We may request, collect and/or display some of your Personal Information when using the Services.
When you create an Account, you will provide Information that could be Personal Information.
Personal Information also includes log-in credentials, password, transactional information based upon your activity on the Site. By creating an Account on the Services and providing Personal Information to us, you allow others, including us, to identify you.
By using the Service you are giving us permission to send you text messages and emails regarding the transactions you request.
We collect and store IP address Information, but it’s not made public.
As stated above, we do not currently collect financial information, as that information is collected and stored by our Payment Processor. However, we may from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
About This Policy
This Policy describes the privacy practices of the Company and its subsidiaries, divisions, and affiliates (collectively and/or individually, "Company", "our", or "we"). Except as otherwise provided, it applies to our interactions with our customers and visitors, including, but not limited to:
- Use of our websites, including mobile websites, applications
- Visits to our stores/locations or attendance at one of our events
- Phone and email communications
- Social media interactions on our websites and other third party websites like Facebook, YouTube, Pinterest, Google+, Instagram and Twitter
- Viewing our online advertisements or emails
- Through our authorized service providers
Personal Information We Collect
As described below, Company may collect or has collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of personal information we collect personal information. In that case, we will inform you.
Purposes We Collect Your Personal Information.
- Identifiers. Examples include real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
- Other elements. Examples include name, signature, characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number.
- Characteristics of protected classifications under California or federal law. Examples include race, religion, and age.
- Commercial information. This includes services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Education information. This includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
- Internet or other electronic network activity. Examples include browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation data. This might include location information while using one of our apps.
- Audio, electronic, visual, thermal, olfactory, or similar information. Examples of this category including identifiable information obtained about you while speaking with our customer service representatives on the telephone.
- Professional or employment-related information.
- Consumer profile. This includes inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.
Purposes We Collect Your Personal Information
- Set forth below are the business or commercial purposes we have collected your PI. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law.
- To provide you with information, products or services that you request from us.
- To fulfill or meet the reason for which the information is provided.
- To contact you and/or provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To engage in marketing activities, including to help design products and services appropriate for our clients.
- To communicate with you in social media concerning our products and services.
- To carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
- To review, improve, and monitor our website, applications, online services, and overall client experience, including to provide customization to meet the specific needs, ensure a consistent experience, and to assess trends, interests, and the demands of clients.
- To provide customer service and engage in quality control activities concerning our products and services.
- For testing, research, analysis and product and service development.
- To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To process applications for employment, as well as to evaluate and improve our recruiting efforts.
- As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Sources of Personal Information
The categories of sources of PI are described below. The examples provided are for illustration purposes and are not exhaustive.
- You. Examples of when we collect that information include:
- During a website visit or completed form, or when you visit us at one of our locations or events.
- If you upload or share a photo, submit a request, submit information, or post other digital content through one of our websites, applications or via social media interactions on third party websites like Facebook or Twitter
- If you register for a referral or loyalty program
- If you participate in a sweepstake, contest, promotion, program, clinic or workshop
- If you request a quote, warranty or other information
- If you use a rebate
- In connection with your interactions with us as a registered user of our websites
- We may use tracking tools like browser cookies, flash cookies, and web beacons.
- Your friends and family, such as when they provide your information through one of our refer-a-friend type features or programs. Persons who share such information in connection with those features or programs should only submit email addresses of individuals with whom they have a close personal or family relationship, who would be interested in receiving the communication, and who have authorized the sharing of their email address
- News outlets
- Social media and related services
Sharing Personal Information
Of the categories of PI noted above, during the past 12 months, we shared the following:
Categories of Personal Information Disclosed
Categories of Third Parties to Whom Disclosed
Characteristics of protected classifications under California or federal law.
Internet or other electronic network activity.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information
- Third parties as directed by you. We will share your PI with those third parties to whom you direct.
- Our business partners. For example, we might share your PI with one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose PI. Where applicable, we encourage you to review each such business partner's privacy statement before signing on with them.
- Third parties who perform services on our behalf. For example, we share information with certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect PI on our behalf.
- Governmental entities, legal service providers. We may share your PI in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request.
- Successors to all or portions of our business. If all or part of our business is sold, we may disclose PI in preparation for or as part of that transaction.
We do not sell your PI and do not have actual knowledge that we have sold personal information of minors under age 16.
Using of Your Personal Information On Our Website.
As is true of most websites, we gather some PI automatically and store it in log files. This information may include the Internet Protocol (IP) address, browser type, language, internet service provider (ISP), referring and exit page, operating system, and date/time stamp. In addition to the purposes above, we use this PI to understand and analyze trends, to administer the Website, to learn about user behavior on the Website, and to gather demographic information about our user base as a whole. To monitor use of the Website and improve its quality, we may compile statistical information concerning the use of the Website through analytics services, such as those provided by Google Analytics. Examples of this information may include: the number of visitors to the Website or to sections or pages within the Website, patterns of traffic flowing through the Website, length of time spent on the Website, or in sections or pages of the Website, the other sites that refer visitors to the Website, the pages of the Website that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Website. We also may use this PI in our marketing and advertising services.
We may use various kinds of software devices to collect PI about use of our Website. Small files called "cookies" may be attached to your Web browser. These files identify your browser and save information such as passwords so that websites can recognize you. You can set your browser to disable cookies, but some portions of this Website (and possibly other sites) may not work properly if you do this. We may also use web beacons to review how visitors navigate the Website. If you would like more information about this practice, and your choices and how they relate to this practice, please contact us.
This Website may use social media plugins (e.g. Facebook and LinkedIn) to enable you to easily share information with others. When you visit our Website, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Website. If you are logged into the social media website (e.g. Facebook, Twitter) while browsing our Website, the social plugins allow that social media website to share data about your activities on our Website with other users of their social media website. For example, Facebook Social Plugins allow Facebook to show your likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website. We do not control any of the content form the social media plugins. For more information about social plugins from other media websites you should refer to those sites’ privacy and data/information sharing statements/policies.
IMPORTANT: By using the Website, you consent to the processing of any PI provided or collected for the analytics purposes and functions described above.
Do Not Track.
“Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Website is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.
Our Sites and Children
We do not knowingly collect or solicit PI from children under 13 years of age. We are concerned about the safety of children when they use the Internet and will never knowingly request PI from anyone under the age of 13. If the parent or guardian of a child under 13 believes that the child has provided us with any PI, the parent or guardian of that child should contact us and ask to have this PI deleted from our files. If we otherwise obtain knowledge that we have PI about a child under 13 in our files, we will delete that information from our existing files so that it is not in retrievable form.
While we use reasonable measures to protect our websites and your information, the Internet is never 100% secure. The measures we use are appropriate for the type of information we collect. We cannot guarantee use of our websites or mobile applications are 100% secure. We encourage you to use caution when using the Internet.
Notice to Website Users Located Outside the U.S.
The Company operates in accordance with the laws of the U.S. When you access our Website from outside the U.S., we may transfer the PI that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Website you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.
If you have additional questions you may call us at 860-522-7641 or reach us by email at email@example.com. You can write to us at: One Financial Plaza, 14th Floor, Hartford, CT 06103.
Effective Date: October 9, 2020
For California Residents
The CA Policy describes Company’s policies and practices regarding the personal information we collect, use, and disclose about you, including personal information you submit or we obtain when you access the Site and other sources. This CA Policy is adopted in part to comply with the California Consumer Privacy Act (“CCPA”).
Any terms defined within the CCPA have the same meaning when utilized within this CA Policy. The other provisions of the Policy continue to apply except as modified in this CA Policy. Note, however, that personal information as used in this CA Policy does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, such as 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.
Pursuant to the CCPA, and as detailed below, consumers have various rights with respect to their PI.
Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
- Request to Know. You have the right to request that we disclose the following to you as it relates to the 12-month period preceding its receipt of your verifiable consumer request:
- The categories of PI we have collected about you.
- The categories of sources from which the PI was collected.
- The business or commercial purpose for collecting PI.
- The categories of PI we disclosed for a business purpose.
- The categories of third parties with whom we share PI.
- The specific pieces of PI we collected about you.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
In addition to the CCPA, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Company to third parties for the third parties’ direct marketing purposes. Consumers who have provided their personal information to us may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such request must be submitted to us by calling 860-522-7641 or reach us by email at firstname.lastname@example.org. Please mention in your call or email that you are making a "California Shine the Light" inquiry. Within 30 days of receiving such a request, we will provide a list of the categories of such personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
- Nondiscrimination. We will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA.
Submitting Consumer Rights Requests. To submit any of the Consumer Rights requests as outlined above, please contact us at 860-522-7641 or email@example.com. We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is:
- the consumer who is the subject of the request,
- a consumer on behalf of the consumer’s minor child, or
- by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.
If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. PI collected from an individual to determine whether a request is a verifiable consumer request may not be used or disclosed for any other purpose except as required by law. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
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 receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.
You may authorize a natural person or a business registered with the California Secretary of State to act on your behalf with respect to the right under this CA Policy. When you submit a Request to Know or a Request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.