2. EU GDPR and US Privacy Laws Compliance: This policy, our standard practices and the other legal terms and agreements between you and the Company are intended to comply with the terms and rules of the European Union General Data Protection Regulation first effective May 25, 2018, as may be amended (the “GDPR”), and with the terms and rules promulgated by the US Federal Trade Commission, including without limitation the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003, as may be amended (“CAN-SPAM Act”) and the Children’s Online Privacy Protection Act of 1998, as may be amended (“COPPA”). By our past, present and intended future actions, on our website or otherwise, we are not a “data processor”, nor are we in any way accepting the duties or obligations of a “data processor”, as such term may be described or defined in the GDPR.
GDPR / US FTC NOTICE: If at any time you would like to stop the collection or use of your information by us, you may opt out or unsubscribe by simply using the “unsubscribe” link or button at the bottom of any of our standard email messages to you. Keep in mind that unsubscribing or opting out in this manner may result in limitations on your use of our website, in the ongoing receipt of our services, in our ability to communicate with you, and/or in your ability to communicate with us going forward; see Section 11 below for more details.
3. What We May Collect: Under our standard practices we may collect the following information, which shall not be considered private information hereunder as between you and us, or as among you and us and our vendors:
● Contact information including email address(es).
● General demographic information such as postal codes, preferences and interests.
● Other information relevant to customer orders, surveys and/or any offers or giveaways (for example, if you are one of our giveaway winners, we will need your mailing address so we can send you your prize by post or parcel).
● Any information you may send, provide or deliver to us, either electronically or otherwise, regardless of whether we have committed not to collect it as part of our standard practices under this policy.
4. What We Do Not Collect, Hold or Control: Our standard practices include using secure third-party payment processors for any online payments to us, and also using secure third-party email service providers for communicating with you. For these reasons, and for the benefit of your privacy and security, under our standard practices we do not collect, hold or control any of the following information:
● Credit card or debit card numbers, except for the last four digits of them, which may be collected by us to provide you with any refund, if available, to verify your status as an adult, and for transaction verification purposes.
● Online financial information or bank account information.
● Internet Protocol (“IP”) addresses or Media Access Control (“MAC”) addresses.
● Dates of birth.
● Any information from persons under age 13.
● US social security numbers, Canadian social insurance numbers or other tax identification numbers, except as may be collected for tax purposes from our affiliates who are providing these numbers to us so they can receive payments from us.
5. What We Do with the Information We Gather: We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
● We may use the information to improve our products and services.
● We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
● From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, online chat, social-media connections phone, text, fax or mail. We may use the information to customize the website according to your interests.
6. Security: We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online, including our use of secure third-party payment processors and secure email service providers. Any of your information collected by these secure third-party payment processors and service providers is subject to their own privacy policies, not ours; therefore, you and we hereby agree that we will have no liability in connection with the actions or inactions of these payment processors and service providers.
7. Our Pledge to You: We will not sell, lend, lease or rent your information to third parties unless we have your permission or are required by law to do so. We may use your information to send you promotional information about third parties or the Company that we think you may find interesting. We love our users and subscribers and we will not sell or rent your email address or any other information to any third parties. Also, as part of our standard practices we do not monitor or recognize (and, therefore, cannot honor) any behavioral-advertising opt-out or do-not-track mechanisms, settings or signals, including those of your, or anyone else’s, web browser.
● A “Cookie” is a small file which is usually temporarily stored on your electronic device, often by your internet browser (a “Cookie” or “cookie” is more fully defined in the following section). The file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to work more efficiently and to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
● We use traffic log cookies to identify which pages are being used. This helps us analyze data about webpage traffic and improve our website in order to tailor it to each user’s needs. We use this information for statistical analysis purposes.
● Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your electronic device or any information about you other than the information you have elected to share with us by use of your browser and system settings.
● You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser and other system settings to decline, modify or manage cookies, if you prefer. This may prevent or limit you from taking full advantage of the website.
11. Opting Out and Managing Your Information with Us: You may choose to stop the collection or use of your information by us by opting out (also interchangeably described as “unsubscribing” below) at any time as provided here. Please note, however, if you are a member of any of our paid membership programs or an affiliate of our affiliate program, then opting out under this policy may result in a cancellation of your membership or affiliate account(s) with us, and a new membership fee or reinstatement fee may apply if you ever want to regain access to any of our membership or affiliate programs. For this reason, if you are a member or affiliate of ours, we may, at our option, email you to verify (i) that you have fulfilled or are fulfilling your obligations under any agreement you may have with us, and (ii) that you do intend to cancel your membership(s) or affiliate account(s) with us, before we close your membership(s) or affiliate account(s). If at any time you no longer want to receive emails similar to those you are receiving from us, you may opt out or unsubscribe using the “unsubscribe” link or button at the bottom of our email messages. You hereby agree that it is your sole responsibility to properly communicate your decision to opt out in accordance with this Section and this policy. You also acknowledge that your unsubscribing from one email list owned or managed by us may not unsubscribe you from every list owned or managed by us depending on how you elected to subscribe to more than one list with us or if you subscribed using more than one email address with us; therefore, you hereby agree that we may continue to send you correspondence if or when (i) you have subscribed to more than one list with us, or (ii) you have subscribed to one or more of our lists with more than one email address. In either or both of the above circumstances, it remains your sole responsibility to (i) unsubscribe from multiple lists of ours, and/or (ii) to unsubscribe for more than one email address you are using with us, as applicable. If at any time you believe that any information we are holding with regard to you is incorrect or incomplete, please contact us by reply email to any email we have sent to you including the words “contact info correction” in the subject line. If you choose to unsubscribe, we wish you all the best, and you’re welcome to re-subscribe at any time.
12. Communications & Other Privacy Matters: By using our website, you represent the following: (1) that you are at least the age of majority (the “Age of Majority”) in your nation, territory, state or province of residence (“your Place”), and (2) that you are hereby accepting complete legal responsibility for any person in your household or who is using your electronic device who is under the age of majority in your Place, including without limitation any of your minor dependents (any such persons herein, “your minors”) who may be using our website, and (3) if any of your minors are under the age of 13 (herein, an “twelve-and-under minor”), then you also hereby agree to in no way, either directly or indirectly, provide us with any personal data or information relating to any of your minors who also is a twelve-and-under minor. You also represent that any of your minors for whom you are providing your consent hereunder are subject to your complete and direct supervision for their use of our website and in any and all communications between or among the parties hereunder. You agree and acknowledge that any communications between or among the parties may include information that we or you consider private, and that not all electronic networks, whether online or private, are necessarily secure. You agree to hold us harmless for any non-intentional loss of, or access to, electronically exchanged and stored information. For us to maintain our standard practices updated in light of ongoing legal and regulatory changes, we reserve the right to make changes to this policy at any time without notice to you. You agree to review this policy from time to time to ensure that you are satisfied with any changes. This version and last update of this policy have been effective since the date listed at the end of this policy. Some of the provisions of our Terms & Conditions and Member Agreement may affect your privacy; therefore, our Terms & Conditions and Member Agreement are incorporated herein by reference.
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