Privacy Policy

Last updated: September 13, 2022

 

This Privacy Policy describes Our policies and procedures on the collection,

use and disclosure of Your information when You use the Service and tells You

about Your privacy rights and how the law protects You.

 

We use Your Personal data to provide and improve the Service. By using the

Service, You agree to the collection and use of information in accordance with

this Privacy Policy.

 

Interpretation and Definitions 

Interpretation 

The words of which the initial letter is capitalized have meanings defined

under the following conditions. The following definitions shall have the same

meaning regardless of whether they appear in singular or in plural.

 

Definitions 

For the purposes of this Privacy Policy:

 

  •   Account means a unique account created for You to access our Service or

parts of our Service.

 

  •   Business, for the purpose of the CCPA (California Consumer Privacy Act),

refers to the Company as the legal entity that collects Consumers'

personal information and determines the purposes and means of the

processing of Consumers' personal information, or on behalf of which such

information is collected and that alone, or jointly with others,

determines the purposes and means of the processing of consumers' personal

information, that does business in the State of California.

 

  •   Company (referred to as either "the Company", "We", "Us" or "Our" in this

Agreement) refers to Miles Franklin, Ltd., 801 Twelve Oaks Center Drive

Suite 834, Wayzata, MN 55391.

 

For the purpose of the GDPR, the Company is the Data Controller.

 

  •   Consumer, for the purpose of the CCPA (California Consumer Privacy Act),

means a natural person who is a California resident. A resident, as

defined in the law, includes (1) every individual who is in the USA for

other than a temporary or transitory purpose, and (2) every individual who

is domiciled in the USA who is outside the USA for a temporary or

transitory purpose.

 

  •   Cookies are small files that are placed on Your computer, mobile device or

any other device by a website, containing the details of Your browsing

history on that website among its many uses.

 

  •   Country refers to: Minnesota, United States

 

  •   Data Controller , for the purposes of the GDPR (General Data Protection

Regulation), refers to the Company as the legal person which alone or

jointly with others determines the purposes and means of the processing of

Personal Data.

 

  •   Device means any device that can access the Service such as a computer, a

cellphone or a digital tablet.

 

  •   Do Not Track (DNT) is a concept that has been promoted by US regulatory

authorities, in particular the U.S. Federal Trade Commission (FTC), for

the Internet industry to develop and implement a mechanism for allowing

internet users to control the tracking of their online activities across

websites.

 

  •  Personal Data is any information that relates to an identified or

identifiable individual.

 

For the purposes of GDPR, Personal Data means any information relating to

You such as a name, an identification number, location data, online

identifier or to one or more factors specific to the physical,

physiological, genetic, mental, economic, cultural or social identity.

 

For the purposes of the CCPA, Personal Data means any information that

identifies, relates to, describes or is capable of being associated with,

or could reasonably be linked, directly or indirectly, with You.

 

  •   Sale, for the purpose of the CCPA (California Consumer Privacy Act),

means selling, renting, releasing, disclosing, disseminating, making

available, transferring, or otherwise communicating orally, in writing, or

by electronic or other means, a Consumer's personal information to another

business or a third party for monetary or other valuable consideration.

 

  •   Service refers to the Website.

 

  •   Service Provider means any natural or legal person who processes the data

on behalf of the Company. It refers to third-party companies or

individuals employed by the Company to facilitate the Service, to provide

the Service on behalf of the Company, to perform services related to the

Service or to assist the Company in analyzing how the Service is used. For

the purpose of the GDPR, Service Providers are considered Data Processors.

 

  •   Usage Data refers to data collected automatically, either generated by the

use of the Service or from the Service infrastructure itself (for example,

the duration of a page visit).

 

  •   Website refers to Miles Franklin Precious Metals Investments, accessible

from <https://www.milesfranklin.com>

 

  •   You means the individual accessing or using the Service, or the company,

or other legal entity on behalf of which such individual is accessing or

using the Service, as applicable.

 

Under GDPR (General Data Protection Regulation), You can be referred to as

the Data Subject or as the User as you are the individual using the

Service.

 

Collecting and Using Your Personal Data 

Types of Data Collected 

 

Personal Data 

 

While using Our Service, We may ask You to provide Us with certain personally

identifiable information that can be used to contact or identify You.

Personally identifiable information may include, but is not limited to:

 

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Bank account information in order to pay for products and/or services within the Service
  • Usage Data

 

When You pay for a product and/or a service via bank transfer, We may ask You

to provide information to facilitate this transaction and to verify Your

identity. Such information may include, without limitation:

 

  •   Date of birth
  •   Passport or National ID card
  •   Bank card statement
  •   Other information linking You to an address

 

Usage Data 

 

Usage Data is collected automatically when using the Service.

 

Usage Data may include information such as Your Device's Internet Protocol

address (e.g. IP address), browser type, browser version, the pages of our

Service that You visit, the time and date of Your visit, the time spent on

those pages, unique device identifiers and other diagnostic data.

 

When You access the Service by or through a mobile device, We may collect

certain information automatically, including, but not limited to, the type of

mobile device You use, Your mobile device unique ID, the IP address of Your

mobile device, Your mobile operating system, the type of mobile Internet

browser You use, unique device identifiers and other diagnostic data.

 

We may also collect information that Your browser sends whenever You visit our

Service or when You access the Service by or through a mobile device.

 

Tracking Technologies and Cookies 

 

We use Cookies and similar tracking technologies to track the activity on Our

Service and store certain information. Tracking technologies used are beacons,

tags, and scripts to collect and track information and to improve and analyze

Our Service. The technologies We use may include:

 

  •   Cookies or Browser Cookies. A cookie is a small file placed on Your

Device. You can instruct Your browser to refuse all Cookies or to indicate

when a Cookie is being sent. However, if You do not accept Cookies, You

may not be able to use some parts of our Service. Unless you have adjusted

Your browser setting so that it will refuse Cookies, our Service may use

Cookies.

  •   Flash Cookies. Certain features of our Service may use local stored

objects (or Flash Cookies) to collect and store information about Your

preferences or Your activity on our Service. Flash Cookies are not managed

by the same browser settings as those used for Browser Cookies. For more

information on how You can delete Flash Cookies, please read "Where can I

change the settings for disabling, or deleting local shared objects?"

available at <https://helpx.adobe.com/flash-player/kb/disable-local-

shared-objects-

flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_>

  •   Web Beacons. Certain sections of our Service and our emails may contain

small electronic files known as web beacons (also referred to as clear

gifs, pixel tags, and single-pixel gifs) that permit the Company, for

example, to count users who have visited those pages or opened an email

and for other related website statistics (for example, recording the

popularity of a certain section and verifying system and server

integrity).

 

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on

Your personal computer or mobile device when You go offline, while Session

Cookies are deleted as soon as You close Your web browser. You can learn more

about cookies on [TermsFeed

website](https://www.termsfeed.com/blog/cookies/#What_Are_Cookies) article.

 

We use both Session and Persistent Cookies for the purposes set out below:

 

  •   Necessary / Essential Cookies

 

  •   Type: Session Cookies

 

  •   Administered by: Us

 

Purpose: These Cookies are essential to provide You with services

available through the Website and to enable You to use some of its

features. They help to authenticate users and prevent fraudulent use of

user accounts. Without these Cookies, the services that You have asked for

cannot be provided, and We only use these Cookies to provide You with

those services.

 

  •   Cookies Policy / Notice Acceptance Cookies

 

  •   Type: Persistent Cookies

 

  •   Administered by: Us

 

Purpose: These Cookies identify if users have accepted the use of cookies

on the Website.

 

  •   Functionality Cookies

 

  •   Type: Persistent Cookies

 

  •   Administered by: Us

 

Purpose: These Cookies allow us to remember choices You make when You use

the Website, such as remembering your login details or language

preference. The purpose of these Cookies is to provide You with a more

personal experience and to avoid You having to re-enter your preferences

every time You use the Website.

 

  •   Tracking and Performance Cookies

 

  •   Type: Persistent Cookies

 

  •   Administered by: Third-Parties

 

Purpose: These Cookies are used to track information about traffic to the

Website and how users use the Website. The information gathered via these

Cookies may directly or indirectly identify you as an individual visitor.

This is because the information collected is typically linked to a

pseudonymous identifier associated with the device you use to access the

Website. We may also use these Cookies to test new pages, features or new

functionality of the Website to see how our users react to them.

 

For more information about the cookies we use and your choices regarding

cookies, please visit our Cookies Policy or the Cookies section of our Privacy

Policy.

 

Use of Your Personal Data 

 

The Company may use Personal Data for the following purposes:

 

  •   To provide and maintain our Service , including to monitor the usage of

our Service.

 

  •   To manage Your Account: to manage Your registration as a user of the

Service. The Personal Data You provide can give You access to different

functionalities of the Service that are available to You as a registered

user.

 

  •   For the performance of a contract: the development, compliance and

undertaking of the purchase contract for the products, items or services

You have purchased or of any other contract with Us through the Service.

 

  •   To contact You: To contact You by email, telephone calls, SMS, or other

equivalent forms of electronic communication, such as a mobile

application's push notifications regarding updates or informative

communications related to the functionalities, products or contracted

services, including the security updates, when necessary or reasonable for

their implementation.

 

  •   To provide You with news, special offers and general information about

other goods, services and events which we offer that are similar to those

that you have already purchased or enquired about unless You have opted

not to receive such information.

 

  •   To manage Your requests: To attend and manage Your requests to Us.

 

  •   For business transfers: We may use Your information to evaluate or conduct

a merger, divestiture, restructuring, reorganization, dissolution, or

other sale or transfer of some or all of Our assets, whether as a going

concern or as part of bankruptcy, liquidation, or similar proceeding, in

which Personal Data held by Us about our Service users is among the assets

transferred.

 

  •   For other purposes : We may use Your information for other purposes, such

as data analysis, identifying usage trends, determining the effectiveness

of our promotional campaigns and to evaluate and improve our Service,

products, services, marketing and your experience.

 

 

We may share Your personal information in the following situations:

 

  •   With Service Providers: We may share Your personal information with

Service Providers to monitor and analyze the use of our Service, for

payment processing, to contact You.

  •   For business transfers: We may share or transfer Your personal information

in connection with, or during negotiations of, any merger, sale of Company

assets, financing, or acquisition of all or a portion of Our business to

another company.

  •   With Affiliates: We may share Your information with Our affiliates, in

which case we will require those affiliates to honor this Privacy Policy.

Affiliates include Our parent company and any other subsidiaries, joint

venture partners or other companies that We control or that are under

common control with Us.

  •   With business partners: We may share Your information with Our business

partners to offer You certain products, services or promotions.

  •   With other users: when You share personal information or otherwise

interact in the public areas with other users, such information may be

viewed by all users and may be publicly distributed outside.

  •   With Your consent : We may disclose Your personal information for any

other purpose with Your consent.

 

Retention of Your Personal Data 

 

The Company will retain Your Personal Data only for as long as is necessary

for the purposes set out in this Privacy Policy. We will retain and use Your

Personal Data to the extent necessary to comply with our legal obligations

(for example, if we are required to retain your data to comply with applicable

laws), resolve disputes, and enforce our legal agreements and policies.

 

The Company will also retain Usage Data for internal analysis purposes. Usage

Data is generally retained for a shorter period of time, except when this data

is used to strengthen the security or to improve the functionality of Our

Service, or We are legally obligated to retain this data for longer time

periods.

 

Transfer of Your Personal Data 

 

Your information, including Personal Data, is processed at the Company's

operating offices and in any other places where the parties involved in the

processing are located. It means that this information may be transferred to —

and maintained on — computers located outside of Your state, province, country

or other governmental jurisdiction where the data protection laws may differ

than those from Your jurisdiction.

 

Your consent to this Privacy Policy followed by Your submission of such

information represents Your agreement to that transfer.

 

The Company will take all steps reasonably necessary to ensure that Your data

is treated securely and in accordance with this Privacy Policy and no transfer

of Your Personal Data will take place to an organization or a country unless

there are adequate controls in place including the security of Your data and

other personal information.

 

Disclosure of Your Personal Data 

 

Business Transactions 

 

If the Company is involved in a merger, acquisition or asset sale, Your

Personal Data may be transferred. We will provide notice before Your Personal

Data is transferred and becomes subject to a different Privacy Policy.

 

Law enforcement 

 

Under certain circumstances, the Company may be required to disclose Your

Personal Data if required to do so by law or in response to valid requests by

public authorities (e.g. a court or a government agency).

 

Other legal requirements 

 

The Company may disclose Your Personal Data in the good faith belief that such

action is necessary to:

 

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

 

Security of Your Personal Data

 

The security of Your Personal Data is important to Us, but remember that no

method of transmission over the Internet, or method of electronic storage is

100% secure. While We strive to use commercially acceptable means to protect

Your Personal Data, We cannot guarantee its absolute security.

 

Detailed Information on the Processing of Your Personal Data

 

The Service Providers We use may have access to Your Personal Data. These

third-party vendors collect, store, use, process and transfer information

about Your activity on Our Service in accordance with their Privacy Policies.

 

Analytics

 

We may use third-party Service providers to monitor and analyze the use of our

Service.

 

  • Cloudflare

 

Their Privacy Policy can be viewed at

https://www.cloudflare.com/privacypolicy/

 

Email Marketing

 

We may use Your Personal Data to contact You with newsletters, marketing or

promotional materials and other information that may be of interest to You.

You may opt-out of receiving any, or all, of these communications from Us by

following the unsubscribe link or instructions provided in any email We send

or by contacting Us.

 

We may use Email Marketing Service Providers to manage and send emails to You.

 

  • Mailchimp

 

Mailchimp is an email marketing sending service provided by The Rocket

Science Group LLC.

 

For more information on the privacy practices of Mailchimp, please visit

their Privacy policy: https://mailchimp.com/legal/privacy/

 

Payments

 

We may provide paid products and/or services within the Service. In that case,

we may use third-party services for payment processing (e.g. payment

processors).

 

We will not store or collect Your payment card details. That information is

provided directly to Our third-party payment processors whose use of Your

personal information is governed by their Privacy Policy. These payment

processors adhere to the standards set by PCI-DSS as managed by the PCI

Security Standards Council, which is a joint effort of brands like Visa,

Mastercard, American Express and Discover. PCI-DSS requirements help ensure

the secure handling of payment information.

 

  • Plaid Inc.

 

Their Privacy Policy can be viewed at https://plaid.com/legal/#consumers

 

  • Network Merchants, LLC

 

Their Privacy Policy can be viewed at https://www.nmi.com/privacy-policy

 

When You use Our Service to pay a product and/or service via bank transfer, We

may ask You to provide information to facilitate this transaction and to

verify Your identity.

 

GDPR Privacy

 

Legal Basis for Processing Personal Data under GDPR

 

We may process Personal Data under the following conditions:

 

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

 

In any case, the Company will gladly help to clarify the specific legal basis

that applies to the processing, and in particular whether the provision of

Personal Data is a statutory or contractual requirement, or a requirement

necessary to enter into a contract.

 

Your Rights under the GDPR

 

The Company undertakes to respect the confidentiality of Your Personal Data

and to guarantee You can exercise Your rights.

 

You have the right under this Privacy Policy, and by law if You are within the

EU, to:

 

  • Request access to Your Personal Data. The right to access, update or

delete the information We have on You. Whenever made possible, you can

access, update or request deletion of Your Personal Data directly within

Your account settings section. If you are unable to perform these actions

yourself, please contact Us to assist You. This also enables You to

receive a copy of the Personal Data We hold about You.

  • Request correction of the Personal Data that We hold about You. You have

the right to have any incomplete or inaccurate information We hold about

You corrected.

  • Object to processing of Your Personal Data. This right exists where We are

relying on a legitimate interest as the legal basis for Our processing and

there is something about Your particular situation, which makes You want

to object to our processing of Your Personal Data on this ground. You also

have the right to object where We are processing Your Personal Data for

direct marketing purposes.

  • Request erasure of Your Personal Data. You have the right to ask Us to

delete or remove Personal Data when there is no good reason for Us to

continue processing it.

  • Request the transfer of Your Personal Data. We will provide to You, or to

a third-party You have chosen, Your Personal Data in a structured,

commonly used, machine-readable format. Please note that this right only

applies to automated information which You initially provided consent for

Us to use or where We used the information to perform a contract with You.

  • Withdraw Your consent. You have the right to withdraw Your consent on

using your Personal Data. If You withdraw Your consent, We may not be able

to provide You with access to certain specific functionalities of the

Service.

 

Exercising of Your GDPR Data Protection Rights

 

You may exercise Your rights of access, rectification, cancellation and

opposition by contacting Us. Please note that we may ask You to verify Your

identity before responding to such requests. If You make a request, We will

try our best to respond to You as soon as possible.

 

You have the right to complain to a Data Protection Authority about Our

collection and use of Your Personal Data. For more information, if You are in

the European Economic Area (EEA), please contact Your local data protection

authority in the EEA.

 

CCPA Privacy

 

This privacy notice section for California residents supplements the

information contained in Our Privacy Policy and it applies solely to all

visitors, users, and others who reside in the State of California.

 

Categories of Personal Information Collected

 

We collect information that identifies, relates to, describes, references, is

capable of being associated with, or could reasonably be linked, directly or

indirectly, with a particular Consumer or Device. The following is a list of

categories of personal information which we may collect or may have been

collected from California residents within the last twelve (12) months.

 

Please note that the categories and examples provided in the list below are

those defined in the CCPA. This does not mean that all examples of that

category of personal information were in fact collected by Us, but reflects

our good faith belief to the best of our knowledge that some of that

information from the applicable category may be and may have been collected.

For example, certain categories of personal information would only be

collected if You provided such personal information directly to Us.

 

  • Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. Collected: Yes.

 

  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Collected: Yes.

 

  • Category C: Protected classification characteristics under California or federal law. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: No.

 

  • Category D: Commercial information. Examples: Records and history of products or services purchased or considered. Collected: Yes.

 

  • Category E: Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No.

 

  • Category F: Internet or other similar network activity. Examples: Interaction with our Service or advertisement. Collected: Yes.

 

  • Category G: Geolocation data. Examples: Approximate physical location. Collected: No.

 

  • Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: No.

 

  • Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations. Collected: No.

 

  • Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No.

 

  • Category K: Inferences drawn from other personal information. Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: No.

 

Under CCPA, personal information does not include:

 

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from the CCPA's scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

 

Sources of Personal Information

 

We obtain the categories of personal information listed above from the

following categories of sources:

 

  • Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
  • Indirectly from You. For example, from observing Your activity on our Service.
  • Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
  • From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

 

Use of Personal Information for Business Purposes or Commercial Purposes

 

We may use or disclose personal information We collect for "business purposes"

or "commercial purposes" (as defined under the CCPA), which may include the

following examples:

 

  • To operate our Service and provide You with our Service.
  • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
  • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

 

Please note that the examples provided above are illustrative and not intended

to be exhaustive. For more details on how we use this information, please

refer to the "Use of Your Personal Data" section.

 

If We decide to collect additional categories of personal information or use

the personal information We collected for materially different, unrelated, or

incompatible purposes We will update this Privacy Policy.

 

Disclosure of Personal Information for Business Purposes or Commercial Purposes

 

We may use or disclose and may have used or disclosed in the last twelve (12)

months the following categories of personal information for business or

commercial purposes:

 

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

 

Please note that the categories listed above are those defined in the CCPA.

This does not mean that all examples of that category of personal information

were in fact disclosed, but reflects our good faith belief to the best of our

knowledge that some of that information from the applicable category may be

and may have been disclosed.

 

When We disclose personal information for a business purpose or a commercial

purpose, We enter a contract that describes the purpose and requires the

recipient to both keep that personal information confidential and not use it

for any purpose except performing the contract.

 

Sale of Personal Information

 

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing,

disclosing, disseminating, making available, transferring, or otherwise

communicating orally, in writing, or by electronic or other means, a

consumer's personal information by the business to a third party for valuable

consideration. This means that We may have received some kind of benefit in

return for sharing personal information, but not necessarily a monetary

benefit.

 

Please note that the categories listed below are those defined in the CCPA.

This does not mean that all examples of that category of personal information

were in fact sold, but reflects our good faith belief to the best of our

knowledge that some of that information from the applicable category may be

and may have been shared for value in return.

 

We may sell and may have sold in the last twelve (12) months the following

categories of personal information:

 

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

 

Share of Personal Information

 

We may share Your personal information identified in the above categories with

the following categories of third parties:

 

  • Service Providers
  • Payment processors
  • Our affiliates
  • Our business partners
  • Third party vendors to whom You or Your agents authorize Us to disclose

Your personal information in connection with products or services We

provide to You

 

Sale of Personal Information of Minors Under 16 Years of Age

 

We do not sell the personal information of Consumers We actually know are less

than 16 years of age, unless We receive affirmative authorization (the "right

to opt-in") from either the Consumer who is between 13 and 16 years of age, or

the parent or guardian of a Consumer less than 13 years of age. Consumers who

opt-in to the sale of personal information may opt-out of future sales at any

time. To exercise the right to opt-out, You (or Your authorized

representative) may submit a request to Us by contacting Us.

 

If You have reason to believe that a child under the age of 13 (or 16) has

provided Us with personal information, please contact Us with sufficient

detail to enable Us to delete that information.

 

Your Rights under the CCPA

 

The CCPA provides California residents with specific rights regarding their

personal information. If You are a resident of California, You have the

following rights:

 

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
  • The categories of personal information We collected about You
  • The categories of sources for the personal information We collected about You
  • Our business or commercial purpose for collecting or selling that personal information
  • The categories of third parties with whom We share that personal information
  • The specific pieces of personal information We collected about You
  • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
  • The categories of personal information categories sold
  • The categories of personal information categories disclosed
  • The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
  • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
  • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
    • Denying goods or services to You
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to You
    • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

 

Exercising Your CCPA Data Protection Rights

 

In order to exercise any of Your rights under the CCPA, and if You are a

California resident, You can contact Us:

 

 

  • By mail: 801 Twelve Oaks Center Drive Suite 834 Wayzata MN 55391

 

 

Only You, or a person registered with the California Secretary of State that

You authorize to act on Your behalf, may make a verifiable request related to

Your personal information.

 

Your request to Us must:

 

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

 

We cannot respond to Your request or provide You with the required information

if We cannot:

 

  • Verify Your identity or authority to make the request
  • And confirm that the personal information relates to You

 

We will disclose and deliver the required information free of charge within 45

days of receiving Your verifiable request. The time period to provide the

required information may be extended once by an additional 45 days when

reasonably necessary and with prior notice.

 

Any disclosures We provide will only cover the 12-month period preceding the

verifiable request's receipt.

 

For data portability requests, We will select a format to provide Your

personal information that is readily usable and should allow You to transmit

the information from one entity to another entity without hindrance.

 

Do Not Sell My Personal Information

 

You have the right to opt-out of the sale of Your personal information. Once

We receive and confirm a verifiable consumer request from You, we will stop

selling Your personal information. To exercise Your right to opt-out, please

contact Us.

 

The Service Providers we partner with (for example, our analytics or

advertising partners) may use technology on the Service that sells personal

information as defined by the CCPA law. If you wish to opt out of the use of

Your personal information for interest-based advertising purposes and these

potential sales as defined under CCPA law, you may do so by following the

instructions below.

 

Please note that any opt out is specific to the browser You use. You may need

to opt out on every browser that You use.

 

Website

 

You can opt out of receiving ads that are personalized as served by our

Service Providers by following our instructions presented on the Service:

 

  • The NAI's opt-out platform: http://www.networkadvertising.org/choices/
  • The EDAA's opt-out platform http://www.youronlinechoices.com/
  • The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN 

 

The opt out will place a cookie on Your computer that is unique to the browser

You use to opt out. If you change browsers or delete the cookies saved by your

browser, You will need to opt out again.

 

Mobile Devices

 

Your mobile device may give You the ability to opt out of the use of

information about the apps You use in order to serve You ads that are targeted

to Your interests:

 

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
  • "Limit Ad Tracking" on iOS devices

 

You can also stop the collection of location information from Your mobile

device by changing the preferences on Your mobile device.

 

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

 

 

Our Service does not respond to Do Not Track signals.

 

However, some third party websites do keep track of Your browsing activities.

If You are visiting such websites, You can set Your preferences in Your web

browser to inform websites that You do not want to be tracked. You can enable

or disable DNT by visiting the preferences or settings page of Your web

browser.

 

Children's Privacy

 

The Service may contain content appropriate for children under the age of 13.

As a parent, you should know that through the Service children under the age

of 13 may participate in activities that involve the collection or use of

personal information. We use reasonable efforts to ensure that before we

collect any personal information from a child, the child's parent receives

notice of and consents to our personal information practices.

 

We also may limit how We collect, use, and store some of the information of

Users between 13 and 18 years old. In some cases, this means We will be unable

to provide certain functionality of the Service to these Users. If We need to

rely on consent as a legal basis for processing Your information and Your

country requires consent from a parent, We may require Your parent's consent

before We collect and use that information.

 

We may ask a User to verify its date of birth before collecting any personal

information from them. If the User is under the age of 13, the Service will be

either blocked or redirected to a parental consent process.

 

Information Collected from Children Under the Age of 13

 

The Company may collect and store persistent identifiers such as cookies or IP

addresses from Children without parental consent for the purpose of supporting

the internal operation of the Service.

 

We may collect and store other personal information about children if this

information is submitted by a child with prior parent consent or by the parent

or guardian of the child.

 

The Company may collect and store the following types of personal information

about a child when submitted by a child with prior parental consent or by the

parent or guardian of the child:

 

  • First and/or last name
  • Date of birth
  • Gender
  • Grade level
  • Email address
  • Telephone number
  • Parent's or guardian's name
  • Parent's or guardian's email address

 

For further details on the information We might collect, You can refer to the

"Types of Data Collected" section of this Privacy Policy. We follow our

standard Privacy Policy for the disclosure of personal information collected

from and about children.

 

Parental Access

 

A parent who has already given the Company permission to collect and use his

child personal information can, at any time:

 

  • Review, correct or delete the child's personal information
  • Discontinue further collection or use of the child's personal information

 

To make such a request, You can write to Us using the contact information

provided in this Privacy Policy.

 

Your California Privacy Rights (California's Shine the Light law)

 

Under California Civil Code Section 1798 (California's Shine the Light law),

California residents with an established business relationship with us can

request information once a year about sharing their Personal Data with third

parties for the third parties' direct marketing purposes.

 

If you'd like to request more information under the California Shine the Light

law, and if You are a California resident, You can contact Us using the

contact information provided below.

 

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

 

California Business and Professions Code Section 22581 allows California

residents under the age of 18 who are registered users of online sites,

services or applications to request and obtain removal of content or

information they have publicly posted.

 

To request removal of such data, and if You are a California resident, You can

contact Us using the contact information provided below, and include the email

address associated with Your account.

 

Be aware that Your request does not guarantee complete or comprehensive

removal of content or information posted online and that the law may not

permit or require removal in certain circumstances.

 

Links to Other Websites

 

Our Service may contain links to other websites that are not operated by Us.

If You click on a third party link, You will be directed to that third party's

site. We strongly advise You to review the Privacy Policy of every site You

visit.

 

We have no control over and assume no responsibility for the content, privacy

policies or practices of any third party sites or services.

 

Changes to this Privacy Policy

 

We may update Our Privacy Policy from time to time. We will notify You of any

changes by posting the new Privacy Policy on this page.

 

We will let You know via email and/or a prominent notice on Our Service, prior

to the change becoming effective and update the "Last updated" date at the top

of this Privacy Policy.

 

You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this

page.

 

Contact Us

 

If you have any questions about this Privacy Policy, You can contact us:

 

 

  • By mail: 801 Twelve Oaks Center Drive Suite 834 Wayzata MN 55391