Privacy Policy

Last updated: January 30, 2024

1661, Inc. dba GOAT (“GOAT”) and its affiliates (collectively, “GOAT Group,” “we,” “us,” “our”) provides this Privacy Policy to inform you about how we collect, use, disclose, and otherwise process personal information when individuals (“you”) access our websites (the “Sites”), our mobile applications (“Apps”), or in-person events or locations, and all related content, products, services, platforms, other functionalities offered on or through our services, and any other properties or locations that link to this Privacy Policy (collectively, the “Services”). This Privacy Policy does not address our privacy practices relating to job candidates, employees and other personnel.

 

TABLE OF CONTENTS

I. OUR COLLECTION AND USE OF PERSONAL INFORMATION

II. DISCLOSURE OF PERSONAL INFORMATION

III. CONTROL OVER YOUR INFORMATION

IV. DATA RETENTION

V. CHILDREN’S PERSONAL INFORMATION

VI. LINKS TO THIRD-PARTY WEBSITES OR SERVICES

VII. UPDATES TO THIS PRIVACY POLICY

VIII. CONTACT US

IX. REGION-SPECIFIC DISCLOSURES

COOKIE POLICY

 

I. OUR COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information in a variety of ways. For example, you may provide us with your personal information when you make a purchase, list an item for sale, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of our Services.

We may link or combine information collected from you on our Sites and Apps with information we have collected from you offline (e.g., in-person), information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to, for example, provide you with a personalized experience regardless of how you interact with us.

The personal information we collect, the way we collect it, and how we use it will depend on how you are interacting with us and the type of services you use.

Personal Information Collected from You

Personal Information from Third Parties

We may also combine the information we receive from you with personal information we obtain from third parties. We may receive the same categories of personal information as described above from the following third parties:

Personal Information Collected at Our In-Person Locations

When you visit one of our in-person locations, we may collect the following information from or about you:

Personal Information Automatically Collected

As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, as described in the list below:

For more information about these practices and your choices regarding cookies, please see the Cookie Policy located at the end of this Privacy Policy.

Additional Uses of Personal Information

In addition to the uses described above, we may use the personal information collected as described above for the following purposes:

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry or request and/or personal information we require fall outside the scope of this Privacy Policy. In that case, the additional privacy-related information will govern how we may process the information provided at that time.

Through the provision of our Services, we may process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. We will maintain and use such information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used satisfies the requirements under applicable law.

We may also aggregate data for reporting, analytics, and other business reasons, including to promote or describe the use of our Services.

 

II. DISCLOSURE OF PERSONAL INFORMATION

As part of our Services, we may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

 

III. CONTROL OVER YOUR INFORMATION

You may control your information in the following ways:

 

IV. DATA RETENTION

We will usually store the personal information we collect about you for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. 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.

For example, if you reside in the European Economic Area, the United Kingdom or the State of California, your personal information may be subject to certain laws and regulations that define the criteria used to determine the period for which personal information about you will be retained, which varies depending on the legal basis under which we process the personal information:

When an individual discontinues the use of our 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. 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 deidentify the personal information or, if this is not possible (e.g., 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 deidentification is possible.

 

V. CHILDREN’S PERSONAL INFORMATION

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

 

VI. 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 Policy, this Privacy Policy 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. To learn about the personal information practices of third parties, please visit their respective privacy policies.

 

VII. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, 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.

 

VIII. CONTACT US

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to [email protected].

Alternatively, inquiries may be addressed to:

GOAT Group

Attn: Privacy Department

P.O. Box 91258

Los Angeles, CA 90009-1258

 

IX. REGION-SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional information relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

 

ADDITIONAL U.S. STATE PRIVACY DISCLOSURES

Last updated: November 6, 2023

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 Policy by providing additional information about our personal information 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 our Privacy Policy. Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in these U.S. Disclosures.

For the purposes of these U.S. Disclosures, personal information does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.

Your Privacy Choices

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

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.

How to Exercise Your Privacy Rights

To submit a request to exercise one of the privacy rights identified above, please submit a request:

We may need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log in to your account, if you have one. Note that we may need to request additional information from you to verify your identity or process your request, although you will not be required to create an account with us to submit a request or have it fulfilled. At a minimum, we may ask you for your name, email address, and telephone number. We will use the personal information you provide us in connection with your exercise of the above rights only to review and comply with your 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.

Exercise Your Right to Opt-Out of Personal Information Sales or Sharing for Targeted Advertising

We do not “sell” personal information as most people would typically understand that term (i.e., we do not share your information in exchange for money), but certain uses may be deemed the “sale” of personal information under applicable privacy laws. Unless you have exercised your Right to Opt-Out, we may disclose or “sell” your personal information to third parties for non-monetary 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, you may submit a request by:

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. 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: (a) a power of attorney valid under the laws of the state where you reside from you or your authorized agent; or (b) sufficient evidence to show that you have: (i) provided the authorized agent signed permission to act on your behalf; and (ii) verified your own identity directly with us pursuant to the instructions set forth in these U.S. Disclosures; or 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 a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by emailing [email protected] or mailing a letter to us at the following address: GOAT Group, Attn: GOAT Group CCPA, P.O. Box 91258, Los Angeles, CA 90009-1258.

California-Specific Disclosures

The following disclosures only apply to residents of the State of California.

In the last 12 months, we may have collected the following categories of sensitive personal information: account log-in in combination with a password allowing access to an account, as well as social security number, government ID, and biometric information (i.e., facial geometry). We do not use or disclose sensitive personal information for any purpose other than for performing services you have requested, for detecting security incidents, fraud and other illegal actions, complying with applicable laws, regulations or other legal obligations, or for short term transient use. We collect and process sensitive information without the purpose of inferring characteristics about a consumer, and we do not sell sensitive information or process or otherwise share sensitive personal information for the purpose of targeted advertising.

For more information about our collection of personal information, the sources of personal information, and how we use this information, please see the Our Collection and Use of Personal Information section of our Privacy Policy.

In addition, please see our Cookie Policy located at the end of this Privacy Policy to learn more about how third-party advertising networks, social media companies and other third-party businesses collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our Sites, use our Apps or otherwise engage with us.

Minors. We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under the age of 16. Please contact us at [email protected] to inform us if you, or your minor child, are under the age of 16.

If you are under the age of 18 and you want to delete your account, please contact us directly at [email protected]. We may not be able to modify or delete your information in all circumstances.

If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).

“Shine the Light”. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the way 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 email us at [email protected].

Financial Incentives. We may provide financial incentives to consumers who allow us to collect and retain personal information, such as identifiers (e.g., name and email address) and commercial information (e.g., purchase history). These incentives may result in differences in our prices or services offered to consumers and may include a lower price for goods and services (e.g., discounts and other promotions). For example, the financial incentives we may provide include discounts or promo codes for certain existing customers. The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer.

Please note that participating in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions or contact us using the contact information referenced in the Contact Us section of the Privacy Policy.

Each financial incentive or price or service difference related to the collection and use of personal information is based upon our reasonable, good faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty and/or repeat purchases.

 

ADDITIONAL CANADA-SPECIFIC PRIVACY DISCLOSURES

Last updated: October 10, 2023

This section contains disclosures required by the Personal Information Protection and Electronic Documents Act and substantially similar provincial privacy laws in Canada, including Quebec’s Act respecting the protection of personal information in the private sector, as may be amended from time to time (“Canada Disclosures”). These Canada Disclosures supplement the information contained in our Privacy Policy and apply solely to individual residents of Canada (“you”). Unless otherwise expressly stated, all terms in this section have the same meaning as defined in our Privacy Policy or as otherwise defined in the applicable Canadian privacy law. Please note our Privacy Officer can be contacted at [email protected].

Cross-jurisdictional Transfers. By providing us with personal information, you acknowledge and agree that your personal information may be transferred to other jurisdictions for processing and storage, including in servers located across Canada and in the United States, where laws regarding the protection of personal information may be less stringent than the laws in your jurisdiction. Further, your personal information may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information.

Your Legal Rights. Subject to certain exemptions, as permitted by law, you have the following rights in relation to the personal information we hold about you:

ADDITIONAL PRIVACY DISCLOSURES FOR EEA, UK AND SWISS USERS

Last updated: December 18, 2023 

This section contains disclosures on how we collect, store, process, transfer, share, or use data that identifies or is associated with residents of the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“UK”) ("personal data") and information regarding our use of cookies and similar technologies (collectively, “EU Disclosures”) in connection with the Services. These EU Disclosures supplement the information contained in our Privacy Policy and apply solely to residents of the EEA, Switzerland, and the UK (“you”). Please ensure that you have read and understood these EU Disclosures before accessing or using the Services. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in our Privacy Policy or as otherwise defined in the EU General Data Protection Regulation and the UK General Data Protection Regulation (collectively, “GDPR”).

The controller, which is the company belonging to GOAT Group that is responsible for the processing of your personal data, depends on how you interact with the GOAT Group brands. As such, the relevant controller will typically consist of one or two entities: (1) The main entity who manages the GOAT Group brands based on region, and, if applicable, (2) the local company you interact with in connection with localized activities (e.g., marketing campaigns, events, promotions). In connection with the local controller, the controller and contact information will be disclosed in the specific method of interaction.

Personal Data We Collect from You When You Use the Services and How We Use It. We collect personal data as set out in the Our Collection and Use of Personal Information section of our Privacy Policy. We will indicate to you where the provision of certain personal data is mandatory. If you choose not to provide such personal data, we may not be able to provide those parts of the Services to you or respond to your other requests.

Annex 1, below, sets out in detail the categories of personal data we collect about you and how we use that information when you use the Services, as well as the legal basis which we rely on to process the personal data and recipients of that personal data.

Information We Collect About You Automatically. We also automatically collect personal data indirectly about how you access and use the Services, and information about the device you use to access the Services, or otherwise engage with us. Please see our Cookie Policy located at the end of this Privacy Policy for more information about what data we collect and how we use it.

Annex 2, below, sets out in detail the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal data and recipients of that personal data. For more information on cookies and other tracking technologies we use, please see our Cookie Policy.

Marketing and Advertising. From time to time, we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

Storing and Transferring Your Personal Data.

Your Rights in Respect of Your Personal Data. In accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold:

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason. 

You also have the right to lodge a complaint to your local data protection authority. Information about how to contact your local data protection authority is available here.

If you wish to exercise one of these rights, please contact us using the details referenced in the Contact Us section of the Privacy Policy.

Due to the confidential nature of data processing, we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

 

ANNEX 1: PERSONAL DATA YOU PROVIDE TO US

Contact information and identifiers, such as your first name, last name, email address, phone number, and birthdate.

Profile and log-in information. This is information you choose to put in your profile such as username, phone number, photo, mailing address and shoe size.

Payment and transaction information, such as your credit/debit card numbers, payment authentication code, billing address, and other information such as date and time of your transaction.

Identity and compliance information, such as your name, birthdate, address, phone number, email address, bank account information, government ID number, VAT ID number or other tax ID number, and copies of national ID or tax documents, along with a selfie image. This information may also be used by our third-party provider, Persona, to create a unique biometric identifier based on facial geometry.

Information about your activity on the Services, such as any offers for products you have made, any products on your 'want list', and information about any products you have purchased, listed for sale or sold.

Chat, comments, opinions. When you contact us directly (e.g., by email or phone), we may record your comments and opinions.

Your preferences such as preferences set for notifications, marketing communications, how the Services are displayed and the active functionalities on the Services.

All personal data set out above.

 

ANNEX 2: PERSONAL DATA COLLECTED AUTOMATICALLY

Approximate location information. Other than information you choose to provide to us (when you enable location services and/or grant permission for location tracking), we do not collect information about your precise location. Your device’s IP address may however help us determine an approximate location.

Information about how you access and use the Services. For example, how frequently you access the Services, the time you access the Services and how long you use it for, the approximate location that you access the Services from, the site from which you came and the site to which you are going when you leave our Site, the website pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, and other actions you take on the Services.

Log files and information about your device. We also collect information about the tablet, smartphone or other electronic device you use to connect to the Services. This information can include details about the type of device, unique device identifiers, operating systems, browsers and applications connected to the Services through the device, your mobile network, your IP address and your device’s telephone number (if it has one).

Recipients of personal data set forth above. We may share this information with the following: affiliates and third-party providers, including payment processors, customer support platforms, email marketing providers, fraud prevention vendors, cloud storage providers and analytics providers; and third-party social media platforms.

 

ANNEX 3: PROVISIONS FOR INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA TO THE UNITED STATES

GOAT and its U.S. subsidiaries (Flight Club New York, LLC and Grailed, LLC) (hereinafter “we”) comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. We have certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles (collectively, the DPF Principles), the DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please click here.

The Federal Trade Commission has jurisdiction over our compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

Complaints per the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF

In compliance with the EU-U.S. DPF, and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we commit to resolve DPF Principles-related complaints about our collection and use of your personal data. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact us using the details referenced in the Contact Us section of the Privacy Policy. EU, UK and Swiss individuals may, under certain circumstances, invoke binding arbitration with respect to complaints about our collection and use of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. See DPF Annex 1 here.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to Judicial Arbitration and Mediation Services, Inc. (JAMS), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit here for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Onward transfers to third parties

In the event that we disclose your personal data to third parties to perform certain business-related services on our behalf as “agents” (as such term is utilized under the DPF), we will do so only for limited and specified purposes consistent with any notice provided to you or your choices regarding processing and disclosure. These companies perform services at our instruction and pursuant to contracts which require they provide at least the same level of privacy protection as is required under the DPF and notify us if they are no longer able to provide such protections, at which point we will take reasonable remedial steps. We may also disclose personal data to our affiliates in order to support marketing, sale, and delivery of any services, or other business operations as disclosed in the Disclosure of Personal Information section of the Privacy Policy and Annex 1 to the Additional Privacy Disclosures for EEA, UK and Swiss Users.

Our accountability for personal data that we receive under the DPF and subsequently transfers to a third party is described in the DPF Principles. In particular, we remain responsible and liable under the DPF Principles if third-party agents that we engage to process the personal data on our behalf do so in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Option to limit certain onward transfers to third parties

You have the opportunity to opt out of sharing of your personal data with third parties other than our agents or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal data under the DPF, please submit a written request using the details referenced in the Contact Us section of the Privacy Policy, indicating as such.

We will not disclose your sensitive personal data to any third party without first obtaining your opt-in consent.

In each instance, please allow us a reasonable amount of time to process your response.

Your DPF rights

Upon request to us, we will confirm whether we are processing your personal data pursuant to the DPF and provide you with the data in a reasonable amount of time. You also have the right to correct, amend, or delete the personal data processed pursuant to the DPF where it is inaccurate or has been processed in violation of our privacy disclosures to you, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable amount of time to respond to your inquiries and requests.

Personal data retention

We will retain the personal data processed pursuant to the DPF in a form that identifies you pursuant to the retention policy described above. We may continue processing such personal data for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of our privacy disclosures. After such time periods have expired, we may either delete your personal data or retain it in a form such that it does not identify you personally.

How we protect your data

We will implement reasonable and appropriate security measures to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data.

If you wish to enquire further about these safeguards used, please contact us using the details referenced in the Contact Us section of the Privacy Policy.

 

COOKIE POLICY

Last updated: November 6, 2023

Unless otherwise expressly stated, terms in this policy have the same meaning as defined in the Privacy Policy.

I. SCOPE OF POLICY

This Cookie Policy supplements the information contained in the Privacy Policy and explains how we and our third-party partners and service providers use cookies and related technologies while managing and providing our online services and our electronic communications to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases, we may use cookies and related technologies described in this Cookie Policy to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information, please review the Privacy Policy.

2. WHAT ARE COOKIES AND RELATED TECHNOLOGIES

As is common practice among websites, our Services use cookies, which are tiny files downloaded to your device that allow us and our third-party partners and service providers to collect certain information about your interactions with our email communications, Sites and other online services, and that improve your experience. We and our third-party partners and service providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).

We use the following types of cookies:

If you are visiting the Site from the EEA, please see the Cookie Library by clicking on “Cookie Settings” at the footer of this page for more information about the cookies we use on the Site. For App users, please see the SDK Library by going to your Profile > Settings > Privacy & Security > Privacy Settings in the Apps for more information about the technologies we use on the Apps. Please see our Privacy Policy for more information about cookies and other similar technologies.

3. WHAT WE COLLECT WHEN USING COOKIES

We and our third-party partners and service providers may use cookies to automatically collect certain types of usage information when you visit or interact with our emails and Services. For example, we may collect log data about your device and its software, such as your IP address, unique device identifier, date and time of your visit, and other similar information. Our emails may also contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. We may also collect analytics data or use third-party analytics tools to help us measure usage and activity trends for our online services and better understand the individuals using our services. We also may collect location data, including general geographic location based on IP address.

We may include or engage in the following as part of our Services:

 

4. HOW WE USE INFORMATION COLLECTED VIA COOKIES

We use cookies for a variety of reasons outlined below:

Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in our Privacy Policy.

5. YOUR CHOICES ABOUT COOKIES

If you are in the EEA, UK, or Switzerland, other than strictly necessary cookies, which are required for the operation of our Service, we will only place cookies on your device if you give us your consent to do so. We will ask you to tell us which cookies you agree to receive when you first access our Service.

If you would prefer not to accept cookies, you can use our cookie consent management tool located at the bottom of the Site. Moreover, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.

Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. These settings will typically be found in the "options" or "preferences" menu of your browser. To understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.

Cookie settings in Internet Explorer

Cookie settings in Firefox

Cookie settings in Chrome

Cookies settings in Safari web and iOS

You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our emails and performed certain functions with them.

If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative's online sources here.

Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.