Last updated December 20, 2022
Warn Industries, Inc. and its affiliates respect your concerns about privacy and your right to know how your personal data is collected and processed. References in this Privacy Notice to “Company”, “we”, “us”, and “our” are references to the entity responsible for the processing of your personal data, which generally is the entity that obtains your personal data.
This Notice applies to the personal data we collect through our websites, mobile applications, social media pages, and offline collection methods that reference this Notice (collectively, the “Services”). This Notice describes how the Services collect personal data from you, what types of information we collect, how we may use the personal data, with whom we may share it, the measures we take to safeguard the personal data we obtain, how you may exercise your rights regarding our processing of your personal data, and how you can contact us regarding our privacy practices.
The Services may provide links to other third-party websites and features, or contain third-party cookies, that are not owned or controlled by us. Please review the privacy notices of these third parties to familiarize yourself with their privacy practices. You may also exercise your choices regarding third-party cookies using our Cookie Consent Management Tool. Depending on the website you are visiting, you can access the tool by clicking on the Cookie icon, Cookie link or Privacy Choices link at the bottom of the page.
By using the Services, you acknowledge you have read and understood the terms of this Notice. Please fully review this Notice before you use the Services or submit information to us.
PERSONAL DATA WE COLLECT
We may collect certain personal data about you in order to provide and improve the Services. The categories of personal data we collect include:
- Contact information including name, job title, business name, phone and fax number, email and postal address for you or for others (e.g., principals in your business)
- Information used to create your online account (such as username, password, favorite store and security question and answer)
- We collect and store the information that you and other users provide when you and they use and interact with the Services (such as your favorite store locations, branch or your vehicle information)
- Purchase and customer service history
- Financial and tax information, including name, billing address, payment card details (i.e., card number, expiration date and security code), tax related information (e.g., business tax ID and VAT ID), credit screening and bank account information
- Location data (i.e., data derived from your IP address, country and zip code)
- Usage data including details on your browser (such as type, version, language); operating system and interface; website from which you are visiting us (referrer URL); webpage(s) you are visiting on our website; date and time of accessing our website and time zone difference; access status/HTTP status code; volume of data transferred; internet protocol (IP) address; and information gathered via cookies
- Correspondence-related data such as emails, texts, letters, or responses to surveys and questionnaires; information you provide us by phone or live chat; or your feedback on your experience with the Services, or a Company facility
- Other personal data (i.e., date of birth, place of birth, citizenship, age)
Please note that providing personal data to us is voluntary on your part. However, some information, such as your name, address, and payment transaction information, may be necessary for the performance of our contractual obligations. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Services.
how we collect personal data
We collect personal data in a few ways:
2.1. Information you give us. We collect information that you elect to share with us, for example, when you sign up for a newsletter, respond to a survey or fill out a form, register for a product warranty, sign up for a loyalty program, create an account to access the Services, visit our stores, attend one of our events, enter into a contest or sweepstakes, place an order, provide a review, contact customer service, or make a purchase.
2.2. Information obtained when you use the Services. We collect certain information from you through your use of the Services, such as usage data and location data (i.e., such as data derived from your IP address, country and zip code). We may also collect generic network information and aggregated data in relation to how you use the Services in order to assess and improve functionality of the Services.
2.3. Information provided by third parties. We may obtain data about you from third parties who help us provide the Services to you. For example, we may obtain information about your order or product return from our order fulfillment and delivery partners, and garages that service your vehicles may provide vehicle service and repair information. We may also obtain data about you from third party credit reference agencies if we conduct a credit check. In these instances, please refer to the relevant third party’s privacy notice to understand how they handle your personal data.
COOKIES AND SIMILAR TECHNOLOGIES
3.1. Cookies. A cookie is a small text file that is stored on a device for record-keeping purposes. Cookies record information about your activities while using a website and “remember” you when you return to the website. Some cookies remain on your device until you delete them. Others, like session ID cookies, expire when you close your browser. You may set your device settings to attempt to reject cookies but doing so may affect functionality of the Services. Information collected by cookies may include, but is not limited to: your IP address, browser type and language, device type, device identifiers, other device and software information (such as configuration information on your device and other applications), apps you access, search and browsing information, web usage information, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages and the date and time of each request you make.
3.2. Pixels. Pixels (aka web beacons) are tiny graphics with a unique identifier that are used to track the online movements of web users. Unlike cookies, which are stored on a computer’s hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on web pages or in HTML-based emails. We do not control the use of pixels by third parties.
3.3. Making cookie choices. Except for cookies that are essential to the operation of the website you are visiting, you can choose what cookies you will accept. You can view the cookies used on the Company website you are visiting and make choices about those cookies, through the Cookie Consent Management tool. Depending on the website, you can access the tool by either clicking on the Cookie icon or the Cookie link at the bottom of that site. By refusing to accept cookies, you may not be able to use some of the features and functionality available through the Services.
3.4. Sharing tools. To enhance your experience when using the Services, we sometimes embed content and sharing tools from other third-party sites, such as “like” buttons from social networking sites; these third-party sites may also place and access cookies on your device. We do not control the placement or access of these third-party cookies. Please review the privacy notices of these third parties to familiarize yourself with their practices.
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) and 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 for 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 https://optout.networkadvertising.org/?c=1.
3.6. Online Ads. To learn more about interest-based advertising and how you may be able to make choices about some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or https://www.networkadvertising.org/choices/, or if you are in the European Economic Area, United Kingdom or Switzerland: https://youronlinechoices.eu/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app.
under the DAA’s Principles.
If you are located in the EEA, UK, or Switzerland, you may take advantage of Your Online Choices. This service allows you to select tracking preferences for most of the advertising tools. As such, it is recommended that you make use of this resource in addition to the information provided in this document.
HOW WE USE PERSONAL DATA
We may use the personal data we obtain as follows:
4.1. Provide and administer our products and services;
4.2. Process and fulfill orders and keep you informed about the status of your order;
4.3. Communicate about and administer our products, services, events, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications);
4.4. Conduct and facilitate surveys, sweepstakes, contests, focus groups and market research initiatives;
4.5. Perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);
4.6. Provide customer support;
4.7. Process, evaluate and respond to requests, inquiries and applications;
4.8. Create, administer and communicate with you about your account (including any purchases and payments);
4.9. Provide investor services;
4.10. Conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
4.11. Operate, evaluate and improve our business (such as by administering, enhancing, and improving our products and services; developing new products and services; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
4.12. Verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
4.13. Conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms; and
4.14. Maintain and enhance the safety and security of our products, services, information resources and employees.
We may at times receive, or process personal data to create, deidentified 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 deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law. Where required by
applicable law, we will obtain your consent for the processing of your personal data for direct marketing purposes.
The legal basis for our processing your personal data as described above will typically be one of the following: (1) your consent; (2) performance of a contract with you or a relevant party; (3) our legitimate business interest (e.g., managing our business and improving the services); or (4) compliance with our legal obligations.
HOW WE SHARE INFORMATION
We may share your personal data with (internal and external) recipients for the processing purposes described above.
5.1. Within the Company. Depending on the categories of personal data and the purposes for which the personal data has been collected, different internal departments within the Company may receive it (for example, our IT department may have access to usage data; our sales departments may have access to account and order data). Moreover, other Company departments may have access to certain personal data about you on a need-to-know basis, such as the legal department, the finance department or internal auditing.
5.2. Sharing with Other Users. The Services may allow users to connect and communicate with others, such as through a message board. If you use any communication features, other users of the Services may be able to view your profile information and your communications that you post to the Services.
5.3. Service Providers. We use third parties to help us operate and improve the Services (e.g., hosting providers, e-commerce service providers and analytics service providers). We may provide these third parties with information we collect, and they may collect information from you and about your use of the Services. The processing by these third parties will, unless specifically noted otherwise in this Notice, be governed by a contractual agreement requiring them to process the personal data solely on behalf of the Company when performing the Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Company.
5.4. Insolvency and Business Transitions. If we ever file for bankruptcy or engage in a business transition such as a merger or joint venture with another company, or if we purchase, sell, or reorganize all or a part of the Services or our business or assets or the business or assets of our affiliates, we may disclose your personal data, including to prospective or actual purchasers in connection with one of these transactions.
5.5. Regulators, authorities and other third parties. We may also transfer your personal data to governmental agencies and regulators (e.g., tax authorities), courts, government authorities, and independent external advisors acting as controllers (e.g., lawyers, accountants, auditors etc.) all in accordance with applicable law.
5.6. Garages. We may share your personal data with garages that service your vehicle and/or provide services to you, for example in order to fulfill your contract with that third party. Please refer to the relevant third party’s privacy notice to understand how they handle and process your personal data.
5.7. Suppliers. We may share certain personal data with our suppliers, for example in relation to claims and complaint management and customer bonus or incentive programs where necessary.
5.8. Third Party Social Media Platforms. We may share certain personal data with third parties such as social media platforms where necessary for the purposes of features or functions incorporated into our Services which are provided by such third parties. Please refer to the relevant third party’s privacy notice to understand how they handle and process your personal data.
We may transfer the personal data we collect and may store such information outside the country in which the information was provided. These countries may have different data protection laws than the country in which the information was provided. If we do so, we will take necessary measures to ensure that such transfers are adequately protected as required by applicable data protection law, including but not limited to adequacy decisions, relevant government treaties and the Standard Contractual Clauses approved by the European Commission.
HOW WE PROTECT PERSONAL DATA
We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal data was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal data provided to us through the Services.
your privacy choices
If you have an account with us and would like to update your personal data associated with your account, you may make changes in the “My Profile” or “Settings” portions of the Services. Aside from updates you make, at any time, you may challenge the accuracy or completeness of your personal data in our records. If you successfully demonstrate that your personal data in our records is inaccurate or incomplete, we will update the personal data as required. Where appropriate, we will transmit the updated information to third parties having access to your personal data.
If you would like to cancel your Account, request access or a correction to your personal data (other than corrections you can make in the “My Profile” or “Settings” portions of the Services), please contact us using the “Contact Us” feature within the Services. If you do not want your information accessed or stored as described in this Notice, you should not access, use, or register an Account with the Services.
To the extent provided by the law of your jurisdiction, you may also have the following rights:
8.1. Right to withdraw your consent. If you have given your consent regarding certain types of processing activities (in particular regarding the receipt of certain direct marketing communications), you can withdraw this consent at any time with future effect. Such a
withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You can withdraw your consent by clicking on the withdraw option in relevant communication or by contacting your relationship manager (for existing customers).
8.2. Access. If provided by applicable data protection law, you have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and to request access to the personal data. Depending on your jurisdiction, the access information may include the purposes of the processing, the envisaged period for which the personal data will be stored, or if not possible, the criteria used to determine that period, the categories of personal data concerned, the categories of sources of the personal data, the categories of personal data disclosed to third parties (if any) and the recipients or categories of recipients to whom the personal data have been or will be disclosed. You may also have the right to obtain a copy of the personal data we hold about you.
8.3. Correction. Where provided by applicable data protection law and taking into account the nature of the personal data and the purposes of processing of the personal data, you may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
8.4. Deletion. Where provided by applicable data protection law, you have the right to request deletion of personal data concerning you and we are obliged to delete such data, except where retention is required by contract, in the context of a legal dispute or other legal retention requirement, or as otherwise permitted by applicable law.
8.5. Restriction. Where provided by applicable data protection law, you have the right to request the restriction of processing of your personal data (for example, where the accuracy of the personal data is contested). In this case, the respective personal data will be marked and may only be processed by us with your consent or for certain purposes.
8.6. Portability. Where provided by applicable data protection law, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that personal data to another entity without hindrance from us, where the processing is carried out by automated means and is based on consent or contract.
8.7. Opt out of the Sales or Sharing of Personal Data. You may have the right to direct us not to sell your personal data to third parties for monetary or other valuable consideration, or “share” your personal data to third parties for cross-context behavioral advertising purposes and targeted advertising purposes.
8.8. Automated Decision-Making/Profiling. You may have the right to direct us not to use automated decision-making or profiling for certain purposes.
8.9. Right to Appeal. Depending on your jurisdiction, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted through the information provided in the “How to contact us” section of this Notice.
a) Colorado Residents: If your appeal is denied, you may contact the Colorado Attorney General to address your concerns here.
b) Connecticut Residents: If your appeal is denied, you may contact the Connecticut Attorney General to submit a complaint here.
c) Virginia Residents: If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint here.
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.
8.10. Objection. Where provided by applicable data protection law and under certain circumstances, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your data by us and we are required to no longer process your data. Such right to object especially applies if we collect and process your data for direct marketing purposes. If you have a right to object and if you exercise this right, your data will no longer be processed for such purposes by us, except where required by law, where we demonstrate a compelling legitimate grounds for the processing that overrides your interests or fundamental rights and freedoms or for the establishment, exercise or defense of legal claims.
Additionally, to the extent the European Union General Data Protection Regulation (GDPR) applies, you also have the right to lodge a complaint with the competent data protection supervisory authority in the relevant Member State (e.g., the place where you reside, work, or where an alleged infringement of the GDPR took place).
Submitting Privacy Rights Requests
To submit a request to exercise one of the privacy rights identified above, please utilize the information provided in the “How to contact us” section of this Privacy Notice.
Before processing your request, we may need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the successful authentication of your customer account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we may require
requests to include email address, phone number, and/or date of last transaction on our Services. We may at times need to request additional personal data from you, taking into consideration our relationship with you and the sensitivity of your request.
In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of one of the eligible states or where we are unable to verify your identity.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
We retain personal data only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal data 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 data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data 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 data for as long as the individual continues to use our services for the purposes explained in this Privacy Notice. When an individual discontinues the use of our services, we will retain their personal data 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 data supplied when joining our services, including complaints, claims and any other personal data 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 data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.
10.1. Children. The Services is intended for users over the age of 18 and is not directed to children under 13. We do not sell the personal data of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.
If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us by using the contact information at the end of this Privacy Notice. We may not be able to modify or delete your information in all circumstances.
If you become aware that a child has provided us with personal data without parental consent, please contact us by using the contact information at the end of this Privacy Notice, and we will take steps to remove the information and terminate the child's account.
10.2. Additional Information.
Nevada. If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information under Chapter 603A, you can submit such a request through the information provided in the “How to contact us” section of this Privacy Notice.
Modification of this Notice. We will occasionally update this Notice, in our sole discretion. When we post changes to this Notice, we will revise the "Last updated date” at the top of this Notice in order to notify you of changes. We recommend that you check the Services from time to time to inform yourself of any changes in this Notice or any of our other policies. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
HOW TO CONTACT US
If you have questions, concerns or complaints regarding your existing account please contact us using the “Contact Us” feature within the Services.
If you have questions, concerns or complaints about our privacy practices, please contact our Privacy Office at:
Warn Industries, Inc.
12900 SE Capps Road
Clackamas, OR 97015
Attn: Legal Department
ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS
The following disclosures apply only to California residents.
12.1 California Data Categories
California law requires we provide disclosures to you about what personal data we collect by reference to the enumerated categories of personal data set forth within California law. To address this obligation, we have identified the relevant enumerated California personal data category for the personal data, sources and purposes described in the Personal Data We Collect section of our Privacy Notice that we have collected in the preceding 12 months below:
Identifiers, including account identifiers, credit and identity information relating to data used to identify an individual, full name, IP address.
Customer Records, including contact information, security/authentication information, account history relating to individual accounts, and payment information.
Commercial Information, including account history relating to an individual’s purchases, service profile information relating to an individual’s purchases and interests, and feedback information.
Internet/Network Information, including log data, analytics data and application data.
Geolocation Data, including general geographic location.
Profession/Employment Information, including 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.
Other Personal Data, including communication preferences, customer service and communication history, personal data an individual permits us to see when interacting with us through social media, and personal data an individual provides us in relation to a question, request, inquiry, survey, contest or promotion.
Inferences, including our predictions about interests and preferences and related Service Profile Information.
We collect this data from the following sources: directly from you, from our business partners and affiliates, from your browser or device when you visit our mobile app(s) or use our Services, or from third parties that you permit to share information with us. Please see the Personal Data We Collect section of our Privacy Notice for more information about the sources of personal data we collect. We disclose all of these categories of personal data for a business purpose to service providers or other third parties at the consumer’s direction, as outlined in the How We Share Information section of our Privacy Notice.
12.2 Sales, Sharing or Targeted Advertising
As further described in the How We Share Information section of the Privacy Notice, we may “sell” or “share” your personal data (as those terms are defined by the CPRA) to third parties, subject to your right to opt out of those sales or sharing.
In the last 12 months, we may have sold or shared the following categories of personal data for the purposes described in our Privacy Notice, subject to your settings and preferences and your Right to Opt-Out: identifiers and network information, such as IP address and advertising ID.
The categories of third parties to whom we may sell or share the personal data include Analytics Providers and Customer Data Management Platforms for advertising and marketing purposes.
The Company honors the Global Privacy Control on your browser through our Cookie Management tool.
To Exercise Your Right to Opt Out of Personal Data Sharing
As is common practice among companies that operate online, we do allow certain third-party advertising networks, social media companies and other third-party businesses to collect information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage,
Geolocation Data, and Inferences generated from your browsing history and interactions with our service as well as other sites and services. These third parties use this personal data to serve relevant ads on our site, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.
By visiting here, you can opt out from sales of this type of personal data by businesses that participate in the opt-out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at https://www.privacyrights.info/.
To exercise the Right to Opt-Out of Personal Data Sales or Sharing, you may also submit a request by clicking on the following link:
DO NOT SELL OR SHARE MY PERSONAL INFORMATION
Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request.
Depending on the evidence provided, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
12.3 Sensitive Information
We do not use or disclose “sensitive personal information” of California residents (as that term is defined under the CPRA) for any purpose other than for what would reasonably be expected in connection with the Services, for detecting security incidents, fraud and other illegal actions, or for short term transient use. We do not sell sensitive information, and we do not process or otherwise share
sensitive information for the purpose of targeted advertising.
12.4 Additional Information
“Shine the Light” Disclosures
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes.
To opt out of this type of sharing, please contact us using the information provided in the “How to contact us” section of this Notice.
Notice of Financial Incentives
A part of our business involves the design and implementation of programs and other offerings intended to provide benefits to eligible participants. Most of the programs and other offerings we manage are provided on behalf of our clients. For these programs and other offerings, please refer to the terms and privacy notice of the client with which you have a relationship for information regarding any financial incentives they may offer through our services.
Apart from the programs and other offerings we provide on behalf of our clients, we also provide our own programs and other offerings directly to interested individuals that may qualify as financial incentives. For example, the programs and other offerings we may make available to interested individuals include:
Access to exclusive content, research, and insights; or
Discounts, coupons, cash back, and other special offers for shopping with our partners.
To obtain access to certain of these programs and other offerings, we may ask to collect or share an interested individual’s personal data, including name, contact information, professional information, account information, and shopping transaction information. We have determined that the value of these programs and other offerings are reasonably related to the value of the personal data we receive and otherwise process in connection with these programs and offerings, based on our reasonable but sole determination. We estimate the value of the personal data we receive and otherwise process in connection with these programs and offerings by considering the expense we incur in collecting and processing the personal data, as well as the expenses related to facilitating the program or offering.
The terms applicable to each program and other offering are provided at the time an eligible individual is offered an opportunity to participate. Interested individuals can opt-in to these financial incentives by following the instructions presented at the time the offer is made. Participating individuals may withdraw from our programs and other offerings at any time by following the instructions provided in connection with each offering or through the information provided in the “How to contact us” section of our Privacy Notice.