Table of Contents
- Information We Collect and How We Collect It
- How We Use Your Information
- How We Share Your Information
- Third Party Advertising and Analytics
- How We Respond to “Do Not Track” Signals
- Third Party Content and Links
- Your Choices About the Information We Collect
- Security of Your Information
- General Audience Services
- Consent to International Transfer of Your Information
- Contact Us
- Notice to Nevada Residents
- Notice to California Residents
1. Information We Collect and How We Collect It
SBE collects information in the following ways:
- Information You Provide to Us. In the course of using the Services, you may provide us with certain information, including contact information (such as your name, email address and telephone number). If we implement an SMS/MMS messaging service we may collect various information on our behalf from and about you when you use the messaging service. For example, when you send messages via the messaging service, we will also collect your messaging history and any information included in those messages.
- Information We Collect Automatically From Your Use of the Services. When you use our Services, we, our third-party service providers, and our business partners may automatically collect certain information (“Usage Information”). One of the ways we collect Usage Information is when you use our Services, our servers automatically generate logs to help us determine how you use various features to improve our services. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as personal information. This Usage Information includes your IP address and unique device identifiers (“Device IDs”) for your computer, mobile phone, or other device used to access the Services. A Device ID is a number that is automatically assigned to your device, and our servers identify your device by its Device ID. We will also collect and track other data and information relating to your device, including the hardware model, the Internet service provider you are using, browser, and operating system you are using. We may track your use of the Services, including the features you access and how you interact with the Services.
We use the following types of tracking technologies (collectively referred to as “Tracking Technologies”) to automatically collect information when you interact with us online:
Web beacons (also known as clear GIFs and pixel tags) are small pieces of code used to collect usage analytics. They help us to determine, for instance, whether a page has been viewed or not and, if so, how many times. When you ask us to send you information on a promotion or a newsletter, we will use web beacons to establish how many of the emails are actually opened. We use similar tools to collect such information from mobile devices. In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
- Information from Third Parties. We may receive information about you from third parties, such as business partners who work with us to provide you access to content or other features.
If you choose to post information to a third party platform, that information may be public and the third party may have access to information about you and your use of the Services. You may also choose to participate in a way that connects that third-party service with the Services, such as posting to one of our pages on a social media site. Doing so may allow us to collect (or the third party to share) information about you, including personal information, and the third party may allow us to re-post content related to us on our own services.
In addition, these third parties may set their own cookies and collect information about your use of the Services, including your IP address or other device identifiers, and which pages you visit on the Services. Certain third-party platforms may be able to collect certain information on your visits to the Services regardless of whether or not you affirmatively interact with the feature. We encourage you to review the privacy policies of third parties that control platforms you post to or that connect to the Services and set your privacy preferences with them.
2. How We Use Your Information
- to provide the Services to you and allow you to participate in the features the Services offer;
- to customize and optimize our content for you, such as advertisements we display to you elsewhere online;
- to provide information on special offers and promotions from us, our advertisers, and third-party partners, using the contact information you provide, including, with your consent where required, contacting you at any mobile phone number that you provide to us by way of direct dial calls, autodialed and prerecorded message calls, text messages and push notifications;
- to improve and monetize the Services, which may include tracking traffic, usage, trends and navigation patterns related to your user activities;
- to operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products);
- to contact you to respond to your customer service questions, feedback, or requests or to provide you with technical support;
- to communicate with you about the services, content, features or products you use or request, including to provide you with information concerning changes or updates to the Services which may affect your use of the Services or in our discretion, changes to our policies;
- to respond to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims;
- in any other way we describe when you provide the information, or otherwise with your prior consent.
We may aggregate, de-identify, and/or anonymize any information collected through the Services such that the related information is no longer linked to your personal information. We may share non-personal information (including hashed or other de-identified data) with third parties for advertising and other purposes. We do not share your personal information with third parties for those third parties’ own direct marketing purposes unless we provide you the opportunity to opt-in or opt-out prior to such sharing, as required by applicable law.
- At Your Request. We may share information when you direct us to do so, such as if we present you with an opportunity to receive marketing offers from a third party, or if you choose to engage with a social media service or third party feature through which information about you is shared. We do not control the actions of third parties, and you direct us to share your information at your own risk.
- Service Providers. We may contract with certain companies to perform services on our behalf, including advertising, marketing assistance, e-mail delivery, hosting services, site maintenance and repair, security, quality assurance, customer service, surveys, and data research and analysis, and provide your information to them only to fulfill such services.
- Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, or other promotions (any of which, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion’s terms or official rules (such as on a winner’s list).
- In Connection with Business Transactions. In the event SBE undergoes a business transition, such as a merger with or acquisition by another company, or sale of all or a portion of its assets, we may transfer your personal information and other information to the successor organization in connection with such transaction, including during the course of any due diligence. By providing your personal information, you agree that we may transfer such information to the other entity in such a transaction without your further consent. If material changes to the Services’ privacy practices will occur as a result of the business transition, SBE or its successor will attempt to notify you, including by posting a notice on the Services.
- For Administrative and Legal Reasons. We reserve the right to use or disclose any information as needed to satisfy any law, regulation, or legal request; to protect the integrity of the Services; to fulfill your requests; to cooperate in a law enforcement investigation, an investigation on a public safety matter, or an investigation into claims of intellectual property infringement; to protect and defend the legal rights and/or property of SBE and any of our affiliates, our and their shareholders, the Services, any users of the Services, or any other person; or, in an emergency, to protect the health and safety of users or the general public.
4. Third Party Advertising and Analytics
SBE works with third party business partners such as online advertising companies, analytics providers, and other partners to serve our ads online, and to provide us with information regarding the use of the Services and the effectiveness of our advertisements. We allow these companies to place tracking technologies like cookies and web tags on the Services, and they may otherwise collect or have access to Usage Information and other information about you. Some of these parties may collect personal information over time when you interact with the Services or other online websites and services. We may share information, typically information that has been aggregated or de-identified, Usage Information, and location information with third party advertising companies, analytics providers, and other third parties including for targeted advertising purposes.
We use a variety of third parties to perform advertising and analytics services, and some of these companies may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”). You may wish to visit optout.networkadvertising.org, which provides information regarding targeted advertising and the opt-out procedures of NAI members, including opt out mechanisms for web browsers, mobile and other connected devices, and a tool to opt out from participating NAI members using your hashed email address for interest-based advertising. You may also want to visit optout.aboutads.info, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies.
Please note that opting out through these mechanisms does not opt you out of being served advertising, and that you will continue to receive generic ads while online.
If you are a California resident, please see our NOTICE TO CALIFORNIA RESIDENTS.
5. How We Respond to “Do Not Track” Signals
Do Not Track (“DNT”) signals offered by some web browsers are settings that request that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to stop tracking your activity. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we may not alter our practices when our systems receive a “Do Not Track” signal from a visitor’s browser, except as specifically required by law. You can learn more about Do Not Track at www.allaboutdnt.com.
6. Third Party Content and Links
7. Your Choices About the Information We Collect
You may opt out of marketing communications as set forth below.
- Other Privacy Rights. If you are a resident of specific states, you may have additional rights. Residents of the below listed regions should refer to the linked notices for more information on additional rights and how to exercise them:
8. Security of Your Information
We implement commercially reasonable security measures to protect the security of your information. However, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe.
9. General Audience Services
The Services are not intended for children younger than the age of 18. We do not knowingly collect or solicit personal information from children younger than the age of 18.
10. Consent to International Transfer of Your Information
We are a US-based company so if you are located outside of the United States, please be aware that the information that we collect from you will be transferred to, and stored at, a destination outside of your country. By using our Services or providing us with any information, you fully understand and unambiguously consent to this transfer to, and processing, usage, sharing, and storage of your information in the United States and other jurisdictions, which may have different or less protective privacy laws than those in your country. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to the laws in those jurisdictions. Your information will also be disclosed to third parties as described in the “How We Share Your Information” section above.
12. Contact Us
13. Notice to Nevada Residents
Nevada S.B. 220 provides consumers with the ability to opt out of the sale of their personal information. We do not sell your personal information as defined in S.B. 220. However, you may still submit an opt-out request, and if our practices were to change in the future, we would honor your request. If you are a Nevada resident and would like to opt out of the sale of your covered information, your request must be submitted to email@example.com. Your request must include your full name, street address, city, state, zip code, and a valid email address so that we can contact you if needed regarding your request. If you previously provided a phone number, including it will assist us in making sure we identify you as someone who wants to opt out. You may be required to take reasonable steps as we determine from time to time to verify your identity and/or the authenticity of your request.
14. Notice to California Residents