Effective date: November 5, 2021
Framebridge, Inc. (“Framebridge”) provides this Privacy Statement to let you know our policies and procedures regarding the collection, use and disclosure of information through www.framebridge.com, our mobile application, and any other websites, features, applications, widgets or online services that are owned or controlled by Framebridge and that post a link to this Privacy Statement (the “Site”), as well as any information Framebridge collects offline in connection with the Site. This Privacy Statement applies to information collected from the effective date forward; information collected while a previous Privacy Statement was in effect remains subject to the terms of that former policy.
This Privacy Statement also explains how we may use and disclose such information, as well as your ability to control certain uses of it. By using this site, you agree to the data collection, use, disclosure and storage practices described in this Privacy Statement.
We collect information about you in a range of forms, including personal information, when you choose to provide it to us. Personal information (or personal data) means information a bout an individual from which that person can be identified. It does not include personal information where the identity has been removed (anonymous personal information). This may include when you purchase a product, contact us with inquiries or otherwise contact us.
When you interact with us through the Services, we may collect information from you, as further described below.
We are committed to protecting your personal information and your right to privacy. Please read this Privacy Statement carefully as it will help you make informed decisions about sharing your personal information with us.
Information You Provide to Us
Information Received from Third Parties
Information Collected from Other Sources
Combination of Information
Information Collected from Users Automatically
How We Respond to Do Not Track Signals
User Generated Postings
Use and Retention of Information
Information Sharing and Disclosure
Information You Agree to Receive from Third Parties or Request That We Share
Legal and Investigative Purposes
Internal and Business Transfers
Sweepstakes, Contests and Promotions
Third Party Analytics Providers, Ad Servers and Similar Third Parties
Your Choices and Opting Out
Changing Your Information or Closing Your Account
International Transfers of Personal Information
Links to Other Sites
California Residents – Your California Privacy Rights
Changes to this Statement
Information You Provide to Us
We collect information from you when you choose to provide it to us. This may include when you purchase a product, create an account with us, sign up for our email lists, use our Services, submit a rating or review, participate in a survey or promotion, or otherwise contact us.
You also may provide information to be published or displayed on public areas of the Site, or transmitted to other users of the Site or third parties, or in connection with placing an order (collectively, "User Submitted Materials").
If you have created an account, you may be able to voluntarily provide additional information in various areas of the Site. For example, you may want to provide additional information as part of an optional profile to enhance your experience and use its features. We may use this information to personalize the Site and its features just for you.
Your User Submitted Materials are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Payment Information: If you use the Site to make purchases, we will also collect certain payment information, such as payment card, PayPal, Square, or other financial account information, and billing address. A third-party payment processor collects that information; we do not store your credit card information. We may also collect additional types of personal information that you choose to provide to us. This could include information about yourself or family members. It’s up to you whether you provide this information. We will not disclose any of this personal information unless you expressly authorize us to do so.
Non-Identifying Information: We also may collect other information, such as ZIP codes, and other information regarding your use of the Site (“Non-Identifying Information”) or from you in response to surveys. Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). We may combine your Personal Information with Non-Identifying Information, but Framebridge will treat the combined information as Personal Information.
Children under age 13: Protecting children’s privacy is important to us. We do not direct the Services to, nor do we knowingly collect Personal Information from, children younger than age 13.
No one under age 13 may provide any personal information to the Site. If you are under age 13, do not use or provide any information on this Site or through any of its features, register on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under age 13 without verification of parental consent, we will delete that information. If youbelieve we might have any information from or about a child under 13 please contact us at firstname.lastname@example.org.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.
Information Collected From Other Sources
We may obtain information about you from other sources, including social networks that you use to connect with Us. If you use a third party service to login, link to us, or communicate with us (such as a social network or third party video chat), we may receive certain information about you from the third party based on your registration and privacy settings on those third party services. This information may include name, user name, demographic information, updated address or contact information, interests, and publicly-observed data, such as from social media and online activity.
Information Received from Third Parties
We also may receive information about you from third parties. If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. For example, we may supplement the information we collect with outside records, or third parties may provide information in connection with a co-marketing agreement or at your request (such as if you choose to sign in with a third-party service such as Facebook). If we combine the information we receive from others with Personal Information we collect through the Site, we will treat the combined information as Personal Information as described in this Privacy Statement.
We and our third party service providers, including advertisers, analytics, and third party content providers, may automatically collect certain information from you whenever you access or interact with the Site. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Site, the search terms you entered into a search engine that led you to the Site, areas within the Site that you visited, and other information commonly shared when browsers communicate with websites. When service providers receive this information, they are not permitted to use the information collected on our behalf except to help use conduct and improve our business.
We capture the following information:
• Domain Name – through which you access the Internet (for instance, MSN for Microsoft Network, or Yahoo, etc.)
• IP address – from the computer or network used to access our website
• Web browser – and operating system used
• Date and time – you accessed our site
• Referral Internet address – of the website from which you clicked to get to our website
• Search terms – used in a search engine (like google.com) that brought you to our website
We may also use third-party tools or services, such as Google Analytics, to assist us with analyzing and improving the Site and Services. These service providers are not permitted to use the information collected on our behalf except to help use conduct and improve our business.
The information we collect also includes the Internet Protocol (“IP”) address or other device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Site. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Site, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Site. If such information is linked to your Personal Information, we will treat it as Personal Information under this Privacy Statement.
The technology used to collect information automatically from Framebridge Users may include the following:
Cookies: Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use both persistent cookies that remain on your computer or similar device (such as to save your registration ID and login password for future logins to the Site and to track your compliance with any Framebridge applicable policies) and session ID cookies, which expire at the end of your browser session (for example, to enable certain features of the Site, to better understand how Framebridge Users interact with the Site and to monitor aggregate usage by Framebridge Users and web traffic routing on the Site). You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all functionality of the Site.
Web Beacons: We may also employ software technology known as “web beacons” or “tracking tags” to help us keep track of what content on our Site is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Site, to monitor how Framebridge Users navigate the Site, to count how many e-mails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
Embedded Scripts: An Embedded Script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Site. In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.
How We Respond To Do Not Track Signals
Choices About How We Use and Disclose Your Information and California Do Not Track Disclosures.
We strive to provide you with choices regarding the personal information you provide to us.
You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences.
We work with third parties to collect user data through our website or mobile device for purposes of serving ads targeted to your interests. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website by clicking here.
On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Not Track headers or requests from some or all browsers.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to email@example.com.
• Promotional Offers from Us. If you do not wish to have your email address used by us to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to firstname.lastname@example.org. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an email with your request to email@example.com.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
User Generated Postings
USE AND RETENTION OF INFORMATION
Framebridge may use information collected through the Site, including your Personal Information and Device Identifier, in order to:
- present the Site and its contents to you
- process your registration with the Site, including verifying the information that you provide to us;
- provide you with services or information or fulfill transactions that you have requested or otherwise agreed to receive;
- send you marketing communications, special offers from us, artists on our Site, our advertisers, or third-party business partners or other third-parties that we believe may be of interest to you, and to tailor content we display to you, including offers we present to you, both on the Site and elsewhere online or offline;
- publish promotional material, including in such material Community Postings that you have made;
- allow you to participate in the public areas and other features of the Site;
- provide customer service to you, including, without limitation, to respond to your questions, complaints or comments, fulfill orders, process payments and prevent transactional fraud, and contact and communicate with you;
- contact you with regard to your use of the Site or, in our discretion, changes to the Site's policies;
- improve the content and functionality of the Site or our services, and for internal business purposes;
- for legal and regulatory compliance;
- display content based upon your interests;
- protect our rights, privacy, safety or property and/or that of you or others;
- develop new programs, products or services;
- protect the security or integrity of the Services and our business;
- enforce this privacy statement; or
- as described to you at the point of data collection or otherwise with your consent, and as further described in this Privacy Statement.
INFORMATION SHARING AND DISCLOSURE
We may disclose Personal Information and Non-Identifying information to third parties in our discretion as otherwise described in this Privacy Statement. We may share the information we collect from and about you, including with third party data brokers and for list exchange purposes with other companies as part of a list cooperative membership environment, such as with Epsilon, Oracle, Wiland, to enable them and us to provide you with information about products or services. In particular, we may share the information we have collected about you for the following purposes:
(2) with our Service Providers, if the disclosure will enable them to perform a business, professional or technical support function for us, including as part of our agreement with our Customers.
We may employ third party companies and individuals to perform services on our behalf, such as to host the Site, perform Site-related functions (e.g., without limitation, maintenance services, database management, data analytics, web analytics and online advertising, payment processing, fraud detection and improvement of Framebridge’s features) or to assist us in analyzing how our Site is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf subject to the privacy policies of those third parties.
(4) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
(5) to respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, national security or law enforcement, as permitted by law, or otherwise as required by law.
(6) for internal and affiliates purposes.
Framebridge may share information, including Personal Information, with its parents, subsidiaries, and affiliates, primarily for business and operational purposes. We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due diligence process with any potential acquiring entity) or in the event of bankruptcy.
(7) for sweepstakes and other promotions.
We may offer sweepstakes, contests, and other promotions (any, a "Promotion") that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winner’s list. In some instances, a Promotion may be hosted by a different website than Framebridge. In such instances, that website will have a different Privacy Statement from this one, and you should review such website’s Privacy Statement to see how your Personal and Non-identifying Information will be used.
(8) as described to you at the point of collection.
We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Statement.
We also may share aggregate or anonymous non-personal information with third parties for their marketing or analytics uses.
If you do not want us to share your personal information as set forth in this Privacy Statement, contact us at firstname.lastname@example.org.
THIRD PARTY ANALYTICS PROVIDERS, AD SERVERS AND SIMILAR THIRD PARTIES
Framebridge works with (or may in the future work with) network advertisers, ad agencies, analytics service providers, and other vendors to provide us with information regarding traffic on the Site, including pages viewed and the actions taken when visiting the Site; to serve our advertisements on other web sites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Site and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Site as well as other web sites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Site or other online websites and services.
While we may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative ("NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note that opting out through these mechanisms does not opt you out of being served advertising, and you will continue to receive generic ads while online.
YOUR CHOICES AND OPTING OUT
Registered Users may update their choices regarding marketing communications you receive from us through your online account. You also may opt-out of receiving marketing e-mails from us by following the opt-out instructions provided in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of the Site (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications. If you choose to receive text messages from us, you may change your mind and opt-out of receiving future text messages by replying “STOP” to any text message received.
ACCESSING, MODIFYING OR DELETING YOUR INFORMATION
You can review and change your personal information by logging into the Site and visiting your account profile page.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information, and you must update any changes through your online account. If you would like us to delete your account in our system, you can do so by sending an email to us at: email@example.com. We will use commercially reasonable efforts to honor your request; however, certain information will actively persist on the Site even if you close your account, including messages you posted to the Site. In addition, your Personal Information may remain in our archives and information you update or delete, or information within a closed account, such as your purchase history, may persist internally or for our administrative purposes. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove information you posted publicly through or on the Site. Bear in mind that neither you nor Framebridge can delete all copies of information that have been previously shared with others on the Site.
You may also send us an email at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
The security of your personal information is important to us. We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about You. While we make every effort to help ensure the integrity and security of our network and systems, the transmission of information via the internet is not completely secure. Email sent to or from the Services may not be secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.
Data Storage and Retention
Your personal information is stored on servers in the United States or in other countries in accordance with the data storage locations of our third party vendors. You understand and agree that we may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Statement. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is needed to provide you with the Services, or to fulfill any legal or contractual obligations we may have.
INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
The Site is a U.S. website. Framebridge makes no representation that this Privacy Statement or its data practices comply with the laws of any other country. Visitors who use the Site and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you are located outside the United States, please be aware that any information you provide to us will be transferred to and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. By using the Site or providing us with any information, you consent to this transfer, storage, and processing of such information in the United States.
This Privacy Statement applies only to the Services. Our Site contains links to other websites, which may have privacy policies that differ from our own. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.
CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
This Privacy Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect
Our Site collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).
- publicly available information from government records.
- deidentified 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
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.
C. Protected classification characteristics under California or federal law.
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).
YES in connection with employee hiring and/or onboarding
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
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.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
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)).
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.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. The following businesses receive personal information from us and may resell that information. To opt-out of those sales, please visit the third-party opt-out notices at the links provided below:
• Oracle America Inc.: https://datacloudoptout.oracle.com/optout
• Epsilon Data Management LLC: https://www.epsilon.com/us/marketing-data-summary-request
• Wiland Inc.: https://privacyportal-cdn.onetrust.com/dsarwebform/7567ece3-2d27-4ee0-a506-1153cb7a62b7/a5485eb1-f1ee-4a9f-9ed4-2b8ee48b550f.html
Framebridge obtains the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Website.
Use of Personal Information
Do not sell my personal information
We may use or disclose the personal information we collect for one or more of the following purposes:
- With third party data brokers and for list exchange purposes with other companies as part of a list cooperative membership environment, such as with Epsilon, Oracle, Wiland, to enable them and us to provide you with information about products or services.
- 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, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
-For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
-To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
-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 share your personal information by disclosing it to a third party for a business purpose or sell your personal information subject to your right to opt-out of those sales. 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.
We may also share your personal information by selling it to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. In the preceding twelve (12) months, Company has sold the following categories of personal information to the categories of third parties indicated in the list below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.
We share your personal information with Service Providers and with third party advertisers, analytics, aggregators, and content providers.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity. Sharing Personal Information
In the preceding twelve (12) months, we have provided/sold the following categories of personal information to third parties:
B. California Customer Records personal information.
We provide/sell your personal information to the following categories of third parties: Third party data brokers and for list exchange purposes with other companies as part of a list cooperative membership environment, such as with Epsilon, Oracle, Wiland, to enable them and us to provide you with information about products or services.
Your Rights and Choices
The CCPA provides consumers who are 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 (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- 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.
We do not provide these access and data portability rights for B2B personal information.
Right to Delete
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 (see Exercising Access, Data Portability, and Deletion Rights), 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:
- 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
Exercising Access, Data Portability, and Deletion Rights
We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct or service providers to take similar action.
Exercising Your Rights to Know or Delete To exercise your rights to know and delete described above, please submit a verifiable consumer request to us by:
Emailing us at email@example.com
Only you, or someone legally authorized 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:
- 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.
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.
You are not required to create an account with us in order to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at firstname.lastname@example.org.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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.
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.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or older, you have the right to direct us to not sell your 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 old. 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 visiting the following internet web link: Do not sell my personal information
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. To do so, please contact email@example.com.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Non-Discrimination; Notice of Financial Incentive
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- 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.
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.
Other California Privacy Rights
Pursuant to California Civil Code Section 1798.83, California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses.
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: firstname.lastname@example.org or write to us at the following mailing address:
Framebridge Customer Support
655 15th St 3rd Floor
Washington, DC 20005
You must put the statement "Your California Privacy Rights" in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We will respond to you at your mailing address or, at our option, your e-mail address. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
If you have any questions or comments about this Privacy Statement, the ways in which Framebridge collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Framebridge Customer Support
655 15th St 3rd Floor
Washington, DC 20005
If you need to access this Privacy Statement in an alternative format due to having a disability, please contact email@example.com.
CHANGES TO THIS STATEMENT
We reserve the right to revise this Privacy Statement at any time. When we do, we will post the changes on the Site. If we change the Privacy Statement in a material way, we will provide appropriate notice to you. Your continued use of the Services after any changes or revisions to this Privacy Statement shall indicate your agreement with the terms of such revised Privacy Statement.
If you have any questions about this Privacy Statement, please contact us at:
Framebridge Customer Support
655 15th St 3rd Floor
Washington, DC 20005