Privacy Policy

Privacy Policy

Last Updated date: January 24, 2024

Gear Patrol, LLC ("we," "us" or "our") respects your privacy when you interact with our publication services, including our websites at GearPatrol.com and DPReview.com and our Gear Patrol and DPReview newsletters (collectively, our “Services”). This privacy policy (“Privacy Policy”) explains how we collect, process, store and share personal information in connection with our Services and the operation of our company. If you are an individual, this Privacy Policy also provides you with important information about your personal information rights with respect to personal information that we control and how to exercise them. 

By using our Services or otherwise providing personal information to us, you acknowledge that you have read, understand and accept our privacy practices and policies outlined below, and you consent that we may collect, process, store and share personal information as described in this Privacy Policy, subject to the exercise of individual rights as explained in this Privacy Policy.

1. Notice at Collection of Personal Information 

Definition of Personal Information

We collect, process, store and share information that identifies, relates to or could reasonably be linked, directly or indirectly, with a particular individual or household (“personal information”). Personal information does not include information publicly available from government records, or which is not personal, like anonymous, deidentified or aggregated data (even if it originally comes from personal information).

Categories of Personal Information We Collect

Depending on your relationship with us, we may collect, process and store, and share with third parties, the following categories of personal information: 

  • Contact information, such as full name, home or work address, email address and phone number
  • Demographic and biographic information, including:  
    • characteristics, such as age, gender or racial or ethnic origin 
    • descriptions of yourself and your physical attributes and photographs 
    • professional information, such as your profession, employer, job title and bio 
    • educational information, such as your educational background
    • your website 
  • Identification information, such as your driver’s license number, social security number or signature 
  • Account credentials, such as username and password 
  • Payment information, such as credit card information
  • Commercial information, such as products or services you considered or purchased, or other of your purchasing histories or tendencies
  • Internet and device information (including identifiers, activity and analytics), which may be collected by us or third parties and/or automatically through cookies, including:
    • the internet protocol (IP) address used to connect your computer to the internet
    • the location of your device or computer
    • information about your computer, device, browser and operating system (such as type, model or version)
    • device identifiers (such as mobile advertising IDs)
    • device metrics such as when a device is in use, application usage, connectivity data and any errors or event failures
    • your activities over time across the Services, as well as across third-party sites, apps or other media
    • your interactions with the features and content of the Services and third-party sites or services, including browsing activities and clickstream data that reflect the content you have accessed, clicked on, or viewed 
    • information about how you accessed the Services, including details about websites or apps visited immediately before or after accessing the Services, such as the full Uniform Resource Locator (URL) clickstream to, through and from our Services and date and time
    • service metrics, such as the occurrences of technical errors and your settings preferences
    • your interactions with email messages, newsletters and other communications, such as whether you opened or forwarded the email or clicked on links contained in the email
    • information about uploaded images and files such as the file name of your images
    • page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs)
    • playback details and network details for streaming quality, including information about your internet service provider
    • version and time zone settings
    • purchase and content use history
    • demographic, interests and household information
  • Approximate geolocation when you are using our Services
    • to prevent the collection of precise location information, please refer to instructions provided by your mobile service provider or device manufacturer
  • Preference information, including preferences related to marketing, privacy or communications 
  • Inferences drawn from any of the personal information listed in this section; for example, to create a profile of an individual’s preferences, interests and characteristics
  • Other information you choose to provide to us, including:
    • comments, reviews, posts to on-site forums or social media, and e-mails to us
    • photos, image, videos and other content uploaded to or shared via the Services 
    • press interviews and media articles
    • information you provide when you choose to participate in surveys, polls, sweepstakes, giveaways, contests or promotions (including information about your participation in activities that may generate loyalty or rewards points)
    • information you may allow us to access through your device’s permissions settings, such as your contacts or address book

Our Business Purposes for Collecting and Sharing Personal Information

We collect, process, store and/or share all of the categories of personal information identified above (unless a limited subset of categories is indicated) for our following business purposes, our legitimate interests and the legitimate interests of third parties to:

  • Provide our Services, including:
    • providing our websites and newsletters
    • processing your requests or your participation in a survey, giveaway, sweepstakes, contest, promotion, event or similar initiative 
    • processing your payments 
    • providing customer assistance or technical support
    • customizing content, providing recommendations and enhancing the quality and your overall experience with the Services, including by retaining your user preferences or presenting content in the most effective manner for the browser or device you use to access the Services
  • Protect, maintain and improve our Services, including:
    • troubleshooting, testing, conducting data analysis, making updates, and detecting and preventing fraud (including through identity verification)
    • learning about users of the Services and analyzing how you and others interact with and respond to the Services, such as by conducting market research, analyzing trends and activities 
    • improving our Services and developing new services, products, features or content, including through measuring and optimizing user interaction with the Services and the reliability and performance of the Services 
    • contacting you to ask for your views on our Services and notifying you about important changes or developments
  • Market and advertise our and third-party products and services to you, including through targeted advertising. We collect, use and share personal information (except for identification information, account credentials and payment information) to market and advertise to you, including:
    • developing, managing and conducting advertising and marketing campaigns, promotions and offers, including about our content, products and services or third parties’ products, services and other initiatives
    • delivering “targeted advertising” (also known as cross-context behavioral advertising), which means advertising based on your interests based on your activities over time on the Services and online services operated by third parties, as well as information from other sources, including information collected offline; for more information, see the below section called, Our Participation in Targeted Advertising 
    • recommending features, content, products, and services that might be of interest to you
    • identifying your preferences and personalizing your experience, including through “profiling” – meaning the automatic processing of your personal information to identify your preferences and interests  
    • inviting you to participate in surveys, giveaways, sweepstakes, competitions and similar promotions
    • analyzing and measuring the performance, effectiveness and reach of our and third-party advertising (including interest-based ads) and marketing efforts on the Services and elsewhere
  • Support our business operations, including website hosting, payment processing, email delivery, text messaging services and customer service, as well as for accounting, tax, auditing, financial and legal purposes 
  • Aggregate personal information, including aggregating, anonymizing and deidentifying personal information so that it is no longer personal information 
  • Meet legal and compliance requirements, including:
    • performing audits, monitoring and reporting
    • supporting information security and anti-fraud operations
    • investigating and responding to disputes and exercising and defend legal claims
    • protecting the rights, property or safety of you, other users, us or a third party or acting in the overriding public interest as permitted by law
    • responding to legal process (including subpoenas) and governmental, court or law enforcement requests, investigations or orders
    • complying with and enforcing applicable laws, regulations, policies, procedures and agreements  
  • Evaluate or conduct business changes, including a merger, acquisition, sale, equity or debt financing, reorganization, dissolution, bankruptcy, or other transaction in which a third party invests in, finances or acquires control of our business or assets (in whole or in part), or any similar corporate event to any of the foregoing

Although we engage in profiling for marketing and targeted advertising purposes, we do not share your personal information for the purposes of making automated decisions that produce legal or similarly significant effects concerning you.

Under the laws of some jurisdictions, we must be able to describe the legal bases on which we rely to process personal information. We primarily rely on the legitimate interests, described above, to process personal information when not overridden by an individual’s data protection interests or fundamental rights and freedoms. Other legal bases for our processing of personal information include when the processing is necessary to perform a contract with you, we have a legal obligation to process the personal information or we have your consent to process the personal information.

Categories of Third Parties With Whom We Share Your Personal Information

We share personal information with the following categories of third parties: 

  • Our affiliates (“Affiliates”) for purposes consistent with this Privacy Policy, including to support marketing, sale and delivery of our Services    
  • Our vendors (“Vendors”) who provide us with services and products that help us provide the Services or operate our business but only to the extent needed to enable them to provide such services or products, including customer service, payment card processing, email distribution, list processing, postal mailing, analytics, digital content performance measurement, ad serving and management of sweepstakes, contests, promotions or events; data storage, hosting, technology and communication providers; cyber security, disaster recovery services and other security providers; and our attorneys, advisors, auditors and accountants 
  • Advertisers, Social Media Platforms and Advertising- and Marketing-Related Service Providers and Partners (“Advertising Providers”), including:
    • advertisers, advertising agencies, ad networks, ad exchanges, marketing businesses, technology vendors and other entities that create, deliver and assess advertising or marketing campaigns, including targeted ads
    • joint marketing partners and content sponsors
    • content measurement companies, who measure content across the internet including the Services
    • social media platforms, including if you interact with social media widgets, share content using social media share buttons, or access features of the Services that contain content or features provided by social media platforms, the relevant social media platforms may collect information
  • Parties you access, authorize or authenticate (“Authorized Parties”), including third parties you access through the services, such as identity verification providers and payment processors; information provided to such third parties are subject to such third parties’ privacy policies; please consult the applicable third party’s privacy policy for more information on how the third party uses your personal information  
  • Parties for legal purposes (“Legal Parties”), including governmental authorities, law enforcement, courts or other third parties in connection with any of the activities set forth in the bullet beginning with "Meet legal and compliance requirements” in the section above called, Our Business Purposes for Collecting and Sharing Personal Information
  • Parties for business changes (“Transaction Parties”), for example, personal information that we collect may be shared with or transferred to a third party if we consider or undergo a merger, acquisition, sale, equity or debt financing, reorganization, dissolution, bankruptcy, or other transaction in which a third party invests in, finances or acquires control of our business or assets (in whole or in part), or any similar corporate event to any of the foregoing

Notice of Right to Opt-Out of Sale/Sharing  

We use your personal information to deliver the Services to you and customize your experience. We may share the personal information that we collect for cross-context behavioral advertising or targeted advertising (except for identification information, account credentials and payment information). Depending on laws that may be applicable to you, when we share your personal information, it may constitute a "sale" of your personal information (for example, when we share your personal information in exchange for money or other valuable consideration).

You may choose to opt-out of our sale of your personal information and sharing of your personal information for cross-contextual behavioral advertising and targeted advertising by visiting:

Retention of Personal Information

We retain personal information for as long as we deem to be necessary or advisable for our business purposes described in the above section called, Our Business Purposes for Collecting and Sharing Personal Information (such as providing Services to you). This may include keeping your personal information after you have stopped using our Services; for example, we may retain your personal information to market our products and services to you (unless you opt-out), comply with legal obligations, resolve disputes or collect fees owed. We may retain your personal information longer pursuant to a specific legal reason or requirement. When our retention period ends, we may either delete your personal information or retain it in a form such that it does not identify you personally.

2. Applicability of this Privacy Policy 

This Privacy Policy covers how we treat personal information that we acquire from or about you in connection with our Services or our other business. This Privacy Policy does not apply to information that we collect in connection with your employment or application for employment with us. 

Sources of Personal Information

We collect personal information from the following categories of sources:

  • Directly from you, such as when you register on our websites, sign up to receive our newsletters, sign up to receive product information or contact us via our websites, or when you otherwise communicate or interact with us in any way, including via mail, email, phone, chat, browser form, online request form, QR code or social media
  • Indirectly from you, for example, we collect cookie data and other information from your device, browser or activity in our Services 
  • From third parties or public sources, for example, from Advertising Providers, including analytics providers and social media platforms 

Generally, you are not under a statutory or contractual obligation to provide personal information to us. However, if you do not provide the personal information required for us to provide certain services, verify your identity or process transactions, we may be unable to offer certain services or otherwise conduct business with you.

Third-Party Links

Our Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not endorse or control these third-party websites or applications and are not responsible for their privacy practices or any information on their websites or in their applications. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

Personal Information of Others You Share with Us

You may not disclose the personal information of another individual to us unless you have their prior written consent or are otherwise authorized under applicable law to share their information with us. To the extent that you provide another individual’s personal information to us or we collect another individual’s personal information on your behalf, you acknowledge and agree that you are responsible for compliance with all applicable laws concerning such personal information, including: 

  • providing all applicable notices 
  • receiving the proper authority or consent to allow us to collect, store, process and share such personal information 
  • responding to data subject requests

Aggregated Data

We may anonymize, deidentify and/or aggregate data so that it no longer constitutes personal information.  Anonymized or deidentified data is not personal information and restrictions on our use of personal information contained in this Privacy Policy do not apply to such anonymized or deidentified data even if such data was created or derived from personal information. We may share anonymized, deidentified and/or aggregated data that does not identify you personally with third parties, including our Affiliates, Vendors and Advertising Providers. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes. We may disclose non-personal information to any third party for any reason in our sole discretion.

Personal Information of Children

The Services are not intended for use by children under the age of 16. If you are a child under the age of 16, please do not attempt to use our websites or other Services or send us any personal information. We do not collect any personal information directly from children under 16 years of age. As a parent or guardian, you may provide or make available personal information of your children to us, and, by doing so, you agree and consent to our collection and use of your children’s personal information.

To our knowledge, we do not sell, or share for cross-context behavioral advertising or targeted advertising purposes, the personal information of children under the age of 16. 

3. Your Privacy Rights and Choices  

Notice of Your Personal Information Rights

With respect to personal information that we control, subject to exemptions and limitations provided by applicable law, if you are an individual you have the right to: 

  1. Know or access – request that we disclose certain information to you about our collection and use of your personal information: Whether or not we are processing your personal information 
    • The categories of your personal information we have collected
    • The categories of sources from which your personal information was collected 
    • Our business purposes for collecting, selling or sharing that personal information
    • The categories of third parties with whom we disclosed your personal information, identifying the personal information categories that each category of recipient obtained and the purposes for sharing your personal information
    • The types of personal information we shared with third parties for third parties’ direct marketing purposes and the identities of such third parties
    • The specific pieces of personal information we collected about you and access to that personal information  
  2. Data portability – request a copy of the personal information you provided to us in a portable, and, if feasible, readily usable format to be transferred to you or a third party 
  3. Deletion – request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions under applicable privacy law 
  4. Correction – request that we correct inaccurate or complete incomplete personal information 
  5. Limit use of sensitive information – request that we limit the use or disclosure of your sensitive personal information to just those actions necessary to perform specific purposes outlined by law
  6. Sale opt out – direct us to not sell your personal information at any time
  7. Sharing for behavioral advertising opt out – direct us to not share your personal information for cross-context behavioral advertising or targeted advertising
  8. Third-party marketing opt out – direct us to not share your personal information with third parties for third parties’ direct marketing purposes
  9. Object to processing – object to our processing of your personal information based on legitimate interests or for direct marketing purposes
  10. Restriction of processing – request that we restrict or suspend the processing of your personal information  in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to delete it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
  11. Withdraw your consent to the processing of your personal information if our processing is based on your consent (without affecting the lawfulness of any processing prior to your withdrawal of consent) 
  12. Non-discrimination – be free from unlawful discrimination for exercising your rights under applicable privacy law 

How to Exercise Your Personal Information Rights 

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a written request (via the methods described below) that (1) provides sufficient information to identify the individual about whom we have collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” 

We may ask for information to verify your identity and process your Valid Request, such as name, phone number, email and address. For a request to opt out of sale or behavioral advertising, we do not require a verifiable request.  If applicable, we recommend that you submit the email that you used when you registered with the Services. 

We will work to respond to your Valid Request promptly within the timeframes required by applicable privacy law (usually between 15 to 45 days depending on the type of Valid Request, with the right for us to extend the response time as necessary). We will not charge you a fee for making a Valid Request unless your Valid Request is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods (depending on the type of Valid Request): 

Send an email to: privacy@gearpatrol.com (all requests except opt out of sharing for behavioral advertising)

You may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. 

In some instances, we may not be able to honor your request. For example, we may not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. We may not honor your request if we are not the controller of your personal information. Additionally, we may not honor your request where not required to do so under applicable privacy laws. For example, we may deny a deletion request if the information is necessary for us to provide our Services to you or comply with our legal obligations. We may deny certain right to know requests made more than twice in a 12-month period or for information collected and disclosed more than 12 months ago. We will advise you in our response if we are not able to honor your request.  

You have the right to appeal our decision to not honor your request or our refusal to take action on a request within a reasonable period of time by contacting us at the email listed above and clearly stating that the purpose of the contact is an “appeal of privacy rights.”   Within 45 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. 

The Right to Lodge a Complaint with a Supervisory Authority 

Subject to applicable privacy law, should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to lodge a complaint with your local data protection authority and/or competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the European Economic Area, you may find the contact details for your appropriate data protection authority on this website: https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you are a resident of the United Kingdom you may contact the UK supervisory authority, the Information Commissioner’s Office here: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/. 

4. Our Use of Cookies and Other Monitoring Technology

Our Use of Cookies  

Our Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “cookies”). Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our or third-party websites.  We use cookies to recognize your browser or device, learn more about your interests, provide you with essential features and services and for additional purposes, including:

  • Recognizing you when you sign-in to our Services
  • Keeping track of your specified preferences, as well as your activities and interests 
  • Delivering content, including targeted ads
  • Measuring and analyzing the performance of our Services
  • Conducting research and diagnostics to improve our content and Services
  • Preventing fraudulent activity
  • Improving security

Approved third parties may also set cookies when you interact with Services. Third parties include providers of measurement and analytics services, social media networks, and Advertising Providers. Third parties use cookies in the process of delivering content, including ads relevant to your interests (including targeted ads), to measure the effectiveness of their ads, and to perform services on our behalf. We and our approved third parties may use first-party cookies (like analytics cookies) and third-party cookies (like advertising cookies) together to serve you with ads, including targeted ads. Please review such third parties’ privacy policies and other terms for information on their privacy practices and uses of personal information, including whether they use cookies to provide targeted and cross-context behavioral advertising and your options to opt out.

Monitoring and Recording Keystrokes and Other Communication

We use cookies and other tracking technology to monitor and record keystrokes and other communications made through the Services, including email, phone, text message and webchat. This includes monitoring your keystrokes while you are using the Services. You consent to us monitoring and recording all of your communications made through the Services and to us using and sharing such recordings for all purposes described in this Privacy Policy. 

More Details About Cookies and Setting Your Cookies Preferences

For more information about the cookies on this website, including third-party cookies, and to set your preferences for certain types of cookies, please visit: 

Do Not Track

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Our websites are configured to respond to Do Not Track signals.

Disable or Delete Cookies

Set Your Cookie Preferences 

You can disable certain cookies on this website by clicking the Cookie Preferences links:  

Disable or Delete Cookies from Your Browser or Device 

You can also decide whether or not to accept certain cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. To explore what cookie settings are available to you, look in the “preferences” “options” or “help” section of your browser's menu. 

You can also delete all cookies that are already on your device. If you delete or block all cookies, however, you may have to manually adjust some preferences every time you visit our Services and some of the Services and functionalities may not work. 

To find out more information about cookies, including information about how to manage and delete cookies, please visit http://www.allaboutcookies.org/. 

5. Our Participation in Targeted Advertising

Targeted Advertising by Us and Third Parties 

Targeted advertising (also known as cross-context behavioral advertising) is advertising based on your interests in topics and content based on your activities over time on the Services and online services operated by third parties, as well as information from other sources, including information collected offline.  

Targeted ads may consist of text ads, images, animations or videos and may be displayed to you based on various factors, including the context of the site or app in which they appear (such as, sport or travel section), information you provided to the operator of the site or app (such as when you created an account), your activities on the site or app (such as, pages viewed, searches performed or ads clicked), and information such as your demographic, interests and household information.

To serve you targeted ads, we use information such as your interactions with the Services or other content. We work with third parties, such as advertisers, publishers, social media networks, search engines, ad serving companies, and advertising companies working on their behalf, to improve the relevance of ads we and third parties serve to you.  

On the Services and on third-party sites, apps or other media, we, our service providers and third parties may use automated means to collect information for targeted advertising purposes and/or serve you targeted ads. These automated means vary depending on the Services and include technologies such as cookies. These technologies may use unique identifiers associated with your browser or device to support targeted advertising.

We may use and/or combine online and offline information we obtain about you, including your personal information, for targeted advertising purposes. We may aggregate the information we obtain to create audiences that are most likely to respond to ads based on demographic, interests or household information.

Targeted ads may be displayed to you by us or by third parties, such as ad networks or exchanges.

If you access the Services from multiple browsers or devices, we, our service providers and third parties may try to establish connections among and link the different browsers and devices you use to access the Services and our content or ads published elsewhere. This helps us provide you with a seamless experience across the browsers and devices you use and serve you with more relevant content and ads (for example, so that we don’t show you the same article twice). 

Targeted Advertising Preferences  

We offer you choices about receiving targeted ads. If you choose not to receive targeted ads, you will still see ads in the Services but they will not be based on your interests. Please visit the following pages to learn how to set your targeted advertising preferences:

You can also generally opt out of receiving targeted ads from third party advertisers and ad networks who are members of the Network Advertising Initiative or who follow the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising by visiting the Network Advertising Initiative at http://www.networkadvertising.org/choices or the Digital Advertising Alliance at https://www.aboutads.info/choices. 

6. Our Uses of Personal Information in the Last 12 Months

The below chart summarizes the categories of personal information we have collected, disclosed for our business purposes, sold or shared for cross-context behavioral advertising (or targeted advertising) to the identified categories of third parties in the last 12 months.  See the above section called, Categories of Third Parties with Whom We Share Your Personal Information, for more details on the categories of third parties.

Our business purposes for disclosing your personal information are all of the business purposes in the above section called, Our Business Purposes for Collecting and Disclosing Personal Information. Our business purposes for selling your personal information or sharing your personal information for cross-context behavioral adverting or targeted advertising are those purposes identified in the bullet beginning with "Market and advertise our and third-party products and services to you, including through targeted advertising,” in the above section called, Our Business Purposes for Collecting and Disclosing Personal Information.

Category of Personal Information Collected in Last 12 Months Disclosed for Our Business Purposes in Last 12 Months to Categories of Third Parties  Sold or Shared for Cross-Context Behavioral Advertising in Last 12 Months to Categories of Third Parties 
Identifiers (for example, name, postal address, email address, IP address, unique personal identifiers)  Yes Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties Yes to our Affiliates, Vendors and Advertising Providers 
Personal information (for example, name, address, telephone number, credit card number) Yes Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties Yes to our Affiliates, Vendors and Advertising Providers
Characteristics of protected persons (for example, age, race, national origin, citizenship, religion, sex/gender) Yes Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties Yes to our Affiliates, Vendors and Advertising Providers
Commercial information (for example, records of products or services purchased or considered) Yes Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties Yes to our Affiliates, Vendors and Advertising Providers
Biometric information (for example, fingerprints and voiceprints)  No* Not applicable Not applicable 
Internet or other electronic network activity (for example, browsing history, search history, website interactions) Yes Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties Yes to our Affiliates, Vendors and Advertising Providers
Geolocation data (for example, device location)  Yes Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties Yes to our Affiliates, Vendors and Advertising Providers 
Sensory data (audio, electronic, visual, thermal, olfactory, or similar information) No* Not applicable Not applicable
Professional or employment-related information  Yes Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties Yes to our Affiliates, Vendors and Advertising Providers
Non-public education information No* Not applicable Not applicable
Inferences drawn from other personal data to create a consumer profile  Yes Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties Yes to our Affiliates, Vendors and Advertising Providers
Other non-sensitive information you choose to provide (for example, you may choose to provide information in any of the above categories even if we do not specifically collect it) Yes Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties No
Sensitive Personal Information 
Category of Sensitive Personal Information Collected in Last 12 Months Disclosed for Our Business Purposes in Last 12 Months to Categories of Third Parties  Sold or Shared for Cross-Context Behavioral Advertising in Last 12 Months to Categories of Third Parties 
Government identifying numbers (social security, driver’s license, state ID, or passport numbers) Yes Yes to Vendors and Legal Parties No
Complete account credentials (account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account) Yes Yes to our Vendors, Authorized Parties and Legal Parties No
Precise geolocation No* Not applicable Not applicable
Racial or ethnic origin, religious or philosophical beliefs, or union membership   Yes Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties Yes to our Affiliates, Vendors and Advertising Providers
Mail, email, or text message contents not directed at us No* Not applicable Not applicable
Genetic data No* Not applicable Not applicable
Biometric information processing for the purpose of uniquely identifying an individual No* Not applicable Not applicable
Health, sex life, or sexual orientation  No* Not applicable Not applicable
Other sensitive information you choose to provide (for example, you may choose to provide information in any of the above categories even if we do not specifically collect it) Yes Yes to our Affiliates, Vendors, Authorized Parties and Legal Parties No 

*Not specifically collected by us but may be included in the category of “other information you choose to provide”.

7. Data Security and Processing

Security of Personal Information 

We will maintain reasonable technical and organizational safeguards for the protection of the security and confidentiality of personal information from unauthorized access, use, disclosure or transfer. Despite our efforts to ensure security, we cannot guarantee or warrant that personal information will not be accessed, acquired, disclosed for an improper purpose, altered or destroyed by an unauthorized person or as a result of a breach of our security safeguards or those of our hosting provider or other vendors or service providers.  We cannot ensure the security of any data transmitted to us over the internet. To the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure by us of personal information. Therefore, we urge you to take adequate precautions to protect personal information as well, including, without limitation, never sharing your account username or password.

International Transfer, Storage and Processing

We operate from the United States and the personal information we collect or receive is stored and processed in the United States and may be processed in other countries around the world subject to the provisions of this Privacy Policy. 

If you are located in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, please note that we may transfer data, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and may afford materially less privacy protections for your personal information than your jurisdiction. You consent to the transfer of personal information to the United States or any other country in which we, our affiliates or vendors maintain facilities. You consent to the use and sharing of information about you as described in this Privacy Policy.

8. Changes and Amendments to Privacy Policy 

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we do, we will post the revised policy on our website with a new “Last Updated” date. We may, but are not required to, also provide you with notice of the amended Privacy Policy via any others means we consider reasonable, including, without limitation, email or posting in our Services. Your continued use of our Services or your provision of personal information to us following the posting of changes (or other notice we provide in our sole discretion) constitutes your acceptance of such changes and the Privacy Policy as amended. We may, but are not required to, also provide you with alternative means of accepting any changes to or amended version of this Privacy Policy. We encourage you to visit this page regularly for any changes. 

9. Contact Us

Contact Us

You may contact us with questions, concerns, complaints or disputes related to this Privacy Policy and our privacy policies and practices.

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