This policy applies to information we collect through any medium, including, but not limited to, information:
On this Site
In email, text, and other electronic messages between you and the Site
Through mobile and desktop applications you download from this Site, which provides dedicated non-browser-based interaction between you and this Site
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy
It does not apply to information collected by:
Us offline or through any other means, including on any other Site operated by Company or any third party (including our affiliates and subsidiaries); or
Any third party (including our affiliates and subsidiaries) including through any application or content (including advertising) that may link or be accessible from or on the Site
POLICY APPLICABLE TO ONLINE ACTIVITIES ONLY
PERSONAL INFORMATION WE MAY COLLECT
TYPES OF INFORMATION COLLECTED. We may ask you for certain information referred to on this Site as “Personal Information,” which includes information that pertains to your identity. Such information may include but is not limited to, items such as your name, address, date of birth, age, gender, e-mail address, telephone number, or credit card or debit card number information. You may be required to provide Personal Information to access or use certain parts of our Website or features of the Site. If you do not provide the requested Personal Information, you may not be able to access or use the features of the Site where such information is requested. This Site will also collect information about you but does not individually identify you.
GENERAL INFORMATION WE MAY COLLECT
TYPES OF INFORMATION COLLECTED. There may be other instances in which we collect information from you that is more general in nature (“General Information”). Such information may include your Internet Protocol (IP) address, which enables us to identify your computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network, which includes the World Wide Web. Your computer has an IP address, which is required in order for you to communicate with others via the Internet. Such General Information, including the “Click Stream Data” (defined below) and cookies, as mentioned below, may be collected from you whenever you access the Site, whether or not you provide us with any Personal Information.
6.1. Click Stream Data
When you visit our Website we may also collect “Click Stream Data” (server address, domain name). This information can be combined with information you have provided to us by registering, for example, which will enable us to analyze and better customize your visits. We may use Click Stream Data for traffic analysis or e-commerce analysis of our Website, to determine which features of our Site are most or least effective or useful to you.
6.3 Clear GIF’s
We may use “clear GIFs” (aka “Web beacons” or “pixel tags”) or similar technologies, in the Site and/or in our communications with you to enable us to know whether you have visited a Web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual’s viewing or receipt of a Web page or message. A clear GIF may enable us to relate your viewing or receipt of a Web page or message to other information about you, including your Personal Information.
6.4 How We Respond to “Do Not Track” Disclosures
We may utilize geolocation (identifying your geographical location by means of digital information that is processed through the internet) to track visitors to our Website. Geolocation is used to track the number of visitors to our Website which may be accessible by third parties and for marketing purposes.
GENERAL INFORMATION YOU PROVIDE US
There are instances in which you will provide information to the Company and the information we collect on or through our Site, as a result, may include:
Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our service posting material or requesting further services. We may also ask for your information when you enter a contest or promotion sponsored by us, and when you report a problem with our Site.
Records and copies of your correspondence (including email addresses) if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through our Site and of the fulfilment of your orders. You may be required to provide financial information before placing an order through our Site.
Your search queries on the Site.
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 (collectively “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site 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.
GENERAL INFORMATION ABOUT YOU
USE OF GENERAL INFORMATION. We will primarily use the Personal Information you provide and any General Information we receive from you to provide products and services to you, including, but not limited to, the following:
To administer a content promotion survey or other Site and to provide you with the relevant products or services (for example, to deliver a prize you may have won in a contest).
To send you information or materials via e-mail about products, offers, and news we think might interest you. This information may relate to products, offers, and news of SoFree LLC or its licensees or selected commercial partners. We send you this only if you have single-opted-in to receive e-mails from our Website. A single-opt-in occurs when you only need to submit your email address to register for our Website and subscribe to any related mailings. If you no longer wish to receive any e-mails from us, or if you want to modify your personal data or want your personal data to be deleted from our database, see Section 14.
To analyze visits to the Website and learn about the interests of our visitors in aggregate and also on a personal level to better understand your interests and needs, so we can improve our products and services and deliver to you the type of content, features and promotions that you are most interested in.
PROTECTION OF YOUR PERSONAL INFORMATION AND GENERAL INFORMATION
9.1. Security Measures
We have implemented appropriate security measures in order to protect both the Personal Information and the General Information that we receive from you through our Website.
9.2. Risk of Interception
Please keep in mind, however, that whenever you give out or have Personal Information collected online there is a risk that third parties may intercept and use that information. While the SoFree LLC Website strives to protect your Personal Information and privacy, we cannot guarantee the security of any information you disclose online. By using this Site, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us through this Site and that any Personal Information, General Information, or other data or information received from you through the Site is provided to us at your own risk, which you expressly assume.
RIGHT TO OPT-IN AND OPT OUT
You have the right to “opt in” and “opt out” of certain of our uses of your Personal Information, including by contacting us at email@example.com Attn: Compliance Department. At the time you are requested to provide Personal Information on this Site, you will have the opportunity to elect to, or not to: (1) receive correspondence from us, or (2) have your Personal Information shared with other entities for their marketing purposes. Users may opt not to receive our electronic newsletters or those of third parties when providing Personal Information. Users whom opt-in may remove themselves from mailing lists at any time through the account-management pages or by following the instructions at the end of the e-mail they received from us. If you opt not to provide certain Personal Information when registering for or using our Site, however, you may not be able to use some of our services such as message boards.
Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us. Also, a request to have us stop sharing your Personal Information with other entities for marketing purposes will only apply as of the date of your request, and we will not be responsible for any communications that you may receive from entities that received your Personal Information prior to such request. In these cases, please contact that entity directly.
NO USE OF THIS SITE BY PERSONS UNDER 18 PERMITTED
11.1. Registration Declined
11.2. Notice Concerning Children
PLEASE NOTE: We are a general audience Site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we are given notice or have reason to suspect that a Site user is under age 13, we will timely delete any Personal Information in that user’s account.
12.1. Sharing Information With Persons or Entities Who Manage This Website
Company’s global and local Websites and the Personal Information and General Information collected are managed and controlled by SoFree LLC located in San Diego CA. The servers that make Company’s global and local Websites available are located in San Diego, CA. If you are located outside San Diego, please note that the information you provide will be transferred to SoFree LLC, and by submitting the information you authorize this transfer. SoFree LLC has entered into an agreement with the hosting company in location to provide safeguards for the protection of your data that are consistent with this Policy.
12.2. Disclosing Information to Third Parties
WHO MAY HAVE ACCESS TO YOUR INFORMATION. Other than to the companies belonging to, or affiliated with SoFree LLC for the purposes set out above, and except as described in this Policy, we do not sell, trade, or otherwise transfer your Personal Information or General Information to third parties without informing you in advance. We provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “Service Partners”). Our Service Partners may use your Personal Information to operate our Sites and to deliver their services. For example, your data may be transferred to Website hosting partners and other parties who assist us in designing and operating the Website, executing services (such as for prize fulfilment), or helping us analyze collected data. These parties will only use your data for the purpose of carrying out the work as agreed with us and will be required to keep the information confidential. We will encourage our Service Partners to adopt and post privacy policies. However, the use of your Personal Information by our Service Partners is governed by the privacy policies of those Service Partners and is not subject to our control. Please also see Paragraph 6.4 on how we will respond to “do not track” signals.
RELEASE OF INFORMATION. SoFree LLC will release Personal or General Information without your consent for security purposes, when required by law, or to prevent imminent harm to any person or entity. We will disclose Personal or General Information upon receipt of a court order or subpoena, or to cooperate with a law enforcement investigation, which may include responding to requests and court orders from jurisdictions outside the United States. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion. Release of your personal data or Personal Information for security purposes, as described in this agreement to any person or entity under any circumstances shall be based on a determination made solely by us, exercising our own discretion, permission for which is expressly granted by you to us in accordance with this Policy.
California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to firstname.lastname@example.org.
12.4. Links to Third Parties
COOKIES. In addition to Section 6.2 above, cookies are also used for such activities as remembering your user name and password, if you use such a feature on this Site. You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options, you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browsers). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the functionality of the Website you visit and you may lose access to some of its features.
DELETING OR MODIFYING PERSONAL INFORMATION
CHANGING YOUR INFORMATION. You may cancel your account or any associated registration information at any time, and you may opt out of receiving any e-mails from SoFree LLC. Additionally, you can choose to have all your Personal Information deleted from our database. You may opt-out or delete your Personal Information and unsubscribe from our marketing materials, by clicking the ‘unsubscribe’ link located on our marketing e-mails and following the instructions provided. We encourage you promptly to update your Personal Information when it changes or utilize the ‘unsubscribe’ link to discontinue receiving marketing information from Pura Vida.
QUESTIONS OR COMMENTS
EU CITIZENS; GDPR ADDENDUM
Citizens of the European Union who are subject to the General Data Protection Regulations can find more information by visiting the following link: www.SoFreeCreations.com/GDPR