Privacy Policy

Welcome to the FigJam Publishing Privacy Policy

Last updated: May 2024

Welcome to Figjam! Your privacy is important to us. We provide a wide range of data and consumer analytic products and services designed to assist advertisers, data owners, networks, platforms, app developers, and marketing companies (collectively “Clients”) to understand their customers, and market their goods and services in a more efficient and relevant manner. Our solutions as described on this website are used to help persons and entities who market to consumers through direct mail, email, online channels, and other marketing channels (collectively “Services”). This policy does not apply to our privacy practices relating to our job applicants, employees, and other personnel, nor does it apply to our Clients. 

This Privacy Policy describes how we collect, use, and disclose personal information in connection with our Services. It also describes our disclosure and sharing of personal information with service providers and third-parties who are retained to assist us in providing our Services, Websites, or perform other business activities (collectively, “Vendors”).

Please read this Privacy Policy carefully to understand how we will treat your personal information. This policy also describes how you may control your personal information and in some states request that we delete or do not disclose or sell your information. We also provide information as to how to control technology that may access some of the information we collect through your own computer and devices.

This Privacy Policy may be updated or changed from time to time. The date the policy was last revised is identified above. All changes to our collection practices will be from the posting date forward. Our use of data we collected prior to the update will not change unless we contact you notifying you of the update and requesting permission for an expanded use of the data we collected prior to the change. Otherwise, we will not provide any notice to you about changes and updates except through posting on this Website. Please check back periodically for updates. 

1. INFORMATION WE COLLECT.

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (collectively “Personal Information”), including:

  • Identifiers, which includes your name, physical address, email address, phone number, mobile number, and identity information relating to data used to identify an individual.
  • Characteristics of protected classifications under applicable laws, such as your age and date of birth.
  • Commercial information, such as profile information relating to your interests, feedback information, communication preferences, customer service and communication history, or information related to your online interests and purchases.
  • Internet or other electronic network activity information, which includes your IP address, log data, analytics data, device ID, and other data collected through cookies, web beacons, JavaScript, and similar technologies.
  • Geolocation data, which includes both your general geographic location when viewing our website and precise location when submitting a registration.
  • Audio, electronic, visual, or similar information, including, where permitted by law, recordings of phone calls between us or our customer service providers.
  • Professional or employment-related information, which may be collected when verifying your identity and may include the business or organization an individual represents, their title with that business or organization, and information relating to their role with the business or organization.
  • Demographic information, which may include your general geolocation, age range and year of birth.
  • Inferences drawn from other personal information or data, includes using your Personal Information to draw an inference about interests and preferences.  Such as the type of device and marketing vertical you would like us to use based on our and third-party’s analysis of your trends in interacting with your device, advertisements and websites.
  • Sensitive Personal Information, includes a specific subset of personal information that includes certain government identifiers (such as social security numbers or driver’s license), an account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account, immigration status, and gender or sexual orientation. We do not target this information, but it may be shared with us as an incidental collection.

2. HOW WE COLLECT INFORMATION.

This section provides more details on how we collect the Personal Information and from whom we receive your Personal Information. Generally, we collect Personal Information from our Clients, Third-parties, Contractors, Service Providers, and Vendors.

  1. Information You Provide to Us. We may collect personal information directly from you when you provide it to us through our Website or Services. This may include the information you provide in response to our request or prompt. We may also receive information from you when you contact us with questions or concerns.
  2. Information Provided by Clients, Third-Parties, and Contractors.
  • Clients. To use our services, Clients provide the information they have collected from you primarily from their Websites, Surveys, Emails, and Apps. Their collection is governed by the privacy policy posted at the time they collected the information. It may include some or all of the information set for in Section 1 of this Policy.
  • Contractors and Service Providers. We use third-party contractors and service providers to support our Services and business processes including without limitation, services which confirm your identity, determine the truthfulness of the information you submitted, and assist us with analytics to determine your interests and marketing preferences.
  • Third-parties. We obtain personal information about you from third-party sources, including commercially available sources, such as data aggregators and public databases. This information may include your name, address, telephone numbers, demographic information, interests, and publicly-observed data.
  1. Information Automatically Collected. When you visit or interact with our or our client’s or third-party ’websites, we or they may use a variety of technologies such as cookies, clear GIFs, pixel tags, log files, JavaScript, web beacons, and other technologies or third-party services to automatically or passively collect personal information about you and your interactions with Websites. We or a party from whom we receive information (collectively “We”) may also automatically collect the following information about you:
  • Computer or Device Information. We automatically collect your Internet Protocol (“IP”) address or other unique identifier or information from the computer, mobile device, tablet you use to access the Websites, including but not limited to your browser type, device type, system type, and the domain name from which you accessed the website, email, or survey.
  • Usage Information. We may collect information about your use of the Websites, including the date and time you visit the Websites, the content, areas or pages of the Websites that you visit, the website or app from which you navigated to the Websites, the page or app you visit after leaving the Websites, the amount of time you spend viewing or using the Websites, the number of times you return to the Websites, as well as other click-stream or usage data, and whether you open, forward, or click-through an email or display ad to the Websites. For legal compliance purposes, we may also capture or record your interactions with the Website to confirm that your information was submitted to us.
  • Third-Party Service Providers. We use third-party service providers to support our Websites. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or HTML5 cookies to receive, collect, and store information on your computer for later access and usage.
  • Use of Third-Party Analytics and Technologies. We use third-parties’ analytic and tracking tools, such as Google Analytics, for display marketing, to better understand our audience, how they are using the Websites, and how to improve the effectiveness of the Websites and its content, and our marketing. We may use this technology and third-parties to target advertising to you through the internet. These technologies may use cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store information about you. They may also combine information they collect from your interaction with the Websites with information they collect from other sources. We do not have access to, or control over these third-parties’ use of cookies or other tracking technologies.
  • Information from Third-Party Websites or Social Media. We may also receive information from third-party’s website, email, or service, such as a social media account, we may automatically receive certain information about you based on your registration and privacy settings on those third-party websites or services. This may include, but may not be limited to your name, username, demographic information, updated address or contact information, location, interests, and online activity.

D. Cookies and Tracking Technology Collecting Information. 

  • Combining Information. In all cases, we may combine information between sources and with other information we collect from or about you. In these cases, our Privacy Policy governs the handling of the combined personal information. We use this information to operate, maintain, and provide Services to our Clients which may influence and affect the communications and marketing tactics to and with a consumer. In all cases, our purpose for this collection and combining is to provide more relevant advertising to consumers in a manner the consumer most often uses for such communications. 

3. HOW WE USE YOUR INFORMATION.

A. De-identified Information. Some of our Services involve the use and processing of de-identified information that cannot be reasonably used to infer information about, or otherwise be linked to, a particular consumer or household. We maintain and use the information in its de-identified form and do not attempt to re-identify the information, except where necessary to determine the legality of the information or to prevent fraud or security issues within our or our Clients’ systems, databases, or technology. 

B. Identified Information. We use the non-personal and personal information collected for various purposes, including the following:

  • Client Marketing Services. We use the Personal and Non-Personal information collected and provided to us to present marketing information to our Clients which allows them to understand their customers or prospective customers and their interest-based products and services. We are also able to advise them of the type of offers, or how to best contact or identify those customers. Our Clients include, but are not limited to, advertisers, brands, agencies, and ad marketing or data platforms that market and advertise their products and services to their own users and prospective users. Some of our Clients are data compilers, who work with their own clients for performance marketing, lead generation, and comparison-shopping website operators.
  • Online Targeting Services. We may create defined audience segments (“Audience Segments”) based on common demographics and/or shared interests or preferences. In providing this Service, we may work with a data Vendor that “matches” our Information through de-identification techniques (such as “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile, email, and other media channels. 
  • Identity Analytics. We may use the information we collect to create analytic graphs, to help locate users across marketing channels, such as common IP addresses, emails addresses, device-based, or network-based identifiers (e.g., IP address, email address).
  • Market Research. We may use the information to help our clients understand specific markets of services or products and what influences the purchase decision and behavior of their target audiences or the physical location of markets.
  • Analytics of Client Data. We may provide our Clients with an analysis of marketing uses of their own data including: (i) targeting and optimizing direct mail, email campaigns, display, social media marketing, and mobile marketing; (ii) measure the effectiveness of certain campaigns by determining which messages were or are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; (iii) analyze and optimize our Client’s proprietary databases, or assist them in detecting and preventing fraud; or (iv) providing “validation” or data hygiene services, by which our Clients may update and/or correct their databases, verify or remove or correcting old, incorrect, or outdated information.
  • Security. We also use all information for our own internal purposes including but not limited to improvement of Services, testing, updating, and verifying our own database; developing new products and services; and to operate, analyze, improve, and secure our Services and databases.
  • Internal Use. We also use all of the information for our own business purposes including:
  • Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations and to deliver the Services you have requested;
  • Manage our organization and its day-to-day operations;
  • Verify your identity and entitlement to products or Services, when you contact us or access our Services;
  • Communicate with individuals, including via email, direct mail, social media, and/or telephone calls;
  • For marketing and advertising purposes, including to market to Clients and prospective Clients through email campaigns and updates on products or services we think that you may be interested in;
  • Identify and analyze how Clients use our Services;
  • Improve and customize our Services to address the needs and interests of our Clients including the use of third-parties and Vendors;
  • Test, enhance, update, and monitor our systems, servers, and Services, or diagnose or fix technology problems;
  • Help maintain the safety, security, and integrity of our Systems, databases, technology assets, and business records;
  • To enforce our Terms of Use or contracts, to resolve disputes, to carry out our obligations, and enforce our rights, and to protect our business interests and the interests and rights of third-parties; Comply with contractual and legal obligations and requirements;
  • Prevent, investigate, or provide notice of fraud or unlawful or criminal activity.

4. USE OF COOKIES AND TRACKING TECHNOLOGY.

A. Cookies and Tracking Technology. We or our clients may participate in interest-based advertising using third-party companies to serve you targeted advertisements based on your browsing history. This permits third-party online advertising networks, social media companies, and other third-party services, to collect information about your use of our or our Clients’ online advertising and websites, apps, or webpages over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time, and date you visited the Sites, AdID, precise geolocation, and other information. 

We may share a common account identifier (such as a hashed email address or user ID) with our Clients to help identify you across devices. We and our Clients use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. We may also use services provided by third-parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

B. Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, X (Twitter), LinkedIn, YouTube, or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

C. Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, X (Twitter), Instagram, LinkedIn, and the like. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.

D. Third-Party Providers. We work with a variety of third-party providers to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us.  We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you.  For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website, “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie), third-party cookies (such as the DoubleClick advertising cookie), or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

5. DISCLOSURE, SALE, AND SELLING PERSONAL INFORMATION. We may disclose, share, and sell your personal information as described below.

A. Clients. We share personal information with our Clients to provide the Services we make available to them, and this includes Advertisers, Ad Networks, and Marketing Companies. 

B. Third-Party Product and Service Marketing Providers. We disclose, share, and sell Personal Information to third-party product and service providers to provide you with the products and services you have requested through your registration on our Website and Services. 

C. Parent and Affiliated Companies. We may disclose and share your information with our parent company and its subsidiaries for business and operational purposes.

D. Service Providers. We disclose and share your information to third-party contractors and other service providers that we use to support our business, Websites, and Services.

E. Sale or Transfer of Business or Assets. We may disclose, share, and sell your Personal Information as part of our sale of assets during the normal course of our business. If another entity acquires any of our assets, information we have collected about you may be transferred to such entity. If we file for bankruptcy or reorganization, information we have collected about you may be considered our asset and may be included in the assets transferred.

F. Marketing Vendors and Other Third-Parties. We may disclose, share, or sell your information to third-parties who provide display and/or email services or other third-party vendors we use who provide cookies, pixel tags, web beacons, clear GIFs, or other similar technologies for our and third-parties use on and to manage and improve our advertising campaigns.

G. Compliance with Laws. We may disclose your Personal Information to comply with any court order, law, or legal process, including responding to any subpoenas, judicial processes, or government or regulatory requests and investigations. We may disclosure your Personal Information to third-parties to assist us in compliance with Laws.

H. Enforcing Our Rights. We may disclose and share your information to enforce or apply our terms of service or other agreements, including for billing and collection purposes, with third-parties who provide you with the product or service which you have requested or to protect the security of our Websites, servers, network systems, and databases.

I. Acquisition or Merger. We may disclose and transfer your personal information to a third-party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of our assets.  

J. Aggregate or Anonymous Non-Personal Information. We may disclose, share, or sell aggregate, anonymous, or de-identified non-personal information to third-parties for their marketing or analytics uses.

6. YOUR CHOICES AND OPTING OUT. 

A. Cookies, Tracking Options, and California Do Not Track Disclosures. We, third-parties, and service providers place Cookies and Tracking Technology on parts of our Website. You may decline or adjust these technologies through your device or Internet browser settings to limit certain tracking or to decline cookies. Please note that by doing so, you may not be able to use certain features on our Websites or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable cookies or to control your tracking preferences. Please note that our Websites may not recognize “do not track” requests or headers from some or all browsers. 

B. Interest-Based Advertising. You have choices for receiving more relevant advertising on the Websites or across other websites and online services, to learn more about these choices please see relevant articles at http://www.aboutads.info/choices/, http://www.networkadvertising.org/choices/, or for your mobile device, please see http://www.aboutads.info/appchoices. If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout/. Your mobile device may also allow you to adjust your privacy and advertising settings to control advertising. Even if you opt-out, you still may receive advertising from us that is not customized based on your Service or usage information, or advertising from other third-parties.

C. Unsubscribing from Our Marketing Communications. We provide our customers, as well as individuals referred by our customers, with the opportunity to opt-out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service. To opt-out of marketing processes simply visit https://www.quilltablebat.com/o-jbwn-p75-772cc0efeb667158413877a38388e8d5 and submit your email address. We will then remove you from our redirect marketing program going forward. You may also email us at [email protected] and request to be opted out of any marketing programs from FigJam Publishing.  

FigJam Publishing DOES NOT engage in any email marketing to consumers. We do purchase redirect traffic from a variety of companies that use email marketing, which is one way consumer may arrive at one of our websites. If you receive marketing communications from one or more of our affiliates or subsidiaries, you must opt-out individually from each of the brands from which you are receiving brand-specific marketing communications. 

D. Third-Party Communications. Any third-parties to whom we have disclosed, shared, or sold your information may have their own privacy policies which describe how they use and disclose your information and your choices. We encourage you to visit the websites of those third-parties.

7. CHILDREN’S PRIVACY.

We do not direct market our Websites to children under the age of 16. We do not knowingly collect any personal information from children under the age of 16. If we learn that a child under the age of 16 has provided personally identifiable information to the Websites, we will use reasonable efforts to remove such information from our files.

8. DATA SECURITY.

We use reasonable industry-accepted technology and controls to protect your information and data from disclosure to unauthorized third-parties. This includes firewalls, secured facilities, and logged and limited access. Although mostly effective to prevent disclosure, no guarantee can be given that all information you provide to us will not be accessed by unauthorized persons. Thus, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Any transmission of data to us or through our Website is at your own risk. 

9. CHANGES TO OUR PRIVACY POLICY.

We reserve the right to make changes to this Privacy Policy as our collection, use, and sharing of your information changes. We do not provide notice of changes except through our posting on this page. We use your information only in the manner described in this Privacy Policy at the time you register your information with us. Please be sure to review this policy each time you communicate or register with us for the latest policy. Your continued use of the Websites and/or Services after we post a change in the Privacy Policy means you accept those changes.

10. RETENTION OF PERSONAL INFORMATION.

We retain personal information only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax, and accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Therefore, we retain personal information for as long as the individual continues to use our Websites and/or Services for the purposes explained in our Privacy Policy. When an individual discontinues the use of our Site and Services, we will retain their personal information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices they have made, such as to receive marketing communications. In particular, we will retain personal information supplied when joining our services, including complaints, claims, and any other personal information supplied during the duration of an individual’s contract with us for the services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise, or defense of legal claims.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or de-identify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or de-identification is possible.

11. LINKS TO THIRD-PARTY WEBSITES OR SERVICES.

Our Services may include links to third-party websites, plug-ins, and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third-parties including our Clients. To learn about the personal information practices of third-parties, please visit their respective privacy notices.

12. CONTACT INFORMATION. 

To ask questions or comment about this privacy policy and our privacy practices, contact us:

By Mail: 

4450 Arapahoe Ave, Suite 100

Boulder, CO 80302

Email: [email protected]

13 ADDITIONAL U.S. STATE PRIVACY DISCLOSURES.

A. For residents of the States of California, Colorado, Connecticut, Nevada, Utah, and Virginia. These Additional U.S. State Privacy Disclosures (“U.S. Disclosures”) supplement the information contained in our Privacy Notice above by providing additional information about our collection, use, and processing practices relating to individual residents of these States. For a detailed description of how we collect, use, disclose, and otherwise process personal information in connection with our services, please see the main body of this Privacy Policy. Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in these U.S. Privacy Disclosures. 

For the purposes of these U.S. Privacy Disclosures, personal information does not include publicly available information, de-identified, aggregated, or anonymized information that is maintained in a form that is not capable of being associated with or linked to you. Additionally, these disclosures set out in this Section do not describe our practices when we process consumer data as a service provider on behalf of our Clients in accordance with our contractual agreements. 

You may be able to exercise the following rights and choices in this section in relation to the personal information about you that we have collected, depending on your state of residency (subject to certain limitations at law): 

  • The Right to Know. The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you in the last 12 months, including:
  • The categories of personal data collected;
  • The categories of sources of the personal data;
  • The purposes for which the personal data were collected;
  • The categories of personal data disclosed to third-parties (if any), and the categories of recipients to whom the personal data were disclosed;
  • The categories of personal data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for those purposes; and
  • The categories of personal data sold (if any), and the categories of third-parties to whom the personal data were sold.
  • The Right to Access and Portability. The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  • The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
  • The Right to Correction. You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
  • The Right to Control over Sensitive Information. You have the right to exercise control over our collection and processing of certain sensitive information.
  • Right to Control over Automated Decision-Making/Profiling. The right to direct us not to use automated decision-making or profiling for certain purposes.
  • The Right to Opt-out of Sales or Sharing for Targeted Advertising. You have the right to direct us not to “sell” personal information we have collected about you to third-parties for monetary or other valuable consideration, or “share” your personal information to third-parties for cross-context behavioral advertising purposes. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
  • Right to Appeal. In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.
    • Colorado Residents. If your appeal is denied, you may contact the Colorado Attorney General to address your concerns at https://complaints.coag.gov/s/?varCFT=2.
    • Connecticut Residents. If your appeal is denied, you may contact the Connecticut Attorney General to submit a complaint https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.
    • Virginia Residents. If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint https://www.oag.state.va.us/consumercomplaintform/start
  • Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

B. How to Exercise Your Privacy Rights.

  • Website and Online Services. To submit a request to exercise one of the privacy rights identified above with regards to your personal information collected or otherwise processed pursuant to the Website and Online Services, please submit a request by:
  • Filling out our Request Form at https://www.figjampublishing.com/contact/ 
  • Emailing us at [email protected]
  • Verification.  We may need to verify your identity before processing your request, which may require us to request additional personal information from you. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

C. Exercise Your Right to Opt-Out of Personal Information Sales or Sharing for Targeted Advertising. Unless you have exercised your Right to Opt-Out, we may disclose or “sell” your personal information to third-parties for monetary or other valuable consideration, or “share” your personal information to third-parties for cross-context behavioral advertising purposes. The third-parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies. You do not need to create an account with us to exercise your Right to Opt-Out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. To exercise the Right to Opt-Out, please fill out the Request Form listed in the How to Exercise Your Privacy Rights section above.

D. Authorized Agents. In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the applicable privacy law) to submit requests on your behalf through the designated methods set forth in these U.S. State Privacy Disclosures where we can verify the authorized agent’s authority to act on your behalf. For requests to know, delete, or correct personal information, we require the following for verification purposes: (i) a power of attorney valid under the laws of the state where you reside from you or your authorized agent; or (ii) sufficient evidence to show that you have: (a) provided the authorized agent signed permission to act on your behalf; and (b) verified your own identity directly with us pursuant to the instructions set forth in these U.S. Privacy Disclosures; or (c) directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf. For requests to opt-out of personal information “sales” or “sharing”, we require signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

E. Additional Personal Information Disclosures.

  • Additional Disclosures on Sales, Sharing, or Targeted Advertising. As further described in the Privacy Policy, we may “sell” or “share” your personal information (as those terms are defined by the CCPA to third-parties, subject to your right to opt-out of those sales. In the last 12 months, we sold, shared (for cross-context behavioral or targeted advertising purposes), or disclosed the personal information (for the purposes described in our Privacy Policy) as follows:
  • Third-party Business and Marketing Companies. Identifiers, Commercial information, Internet or other electronic network activity information, and Geolocation data.
  • Online Advertising Networks, Social Networks, and Analytics Providers. Identifiers, Commercial information, Internet or other electronic network activity information, and Geolocation data.
  • Contractual Compliance. We also disclose personal information to third-parties at the resident’s direction or upon their request, in connection with a service or product the resident received, for our corporate business transaction, or to comply with legal or contractual obligations, as described in our Privacy Policy. In the last 12 months, we may have disclosed each category of personal information for these purposes.
  • Sensitive Personal Information. We do not sell Sensitive Personal Information, except as requested by the resident for products and services they have requested. We have used general geolocation for targeted advertising and marketing purposes only and do not otherwise share Sensitive Personal Information for the purpose of cross-context behavioral or targeted advertising. 

De-identified Information. We may receive or process personal information to create de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain de-identified data, we maintain and use the data in de-identified form and not attempt to reidentify the data except as required or permitted by law.

Changes

We may update this Privacy Policy from time to time, so you should check it periodically. If we make changes that are material we will provide you with appropriate notice before such changes take effect.

Questions & Suggestions

If you have questions, suggestions, or wish to make a complaint, please complete a feedback form or you can contact us at [email protected].