrm and ur Prperties are nt currently set up t respnd t these signals. Back t tp Strage f Persnal Infrmatin We will retain persnal infrmatin fr the perid necessary t fulfill the purpses utlined in this Privacy Statement and as therwise needed t cmply with applicable law and internal cmpany plicies. We use secure methds t destry persnal infrmatin when it is n lnger needed, including the use f reasnable technical and physical security measures t avid unauthrized access t r use f the persnal infrmatin after it is dispsed. Back t tp Accessing and Updating Yur Persnal Infrmatin If yu have created an nline accunt n ne f ur websites and wuld like t update the persnal infrmatin yu have prvided t us, yu can access yur accunt n the applicable website t view and make changes r crrectins t yur persnal infrmatin. Yu may als

7 cntact us using the methds described belw under Cntacting Us t request access t yur persnal infrmatin, t be infrmed f persnal infrmatin that we hld abut yu, t have inaccurate persnal infrmatin updated, crrected r remved and t bject t the prcessing f yur persnal infrmatin as described in this Privacy Statement fr legitimate purpses, except where the data prcessing is implemented in cmpliance with mandatry prvisins f the applicable law. We will try t cmply with yur request as sn as reasnably practicable and in any case in cmpliance with applicable regulatins. Back t tp Opting Out f Cmmunicatins If yu n lnger want t receive marketing-related s frm ne f ur brands n a gingfrward basis, yu may pt-ut f receiving marketing-related s by clicking the "unsubscribe" link at the bttm f any newsletter yu receive frm that brand, r, if yu created an nline accunt when yu registered t receive ur s, yu may lg-in t yur accunt n the applicable brand s website and make changes t yur cmmunicatin preferences. If yu n lnger want t receive prmtinal text messages frm ne f ur brands, please fllw the cancellatin instructins cntained in the last text message sent by that brand. If yu are having difficulty unsubscribing frm ur marketing cmmunicatins using the abve methds, please cntact us directly using the methds listed belw under Cntacting Us. Please allw reasnable time fr us t prcess yur request. Hwever, please nte that even if yu pt-ut frm receiving marketing cmmunicatins, we may need t send yu service-related cmmunicatins and may need t keep infrmatin we have cllected abut yu fr recrdkeeping, research and ther purpses. Als, please nte that if yu participated in a prmtin that invlved a third party, and, as part f that prmtin, yu agreed t receive future marketing cmmunicatins directly frm that party, yu will need t cntact that party t pt-ut f such cmmunicatins. This prcess may be utlined in that party s privacy plicy. Back t tp Security We use cmmercially reasnable rganizatinal, technical and administrative means intended t prtect stred and transmitted infrmatin frm lss, misuse and unauthrized access r disclsure, and we encrypt credit card numbers frm e-cmmerce transactins cnducted n ur Prperties using secure scket layer (SSL) technlgy. Hwever, n methd f Internet transmissin r electrnic strage is 100% secure r errr-free, s we unfrtunately cannt guarantee abslute security. If yu have reasn t believe that yur interactin with us is n lnger secure (fr example, if yu feel that the security f any accunt yu might have with us has been cmprmised), please cntact us immediately. Back t tp Websites Nt Cvered by this Privacy Statement Our Prperties may cntain links r references t ther websites r services that are managed by third parties r that are managed by us but cntain a different privacy statement. This Privacy Statement gverns nly infrmatin that we cllect thrugh ur Prperties that link t this Privacy Statement, and nt t websites, services r applicatins that d nt link t this Privacy Statement r that are maintained and cntrlled by ther cmpanies r rganizatins, including third party websites linked t frm ur Prperties, as well as cmmunicatins frm third parties that reference ur cmpany r prducts. Fr example, sme f ur Prperties may ffer yu the ability t make purchases using thirdparty e-cmmerce prviders r payment services. In thse instances, yu will be directed t a webpage that is hsted by the third party (r its service prviders) and nt by us. Unless therwise stated, any persnal infrmatin that yu prvide thrugh that third party webpage will

8 be cllected by that party and nt by us, and will be subject t that party s privacy plicy, rather than this Privacy Statement. In such a situatin, we will have n cntrl ver, and shall nt be respnsible fr, that party s use f the infrmatin yu prvide t them. Please nte that many f the websites we perate utside f yur hme cuntry are gverned by separate privacy plicies linked t frm thse websites. This Privacy Statement als des nt cver the ffline cllectin f infrmatin by us frm yu unless yu have been ntified that this Privacy Statement applies at the time f cllectin. The cllectin and use f yur infrmatin by and thrugh third party websites, applicatins r ther means will be gverned by the privacy plicies applicable t thse third parties and mediums. The inclusin f a link r reference n the Prperties des nt imply endrsement f the linked site by us r by ur affiliates. Websites may cntain ur name, lgs, prducts r ther branding even thugh they are actually perated by third parties that may r may nt have a relatinship with us. Therefre, we encurage yu t read the privacy statement f every service, applicatin, r website yu visit r interact with. Back t tp Children Under the Age f 13 Our Prperties are nt intended fr children under the age f 13 and we d nt knwingly cllect persnal infrmatin frm children under age 13. Children under the age f 13 shuld nt use ur Prperties and shuld nt prvide their persnal infrmatin t us. If yu are yunger than age 18, yu may use ur website nly with the permissin and invlvement f yur parents r guardian. Back t tp Crss-Brder Data Transfers Because we perate glbally, yur persnal infrmatin may be stred and prcessed in any cuntry where we have facilities r in which we engage service prviders. By using ur Prperties, yu cnsent t the transfer f infrmatin t cuntries utside yur cuntry f residence, including the United States, which may have different data prtectin rules than in yur cuntry. Where required, Clrx has implemented apprpriate safeguards fr the transfer f such persnal infrmatin, including by entering int data transfer agreements based n the Mdel Cntractual Clauses f the Eurpean Cmmissin, if applicable. Back t tp Cntacting Us Please direct any inquiries related t this Privacy Statement r persnal infrmatin we have cllected abut yu t ur Privacy Team by cmpleting this nline frm. If yu have any questins r cmments abut ur cmpany r ur prducts r have ther custmer service needs, please click here fr infrmatin n cntacting ur cnsumer service representatives. Back t tp Changes t this Privacy Statement We will update this Privacy Statement frm time t time t reflect changes t ur practices, technlgy, legal requirements and ther factrs. Please check the Last Revised legend at the tp f this page t see when this Privacy Statement was last revised. When changes are made t this Privacy Statement they will becme immediately effective when published in a revised Privacy Statement psted n this page unless therwise nted. Yur use f the Prperties fllwing these changes indicates yur cnsent t the practices described in the revised Privacy Statement. Back t tp