- What information we collect;
- With whom it is shared;
- How it can be corrected;
- How it is secured;
- How policy changes will be communicated; and
- How to address concerns over misuse of personal and company data.
Cross Border Data Transfers
Information Collection, Sharing and Use
We collect personal information when communicating or interacting with you. Personal information is any information that we can use to identify, locate or contact you. Some examples of personal information we collect include:
- Registering for an account on our website;
- Subscribing to any communications from us or managing your preferences with us;
- Your Financial Account numbers when transacting with us, including donating to SOS;
- Interacting with our Website, other Services;
- Transaction information about how you interact with us such as account information, computer and mobile device information and push notification services you request;
- Device Information: such as your IP address and an anonymous device identifier. In addition, the Services collects certain information automatically, such as content viewed, and information that allows us to periodically determine mobile device and usage information, which may include (i) information about the way you use the Website, (ii) information specific to your mobile device (such as make, model, operating system and version, Internet browser, device IP address, cookies, anonymous device and/or advertising identifier and similar information), (iii) information about your use of features, functions, or notifications on the device, and (iv) signal strength relating to WiFi or Bluetooth functionality, temperature, battery level, and similar technical data. We may collect the foregoing information even if you are not logged in to the Website;
- Browser Information: such as information automatically provided by browsers like user agent and IP addresses accessing the Website;
- Through communications with you;
- Contacting us with a comment, question or dispute;
We are the sole owners of the information collected on this site. We only have access to or collect information that you voluntarily give us via the Website or other direct contact from you. We may share the information we collect as stated herein, and/or in the following instances:
- we have been given your consent to disclose;
- we are required by law, legal process, or court order to disclose;
- disclosure is necessary to identify, contact, or bring legal action against someone who may cause or be causing harm to, or interference with, our rights or property, our Website users, or anyone else; or
- to respond to an inquiry, request or complaint that you have made.
We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request. Such information may be used to facilitate transactions among our accounts, users, SOS, and third parties. As such, this information may be shared and used by all such parties to the extent we desire or otherwise allow such information to be shared. You are hereby accepting and agreeing to such use and sharing of information. Information about your use of the Services may also be used for the following purposes:
- to provide, improve and create new Services;
- to screen orders for potential risk or fraud;
- to improve and optimize the Website;
- to provide you with targeted advertisements or marketing communication we believe may be of interest to you.
- to respond to your inquiries and to send you administrative communications about the Website and Services;
- to obtain your feedback about the Website and Services;
- to send you secure electronic messages and personalized emails pertaining to your interests as inferred from your use of the Services, including news, announcements, reminders and opportunities from SOS;
- to statistically analyze trends and user behavior and activity including how frequently areas of the Website are visited, how the Services are being used and how many emails are received and opened;
- to provide you and people with similar demographic characteristics and interests with more relevant content including advertising both on and of the Website;
- to offer lead generation services;
- to detect and defend against fraud and other threats to the Services and our users,
- to identify issues with the Services;
- to conduct research and measurement activities, including those described below; and
- to administer your account.
Our Websites and Services may ask you to submit User Information, as well as other information about other people and/or their affiliated companies. Such information may be used to facilitate transactions among our Users, SOS, and third parties. As such, such information may be shared and used by all such parties. You are hereby accepting and agreeing to such use and sharing of information.
Your Access to and Control Over Information
You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address at firstname.lastname@example.org.
- See what data we have about you, if any.
- Change/correct any data we have about you.
- Have us delete any data we have about you.
- Express any concern you have about our use of your data
E-mail Newsletter Subscriptions
You may agree to be subscribed to our e-mail newsletters, if any. You may also be asked for other information at the same or later time. We do not use your email address or other User Information to send marketing messages unless you’ve opted in to receive such messages.
Sharing and Disclosure
When you visit and utilize the different functions of our Website, our web servers may automatically collect website usage information. Website usage information is non-User Information that describes how our visitors utilize the Website. Information collected includes, but is not limited to, the number and frequency of visitors each web page and the length of their stays, browser type, referrer data that identifies the web page visited prior and subsequent to visit the Website, and IP addresses. SOS may use IP addresses for a number of purposes, such as system administration, to determine your computer’s server location, to report aggregate information to our business partners or to audit use of the Website.
SOS may share your information with our affiliates. SOS may also work with third parties to provide some Services on our Website. For example, we may use Google Analytics to help us understand how our customers use the Website (for information about how Google uses your personal information go to https://www.google.com/intl/en/policies/privacy/). SOS may also work with third parties to provide some Services on our Website. In connection with those Services, you are deemed to consent to us sharing User Information with third parties who provide services including, but not limited to, credit card processing, customer service, promotions, and order fulfillment. These third parties do not have any right to use User Information or information shared with them beyond what is necessary to assist in providing the Services. You consent to our sharing of User Information with these third parties. We will use commercially reasonable efforts to prevent such third parties from disclosing User Information, except for providing such Services. We cannot guarantee that these third parties will not disclose our User Information and will not be liable for any unauthorized use or disclosure by any third party.
From time to time, SOS may use and share with third parties aggregate, non-personally identifiable User Information to show demographic and preference information among users of SOS websites. For example, SOS may produce and share with others “trend reports” using such aggregate, non-personally identifiable User Information, generated based on information gathered on Users from order information (i.e. products purchased, amount spent, type of product, addresses to be shipped to, etc.), retailer information related to purchases (i.e. type of retailer and their buying habits) and brand information (i.e. type of product a brand showcases).
SOS will share information in order to comply with state and federal law. We will share information to respond to a court order or subpoena, or to establish or exercise our legal rights or defend against legal claims. We may also share it if a government agency or investigatory body requests. We may also share information to protect us, or our site, or our users. We might share information with other companies for fraud and credit risk reduction.
SOS will share information to any successor to all or part of our business whether SOS is acquired by or merged with another company. For example, if part of our business was sold we may sell our customer list as part of that transaction. In the event that SOS is acquired by or merged with a third party, we reserve the right to transfer or assign the information collected from our Users as part of such transaction. We may not control how our User Information is handled in the event of a bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of law when applied to creditor rights.
We take precautions to protect your information. When you submit sensitive information via the Website, your information is protected both online and offline.
Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (e.g. billing or customer service) are granted access to personally identifiable information. The computers/servers on which we store User Information are kept in a secure environment.
All of that being stated, the internet is not 100% secure. SOS cannot promise that your information will be completely safe. Please use caution when using the Internet or providing personal and company information to others.
If SOS learns of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps, or alternatively, we may post a notice of such security breach on our Website. Please contact us if you would like to receive a written notice of a security breach.
Cookies and Related Technologies
SOS receives and records certain technical information from your browser in order to operate its Services. We may use certain tools to view statistics about usage of our Services.
We may also collect information through web beacons; tags; pixels which are blocks of code that can read and place cookies, recognize certain types of information on your device, such as which websites or apps you use, and your browsing behavior, as well as provide Service analytics.
Mobile device identifiers also collect information and these are standard device identifiers, for example the “IDFA” advertising identifier used on Apple’s iOS devices and the “Google Advertising ID” advertising identifier used on Android devices, to analyze your use of mobile applications.
Links to Third-Party Websites
The Website may contain links to other sites. Please be aware that SOS is not responsible for the content or privacy practices of such other sites. We encourage users to be aware when they leave the Website and to read the privacy statements of any other site that collects user information.
Children and Minors
The Website is not intended for children under 18. In some cases, children may give us information without us knowing about it. If you are a parent or legal guardian and believe that your child under 18 has provided us with personally identifiable information, please email SOS at email@example.com. SOS is committed to complying with all applicable laws and regulations regarding children, including the Children’s Online Privacy Protection Act.
From time-to-time our site may request information via surveys. Participation in these surveys is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level). Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.
We respect your need to be able to access and update the personal information that you have provided to us. If you have registered online, you may access and update your personal information at any time by logging into your account. You may also request access and update your personal information by email or writing to SOS at the contact information set out above (subject to certain exceptions and as prescribed by law). We may request certain personal information to verify the identity of the individual seeking access to their personal information records.
California Privacy Rights
FOR CALIFORNIA RESIDENTS ONLY. California law entitles residents to certain rights with respect to your personal information, including to ask us for a notice describing what categories of personal information we share with third parties or with corporate affiliates for those entities direct marketing purposes. SOS does not provide any personal information to third parties for their own direct marketing purposes. If you want to request a notice or have any questions about SOS privacy practices, please contact us at firstname.lastname@example.org. You may make a request to access our personal information up to two times in a 12-month period, subject to the limitations described in the California Privacy Rights Act (https://oag.ca.gov/privacy/ccpa). For a list of general categories of information see “Information Collection, Sharing and Use” above. You may request that we correct any inaccurate information we have about you. You may also request that we delete any personal information that we have collected from you. However, it may be necessary for us to retain certain information which the law exempts from deletion when it is necessary for us to:
- Complete a transaction, provide goods or services, or otherwise perform an agreement we have with you;
- When necessary to ensure security and prevent fraud;
- Debug to identify and repair errors;
- Ensure the exercise of free speech or another right provided by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in scientific, historical, or statistical research (subject to your consent);
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship us, the Website and the Services; or
- Comply with a legal obligation.
If you are a California resident, you have the right to opt out of the “sale” of your personal information to “third parties.” We do not sell personal information to third parties but we do transfer certain personal information to third parties in order to provide the Services through the Website which the law permits. You may also designate an authorized representative to make data subject rights requests on your behalf. Unless the law requires otherwise, your authorized representative must provide contact details for you so that we can verify that you did in fact authorize the representative. Upon such confirmation, we will promptly respond to the rights request. You have the right to be free from discrimination for exercising any rights under law. We will not deny you goods or services, charge you different rates, or give you different discounts because you used one of these rights.
Legal Basis for Processing Information (EEA users only)
If you a user located in the European Economic Area, our legal basis for collecting and using the information described above depends on the type of information concerned and the specific context in which we collect it.
We may rely on our legitimate interest to collect information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to collect and process information about you, they include the interests described herein.
However, in some cases, we may rely on your consent or have a legal obligation to collect the information from you, or may otherwise need the information to protect your and/or our vital interests or those of another person or entity. If we rely on your consent to collect and/or process information about you, we will obtain such consent in compliance with applicable laws.
If you have questions about or want further information concerning the legal basis on which we collect and use information about you, please contact us at email@example.com.
European Data Subject Rights
If you are a resident of a country in the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the collection, processing, and use of information about you. As set forth above, the information that we collect about you when you use the Service may include certain digital identifiers that are considered “personal data” under European law. We process this data either as it is necessary to further our legitimate interest and/or pursuant to your consent.
As a resident of a country in the EEA, you have the right to: (i) request access and obtain a copy of the information we collect about you; (ii) request rectification or erasure; (iii) restrict the processing of such information; (iv) withdraw consent previously provided; and (iv) if applicable, data portability. In certain circumstances, you may also have the right to object to the processing of such information.
If you would like to exercise any of these rights, please contact us at firstname.lastname@example.org. Please note that because most of the information we collect and maintain about you can only identify a particular browser or device, and cannot identify you individually, you may need to provide us with additional information to enable us to identify the information we have about you and ensure that we accurately fulfill your request. Although we use good faith efforts to respond to your request, we may not be able to provide and/or correct the requested information in all situations. For example, we may not be able to provide the information requested if it imposes an undue burden or expense, requires us to release confidential commercial information, or requires the disclosure of information relating to another person.
Finally, as a resident of the EEA, you have the right to lodge a complaint about our processing of personal data with a European Data Protection Authority. For contact details of your relevant local Data Protection Authority, please see here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
Retention of Information
We do not store information longer than we need it. [The cookies we set expire no later than 30 days after they were last accessed.] We typically store the information collected, such as IP address and other information described above until the next login. When we no longer need the information collected, it is deleted from either the cookies or our servers (as applicable).
In some cases, we may keep some information for longer periods of time where required under certain laws or to comply with law enforcement or regulatory requests, which for example may include, those relating to corporate governance, taxation, money laundering and financial reporting legislation.
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