Last updated on March 31, 2020.
Glow takes issues of privacy and the protection not only of personal health information, but all kinds of information about your private life very seriously. As discussed below we take great efforts to protect your information from disclosure, to use your information only to provide services to you, to improve the service for you, to improve our ability to provide services to other people in a similar situation, and to assist researchers in finding better ways to improve health.
WE DO NOT SELL OR RENT YOUR PERSONAL DATA TO THIRD PARTIES. WE DON’T SHARE YOUR INFORMATION (OTHER THAN FORUM POSTS) TO SOCIAL NETWORKS OR OTHER PUBLIC OR SEMI-PUBLIC PLACES UNLESS INSTRUCTED BY YOU TO DO SO.
We only disclose your information to you or as you authorize us to (although we may include certain elements of that information in our data base on an anonymized basis). However, we wish to remind you that the kind of information Glow collects is significantly more sensitive than the information you may be providing to other application providers – and you should be extra careful before instructing us to share that information with anyone else. Your menstrual cycles, fertility information and pregnancy status are much more sensitive than the number of steps you took today or where you were when you took your most recent selfie – we recognize that and recommend that you take extra care before deciding to ask us to share it with anyone.
PARTICULARLY IMPORTANT INFORMATION
Who We are: For the purpose of applicable data protection legislation, the data controller of your personal data is Upward Labs Holdings, Inc. of 555 Kearny Street, 7th Floor San Francisco, California. We are in the process of identifying and appointing a Representative in the EU, but in the meantime, our EU Representative is Allen Xu, reachable through EURepresentative@glowing.com. Our data protection officer is Allen Xu, reachable through GlowDataProtectionOfficer@glowing.com
Must Read Sections: We direct your attention in particular to the sections entitled “International Data Transfer” and “Your Rights”.
PURPOSES OF PROCESSING
Note that not all Glow account types and features are available in all locations, so some of the examples below may not apply where you live.
WHAT WE COLLECT
Information You Give Us:
Glow gives you a number of options regarding what information you will give us:
- When you register to create an account with Glow and/or Glow Premium (whether through one of the Glow Apps or on the Internet);
- When you participate on a Forum or other communication mechanism; and
- When you update a Glow App or the Website with information relevant to your fertility or pregnancy,
When you register with Glow you will submit a variety of personal data (such as gender, age, birthdate, name, email address, mobile phone number) and as you use the Glow Apps you may submit a variety of information (such as menstrual cycle, weight, temperature, occupation, hobbies, interests, zip code, etc.) which may include sensitive personal data about personal health issues and/or information related to your past, present, or future physical or mental health condition (“Sensitive Personal Data”). You may also choose to provide us with access to certain personal data stored by third parties including social media sites (such as Facebook and Twitter) and health sites, such as Samsung Health, Apple HealthKit and Google Fit. The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. You may (and may be required to) share information about or give us access to additional third-party websites or services.
If you register to use Glow features with a healthcare provider we will share personal data including Sensitive Personal Data with your healthcare provider that is using such features.
If you choose to participate in Glow Premium or become a party to the Glow Fertility Services Patient Agreement, not only may you need to provide us with Payment Information, but if you become entitled to receive a payment from Glow Premium, you will need to provide us with your social security number as well as information about an accredited infertility clinic and proof of medical claims showing that you are using their services. We may use that information in making filings with the IRS or relevant state taxing authorities.
User Generated Content
In addition to information about yourself, it may be possible for you to submit other content ("Content"), such as photos and other media, each of which you present through technology available through the Services, including but not limited to our forum. It is entirely up to you whether you want to submit this additional information, and whether you would like to make it available to others – although information you share on the forum will automatically be shared with others, including users of the Services and others on the internet. However, Glow has no responsibility for how people you allow to view your Content (or the public if you make any information available to the public or post on the forum) use that material, or to whom they may forward it. We urge you to be very careful when deciding to disclose your personal data, or any other information, on the forum. Such personal data and other information will not be private or confidential once it is published on the forum.
If you send or disclose any Sensitive Personal Data to us when you submit user generated content on our forum, you consent to our processing and use of such Sensitive Personal Data in accordance with this Policy. If you do not consent to our processing and use of such Sensitive Personal Data, you must not submit such user generated content to our Website.”
In each case, we will collect and record the information you have provided.
Information We Automatically Collect:
If you visit this Website, be advised that Company will maintain web logs to record data about all visitors and customers who use this website and interact with the Services and we will store this information. All web logs are stored securely and are accessible to a very limited number of employees who are required to adhere to strict guidelines regarding user data security and privacy.
Furthermore, when you use one of the Glow Apps, we may record information regarding the use of that Glow App, including your cell phone number, and if such facilities are enabled on your cell phone, your location and similar information.
Finally, in order to provide the best possible service and to allow us to make certain internal reports and make recommendations, we collect aggregate information about the use of the Service, including information about users accessing this website or using the Glow Apps, such as Internet protocol addresses, browser type, browser language, referring / exit pages and URLs, other browser history, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time (“Activity Information”). We use Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie (_ga) with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use GA to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. If you would like to access what browsing information we have - or ask us to delete any GA data - please delete your _ga cookies, reach out to us via this form, and/or install the Google Analytics Opt-Out Browser Add-On.
When you visit the Services, we may also store information based on your usage history. This includes, but is not limited to, details of your transactions, content you viewed, click stream information, and cookies that may uniquely identify your browser or your account. We use various technologies to collect and store information which may include sending one or more cookies or anonymous identifiers to your device. Please refer to the section on cookies below.
Information We Collect From Other Sources:
Information from Health Sites. Our Services include interfaces that allow you to connect with health sites, such as Samsung Health, Google Fit or Apple Healthkit. We may add this to information we get from our Services. Please refer to the section “Information Shared with Other Systems, Such As Samsung Health, Apple Healthkit or Google Fit” below for more information.
HOW WE USE/SHARE YOUR INFORMATION
We may use personal data to verify your identity, verify your address, or manage risk. We may also use personal data to perform and improve our Services, contact you, conduct research, and provide anonymous reporting for medical research. For example, we may use information to provide customer service and support, process transactions, resolve disputes, collect payments, prevent illegal activities, customize the Services and recommendations, reduce risk to all parties involved in our transactions, and verify the accuracy of information.
We make your profile available to other users according to the privacy settings you set for yourself as part of your profile. Your user name will be identified to us and to any recipient of messages you send through the Services, including on forums. We also use your name, email address and other information on our system to notify you of new product releases, service notifications, and to solicit your feedback and input. In the event that we decide to allow you to submit other information about yourself, the availability of that information to other users will also be controlled by privacy settings you may set for yourself.
We share your personal data with employees and affiliates, as well as certain vendors, partners and third parties as required to offer the Services. This includes, but is not limited to, processing transactions, maintaining your account, responding to court orders and legal investigations, for litigation purposes, complying with audits or other investigations, and reporting to credit bureaus. We do not profit from your personal information and do not share your information with advertisers.
We may combine your personal data with information we collect from other companies and use it to improve and personalize the Services, content, and communications with you. We may also do so in order to improve our prediction methodologies and algorithms.
We may combine your personal data with information we collect from other users in an aggregate and anonymous format and share this anonymous data with third parties. When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We do this in order to improve the quality of the information we provide to you and to other users.
Protected Health Information
We maintain “protected health information” (as defined in the Health Insurance Portability and Accountability Act, “HIPAA”) in compliance with applicable health care privacy and security rules and our contractual obligations with our business partners and customers, including health care providers and their contractors (who are also subject to HIPAA). In the case where your healthcare provider uses certain Glow features and you establish an account with us to allow such usage, we act as a conduit between (a) health care providers offering fertility-related services, (b) other persons involved in the arranging, provision or financing of health care services and (c) end users such as you, and share your protected health information in connection with those services only in accordance with applicable law.
We may use personal data to deliver products, or service update notices, and promotional offers based on your communication preferences. With your consent (either in response to an email request or in certain cases, pursuant to the preferences you’ve expressed in your profile), we may send you marketing e-mails about upcoming promotions, and other news, including information about products and services that may be of interest to you. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you. We may combine your information (after it has been anonymized) with information we collect from other companies and use it to improve and personalize the Services, content and advertising. We may also do so in order to improve our prediction methodologies and algorithms.
Third Party Content
We may decide to share information about your transactions and experiences using the Glow Service (but not about your creditworthiness) to our affiliates for their everyday business purposes.
We will share your information with any party when required by law or by a government request to do so or to combat fraud or criminal activity.
CONTROLLING YOUR PERSONAL DATA
Be advised that if you send messages or post material on or forums or elsewhere containing personal data, that data may be collected and used by others. The Services provide a number of tools that you can use to control the availability of your profile and other personal data, but forum posts will be available to the general public. You can edit your profile and other data at any time through each of the Glow Apps and/or the Website.
You can terminate your account at any time, which will remove your profile and other personal data from view. Glow, however, may (but is not obligated to) keep information about you that is on its system following your termination, and your forum posts will continue to be available online. You may request complete deletion of your personal data (other than forum posts) by writing firstname.lastname@example.org. Subject to the provisions of your Glow Fertility Program Patient Services Agreement, if any, we will delete your data within 60 days of our receipt of that request. Contact Glow at email@example.com to terminate your account or for any other questions about your personal data and/or forum posts. Unless you request the deletion of your personal information and subject to applicable law, Glow maintain copies of your content indefinitely, even after you terminate your account.
INFORMATION SHARED WITH OTHER SYSTEMS, SUCH AS SAMSUNG HEALTH, APPLE HEALTHKIT OR GOOGLE FIT
In addition, in the event that you use one of those services, you should be careful about allowing other applications, services or people to access your information through that service. While much information collected by those services is innocuous, people who see Glow data may be able to determine a variety of personal data, such as that you are trying to become pregnant or when you are likely to be having your period.
Glow does not use or disclose to third parties personal data or other information gained through the use of Samsung Health, the HealthKit framework or Google Fit for advertising, other use-based data mining purposes or similar services, other than for purposes of improving health or for purposes of health or medical research.
We do not disclose any of your personal data, to any third party without your express permission (other than as provided herein or in anonymized and aggregated format), and in the case of information gained through Samsung Health, HealthKit or Google Fit such sharing will only be for purposes of enabling the third party to provide health and/or fitness services or for medical research.
We do not sell any of your personal data, including personal data gained through Samsung Health, HealthKit or Google Fit, to advertising platforms, data brokers or information resellers.
We do not use any of the personal data obtained through Samsung Health, HealthKit or Google Fit for any purpose other than providing health and/or fitness services in connection with the Glow Apps.
You may decide to provide us with another person's email address so that person may be invited to join Glow or so that we may facilitate your communication with other people through the Services. You may also provide us with another person's contact information for purposes of delivering information through the Glow Apps. We use this information to contact and, if necessary, remind that person that he or she has been invited to join Glow or receive content through one of the Glow Apps. All invitees are provided with the option not to receive further invitations from Glow. We may disclose such information if required to do so in order to comply with legal process, as described above.
AUTOMATED DECISION MAKING AND PROFILING
We do not generally use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
THIRD PARTY SITES
The Services may contain links to other web sites, and content in the Glow Apps may be hosted by other web sites. These other sites maintain their own policies regarding cookies and the collection and use of personal data. It is up to you to review those policies yourself.
INTERNATIONAL DATA TRANSFER
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the Glow Apps or Services you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We use reasonable organizational, technical and administrative measures to protect personal data within our organization. If you have any questions regarding which measures and techniques we use, feel free to contact us. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the Internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised, please immediately notify us of the problem by contacting us using the details set forth in the section titled “Additional Questions” below.
In addition, we urge you to take precautionary measures in maintaining the integrity of your data. Please be responsible in making sure no one can see or has access to your personal accounts and log-in username and password information. If you use a public computer, such as one at a library or a university, or a shared device, always remember to log out of the Glow Apps or Services.
If you use the Glow Apps or Services through your employer’s computer network a mobile device owned by your employer or through an internet café, library or other potentially non-secure internet connection, such use is at your own risk. It is your responsibility to check beforehand with each such company’s privacy and security policy with respect to Internet and mobile device use.
We cannot guarantee the identity of any other person with whom you may interact in the course of using the Glow Apps or Services, or the authenticity of any information that others may provide.
Company is not responsible for your handling, sharing, re-sharing and/or distribution of your personal health information. Moreover, if you forward personal health information electronically to another person on or off any Glow Apps or the Services, we are not responsible for any harm or other consequences from third party use or re-sharing of your information.
We will only retain your personal data as long reasonably required for you to use the Glow Apps and/or to provide you with the Services unless a longer retention period is required or permitted by law (for example for regulatory purposes). You may request that we delete data you have provided by sending an email to firstname.lastname@example.org. Subject to the provisions of your Glow Fertility Program Patient Services Agreement, if any, we will delete your data within 60 days of our receipt of that request.
We do not knowingly allow individual Users who are identified as located in the European Economic Area and under the age of 16 or who are identified as located outside the European Economic Area and under the age of 13 to create accounts that allow access to our secure site or that use Glow Apps, without them obtaining the prior consent of a parent or guardian.
- Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of Sensitive Personal Data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data from a server or business located in the European Economic Area to a server or business outside the European Economic Area. Please note that your use of some of the Glow Apps or Services may be ineffective upon opt-out.
- Access. You may access the information we hold about you at any time via your profile/account or by contacting us directly.
- Amend. You can also contact us to update or correct any inaccuracies in your personal data.
- Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us using the details set forth in the section titled “Additional Questions” below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
Please contact email@example.com if you would like to receive a copy of this document showing changes from previous versions.
GLOW PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: January 1, 2020
Last Reviewed on: January 1, 2020
INFORMATION WE COLLECT
Our Website and Applications (the “Platform”) collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our Platform has collected the following categories of personal information from its consumers within the last twelve (12) months:
Category A: Identifiers
Examples: A real name, Internet Protocol address, email address, account name, iOS IDFAs, Android Ads IDs or other similar identifiers.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Category D: Commercial Information.
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Category F: Internet or other similar network activity.
Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Category G: Geolocation data.
Examples: Physical location or movements.
Collected: YES (if selected and enabled by user)
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Glow obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete on our website. If you send messages or post material on or forums or elsewhere containing personal data, that data may be collected and used by others.
- Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.
- From apps you associate with our Platform. For example, if you instruct us to share certain of your personal data (including Sensitive Personal Data) with systems such as Samsung Health, Apple’s Healthkit or Google Fit, and to access personal data from those systems which we will use to improve the services we provide to you and, we hope, make our information more accurate for you as an individual.
USE OF PERSONAL INFORMATION
We may use, or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide customer service and support, personalize, and develop and improve our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process transactions, resolve disputes, collect payments, prevent illegal activities, customize the Services and recommendations, reduce risk to all parties involved in our transactions, verify the accuracy of information and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE
Glow may share the following categories of your personal information for a business purpose (as we have done for the preceding 12 months) to provide you with a variety of the Glow Platform’s features and services:
- Personal identifiers, such as your name, address, email address, date of birth, government identification number (such as social security number), driver’s license information, vehicle information, and car insurance information.
- Personal information such as your age, gender, and pregnancy status whether you are trying to conceive (TTC), not trying to conceive (non-TTC) or pregnant.
- Financial information, such as bank routing numbers, tax information, and any other payment information you provide us.
- Commercial information, such as your transaction history.
- Internet or other electronic network activity information, such as your IP address, type of browser, version of operating system, carrier and/or manufacturer, device identifiers, and mobile advertising identifiers.
- Location data. We may use certain information like your IP address or other Device Information or Log Information to estimate your location (e.g., your city or state). We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance our Services. We will only use these location-enabled services on your device with your consent, though.
- In Connection with Sale or Merger: We may share your personal information while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.
- Upon your further direction: With your permission or upon your direction, we may disclose your personal information to interact with a third party or for other purposes.
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
SALES OF PERSONAL INFORMATION
The definition of “sale” in California law is somewhat ambiguous. In the preceding twelve (12) months, Company has not sold your personal information as we understand that term and does not anticipate doing so in the future. However, you should review the discussion above to see how certain aspects of your personal information are used, some of which may be treated as a “sale” under California law.
YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
DELETION REQUEST RIGHTS
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website or calling us at 1 (513) 813-1382. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
RESPONSE TIMING AND FORMAT
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by the following means: visiting our webpage and sending us a message, calling us at 1 (513) 813-1382, or sending a letter to our address listed on our website.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website, call us at 1 (513) 813-1382, or write us at our address listed on our webpage.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
HOW YOU CAN CONTACT US