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Avenge Digital Privacy Policy

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At Avenge Digital LLC, we appreciate the trust you place in us when you choose to visit our website and we take that responsibility seriously. This Avenge Digital Privacy Policy (the “Policy”) describes how we collect and use personal information about you when you visit our website, use our mobile application, or call us on the phone.  This Policy also includes the disclosures, rights, and obligations required for California consumers and residents under the California Consumer Privacy Act.  

By “personal information”, we mean information that directly identifies you, such as your name, address, or email address. In this Policy, “we” and “our” mean Avenge Digital and “you” means any person who visits our website or uses our mobile application.

What Information We Collect

We collect a variety of types of information:

• Contact information, such as your name, address, phone number, or email address;
• Purchase information, such as the items you purchase, payment method and payment information (such as debit or credit card number and information), billing and shipping address, and contact information (such as for receipts or order updates);
• Preference information, such as your contact and marketing preferences;
• Profile and account information, which may include Contact, Purchase, and Preference information as well as your account password, and other information about your profile or account;
• Demographic information, which may include age or birthdate, gender, ZIP code, and other information about you;
• Call recordings including information about your call and that you share when you call us on the phone;
• Location information of your device that you use with our mobile application, if your device settings allow us to collect location information; and
• Device and browsing information, including information about your phone, tablet, computer, or device, and online browsing activity (collectively, “automatically collected information”). Automatically collected information may include IP addresses, unique device identifiers, cookie identifiers, device and browser settings and information, and Internet service provider information. Automatically collected information also may include information about when and how you access and use our website or mobile application, such as the date and time of your visit or use, the websites you visit before coming and after leaving our website, how you navigate and what you search for using our website and mobile application, the website pages and items you view using our website and mobile application, and the items you purchase.

How We Collect Information

We collect information on our website, through our mobile application, and during calls with you. We also obtain information from you and from third parties. For example, we collect and obtain information:

• You provide, such as when you make a purchase, interact with a salesperson, visit or contact us, register for a Rewards or online account, participate in a contest or sweepstakes, respond to a survey, engage in a promotional activity, register to attend an event or appointment, apply for employment, or sign up for emails or marketing;
• From wi-fi and mobile devices, such information about your device when you use our store wi-fi services; and information about your device and location if you have installed our mobile application on your device and your device is near our store or store systems (such as systems that offer personalized content), even if you are not currently using the mobile application, though you can disable location sharing using your device or application settings;
• From third parties, such as service providers that we use, analytics companies, advertising networks and cooperatives, demographic companies, third parties that provide us with information about you and the different devices you use online, and other third parties that we choose to collaborate or work with; 
• From social media platforms and networks that you use in connection with our website or mobile application, or that share or allow you to share information with us, such as Facebook, Twitter, and Instagram. For example, if you use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with our website or mobile application (e.g., to log into an account, or to share inspiration, finds, purchases, and other content with your friends and followers on social media), we will collect the information that you share with us, or that those social media platforms or networks share with us. For more information about social media platform and network privacy practices, please review the privacy policies and settings of the social media platforms and networks that you use; and
• Using cookies and automatic collection methods. For example, we and third parties we work with may collect information from the computer, tablet, phone, or other device: that you install our mobile application on; that you use to access our website; or that you use to open an email or click on an advertisement from us. This collection includes automatically collected information, and generally does not include personal information unless you provide it through our mobile application or website or you choose to share it with us. Methods we use include:
  • cookies (which may be session-based or persistent, and are typically small data files that are stored on your hard drive or in connection with your Internet browser);
  • web beacons or tags (small images embedded into websites or emails that send information about your computer, tablet, phone, or other device when you visit our website, use or mobile application, or open an email we send to you);
  • website and mobile application log files (which we tend to create automatically in connection with access to and use of our website and mobile application);
  • Flash cookies or Local Stored Objects (which may be placed using Adobe Flash software—learn more about privacy and storage settings for Flash cookies here); and
  • other technologies (which may be similar to or different than the methods noted above).

How We Use Information

We use the information that we collect to conduct our business and to provide you with the best possible products, services, and experiences. We also may combine any or all of the information that we collect or obtain. Examples of how we use information include:

• To provide you with products and services, such as to: fulfill your orders and process your payments; process, maintain and service your account(s); and to provide you with products and services that we think you will like. To see a list of our marketing partners, click here;
• To respond to you, such as when you: place an order; call us; make a request or inquiry; or share a comment or concern;
• For marketing and advertising, such as to: send you marketing and advertising communications; check creditworthiness; and to customize the marketing and advertising that we show you;
• For analytics, such as to: understand how you use our website and mobile application; determine the methods and devices used to access our website and mobile application; and improve our website and mobile application;
• For our business purposes, such as: to operate and improve upon our business and lawful business activities; to maintain our programs, accounts, and records; for research; to determine your satisfaction with our products and services; to detect and prevent fraud or misuse of our services; and for any other business purpose that is permitted by law; and
• For legal and safety purposes, such as to: defend or protect us, our customers, you, or third parties, from harm or in legal proceedings; protect our rights; protect our security and the security of our customers, employees, and property; respond to court orders, lawsuits, subpoenas, and government requests; address legal and regulatory compliance; and notify you of product recalls or safety issues.

How We Share Information

In general, we do not share personal information about you with third parties for third party marketing or advertising purposes. We may share personal information with third parties for other purposes. For example, we share personal information with:

• Third parties and service providers that provide products or services to us, that help us market or advertise to you, or that provide products or services to you. We may use third parties or service providers to perform any of the actions or activities allowed under this Policy;
• Social media platforms and networks such as Facebook, Twitter, and Instagram that offer functionalities, plugins, widgets, or tools in connection with our website or mobile application (e.g., to log into an account, or to share inspiration, finds, purchases, and other content with your friends and followers on social media). If you choose to use these functionalities, plugins, widgets, or tools, certain information may be shared with or collected by those social media companies—for more information about what information is shared or collected, and how it is used, see the applicable social media company’s privacy policy;
• Parties to business transactions such as those we deal with in mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, personal information may be shared, sold, or transferred, and it may be used subsequently by a third party; and
• Additional third parties such as law enforcement, government entities, courts, or other third parties as required or allowed by applicable law, such as for the legal and safety purposes described under the “How We Use Information” Section above, or otherwise to help prevent harm or fraud to us, you, our customers, or other third parties. We also may share personal information with third parties upon your request or with your approval, though we may not be able to accommodate all requests.

How Long We Will Keep Information

We retain your Personal Information for the length of time required for the specific purpose or purposes for which it was collected and we will securely delete that information once we no longer need it. In some cases, we may be obliged to store your Personal Information for a longer time, taking into account factors including: (a) legal obligation(s) under applicable law to retain data for a certain period of time; (b) statute of limitations under applicable law(s); and (c) guidelines issued by relevant data protection authorities.

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

A. Information We Collect.

As discussed herein, Avenge Digital collects 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 (“personal information”). In particular, Avenge Digital has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	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.	Yes.
Protected classification characteristics under California or federal law.	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).	Yes
Commercial Information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes.
Biometric information.	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.	No.
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes.
Geolocation data.	Physical location or movements.	No.
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No.
Professional or employment-related information.	Current or past job history or performance evaluations.	No.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	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.	No.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

 

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• 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.

Avenge Digital obtains the categories of personal information listed above from the following categories of sources:

• Directly from you, including from forms you complete or products and services you purchase; and
• Indirectly from you, including from observing your actions on our Website.

B. Use of Personal Information.

Avenge Digital may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, 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. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• 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.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Avenge Digital’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Aveng Digital about our Website users is among the assets transferred.

Avenge Digital will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

C. Sharing Personal Information.

Avenge Digital may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business 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. 

 

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

• Service providers.
• Data aggregators.

D. Rights and Choices for California Consumers.

The CCPA provides California consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

i. Access to Specific Information and Data Portability Rights.

You have the right to request that Avenge Digital disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

ii. Deletion Request Rights.

You have the right to request that Avenge Digital delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 provider(s) 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.

iii. Exercising Access, Data Portability, and Deletion Rights.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at (425) 658-9008.
• Emailing us at contact@avengedigital.com. 

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.  You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

iv. Response Timing and Format.

Avenge Digital endeavors to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

How You Can Contact Us About this Policy

Questions about this policy may be directed to priceshopinsurance@avengedigital.com, or you can call us at (425) 658-9008. 

Effective: January 1, 2020

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