Update: June 22, 2020
- Information we collect and store
- How we use Personal Information
- Information sharing and disclosures
- Cookies and Do Not Track (DNT) signals
- Mobile Application
- Third party links
- Children’s privacy
- Individual rights to Personal Information
- State privacy rights (including California residents)
INFORMATION WE COLLECT AND STORE
Your Personal Information. For a better experience while using our Site and Services, we may require you to provide us with certain personally identifiable information (“Personal Information”). This Personal Information may include, but is not limited to:
- Name(s) (including aliases and your signature);
- Phone number(s), including mobile phone numbers;
- Physical, shipping, postal and billing address(es);
- Email address(es);
- Biometric information, like your photograph;
- Tax identification numbers/tax type;
- Age/date of birth, educational/professional/employment related information, gender/gender identity/gender expression, sexual orientation, race, ethnicity, religion or creed, veteran or military status, or other profile information;
- Commercial information, such as your payment information and purchase history described below;
- IP address(es) and device identifier(s);
- URLs, such as your social media accounts;
- Inferences our Site or Services draw from any of the Personal Information we collect, such as your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes; and
- Other identifying information you voluntarily choose to provide us, including without limitation, any unique identifiers (e.g., personal identifiers, online identifiers, the account name you create with us, identifications cards like driver’s license or passport) and information exchanged on the Site or in connection with the Services (whether orally or in writing).
Your Personal Information does not include aggregated, de-identified or anonymized information. Aggregated, de-identified or anonymized information is information that cannot reasonably be used to identify you.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Sites, we may collect and retain such information in a file specific to you.
PAYMENT INFORMATION AND PURCHASE HISTORY
The payment information we collect and store includes your payment card type (such as VISA or MASTERCARD), last four digits of the payment card and expiration date, what and how much you purchased, and when you purchased it. We collect and store this payment information to provide the Services to you and so that you can monitor your payment history, request a refund, and alert us of any potential fraud or misuse of your payment information. We may also use this payment information to process your request for a refund, to monitor for fraud and misuse, for data analytic purposes, and for the other purposes described below in the Section on How we use Personal Information.
Other Information. Some information is automatically collected from you when you use our Site or Services and is stored in log files, which are used on the Site and in links to the Site from an email. The types of information that may be automatically collected from your use of the Site include (without limitation):
- Information about your search queries;
- Information about your computer and its operating system, Internet connection, and the equipment you use to access the Site;
- Information about your geolocation and the statistics and information associated with the interaction between your browser or device and the Site;
- Some commercial information, such as what you purchased on the Site; and
- Information from Cookies (defined below) or other source through which you accessed the Site, the pages you visit, and the time spent on these pages, and other usage details regarding your activities on the Site.
The automatically collected information is generally statistical, but may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. We use this information to analyze trends, administer the Site, track users’ movements around the Sites, and gather demographic information about our user base as a whole. We do so in an effort to create a more efficient and usable Site, and to determine areas of the Sites or Services that could be improved to enhance the user experience.
We may collect Personal Information and other information for a variety of sources, including the following categories of sources:
- Directly or indirectly from you and your agent’s through use of the Site or Services; and
- From third parties that may interact with us in connection with the Site or Services.
We retain your Personal Information for as long as you have an open account with us or as otherwise necessary for you to use the Site or Services, resolve disputes, prevent fraud, enforce any agreement between you and Agellum, or as otherwise permitted or required by applicable law. Afterwards, we may choose to retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
How we use Personal Information
- Provide, maintain, administer, improve and/or expand our Services;
- Provide customer support, resolve disputes or troubleshoot problems, including debugging to identify and repair errors that impair functionality of the Site and our Services;
- Inform you about updates, advertise our Services to you, or customize your experience on the Site (including its content or layout);
- Detect security incidents and protect against error, fraud, or other illegal/criminal activity and prosecuting those responsible for such activities;
- Provide you with notices about certain resources you may be interested in learning about and notices regarding your account (including expiration and renewal notices);
- As part of our internal auditing related to interactions with our customers;
- Perform internal research on your demographics, interests, traffic patterns, usage, and behavior;
- Run data analytics (such as Google analytics) to understand how our users use the Site;
- Improve our internal marketing, promotional efforts, or enhance our business and Services; and
- For such other purposes as described to you at the time we collect Personal Information. We may (but have no obligation to) compare and review Personal Information for errors, omissions, and accuracy.
INFORMATION SHARINGA AND DISCLOSURES
We may share (disclose) your Personal Information and other information we collect and store about you to:
- Any third party if the disclosure is to fulfill the purpose for which you provide it to us, including in order to provide you with access to the Site or Services or to assist us in how we use Personal Information. For example, if you are a Rep or customer, the person who sponsored you will have access to your name, the Agellum identification number associated with your account, and the date of your last purchase order.
- Our contractors who help us with the Site and in providing the Services, such as those who host our website and data, assist with order fulfillment, process credit card payments, and help us with data analytics. We could not provide the Site or Services without their help. We require our contractors to protect the confidentiality and security of Personal Information.
- We may disclose Personal Information to a buyer or other successor of Agellum in the event of a merger, divestiture, restructuring, reorganization, dissolution, change of control, or other sale or transfer of some or all of Agellum’s assets.
- Third parties pursuant to a legal request. We also may disclose Personal Information or any other information we collect about you if we determine in good faith that such disclosure is needed to: (1) comply with or fulfill our obligations under applicable law, regulation, court order or other legal process; (2) protect the rights, property, or safety of you, Agellum, or another party; or (3) enforce any agreement between with you and Agellum. If we receive a law enforcement or other government official request to disclose your Personal Information in connection with your involvement in an alleged crime or other illegal activity, we can (and you hereby authorize us to) disclose your name, city, state, telephone number, email address, username history, and fraud complaints without a subpoena.
- We may also disclose your Personal Information for any other purpose with your consent.
We do not, and will not, sell your Personal Information to any third party for marketing purposes without your explicit consent.
WE MAY DISCLOSE AGGREGATED, DE-IDENTIFIED AND/OR ANONYMIZED INFORMATION ABOUT OUR USERS, AND INFORMATION THAT DOES NOT REASONABLY IDENTIFY ANY INDIVIDUAL, WITHOUT RESTRICTION, INCLUDING TO BETTER UNDERSTAND THE USERS OF OUR SITE AND EVALUATE HOW WE CAN DELIVER A BETTER EXPERIENCE FOR OUR USERS.
We cannot assure you that your Personal Information will never be disclosed in ways not otherwise described here. For example (and without limitation), third parties may unlawfully intercept or access transmissions, or users may abuse or misuse Personal Information they collect from Agellum. Although we use commercially reasonable practices to protect your privacy, we do not guarantee (and you should neither rely upon nor expect) that Personal Information will always remain private.
COOKIES AND DO NOT TRACK (DNT) SIGNALS
When you use the Site, we may collect certain information automatically by electronic means, which may include:
- Browser Cookies. A cookie is a small file placed on the hard drive of your computer or mobile device and are stored on your device after you exit your browser. Temporary cookies, also known as “Session Cookies,” are used for various reasons, such as managing page views and are usually erased by your browser when you exit it. Cookies that are stored on your device after you exit your browser, also known as, “Persistent Cookies” are used for a number of reasons, such as storing your preferences and retrieving certain information, you have previously provided.
- Flash Cookies. A locally stored object, also known as “flash cookies,” is a feature from our Site that collects and stores information about your preferences and navigation to, from, and on our Sites, but is not managed by the same browser settings as are used for session cookies, persistent cookies, or other types of browser cookies.
- Web Beacons. A web beacon is a small electronic file, sometimes referred to as clear gifs, pixel tags, and single-pixel gifs (collectively, “Web Beacons”), that permits us, 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 certain website content and verifying system and server integrity).
- Web Analytic Service. A web analytic service, such as Google Analytics, can be used to evaluate your use of the Site, such as mouse clicks, mouse movements, scrolling activity, and text typed into the Site (“Web Analytics”). We use Web Analytics to help us understand how we can make our Services easier to use.
- Mobile Device Identifiers. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it (“Mobile Device Identifiers”). Mobile Device Identifiers enable collection of Personal Information (such as media access control, address and location) and your traffic data, and allow us to learn more about your demographics and internet behaviors in order to personalize and improve the Services.
We use the term “Cookies” to refer to all of the above. Cookies help us to improve our Site and Services. Some web browsers allow you to reject Cookies or alert you when a Cookie is placed on your computer or other device. Although you are not required to accept our Cookies, if you refuse them, you may not be able to use some portions of our Site or Services.
Third Party Cookies. Some Cookies are placed by a third party on your computer or device and provide information to us and third parties about your browsing habits, such as links you have clicked (“Third Party Cookies”). These Third-Party Cookies can be used to determine whether certain third party services are being used, to identify your interests, and to serve advertisements relevant to you. WE DO NOT CONTROL THIRD PARTY COOKIES.
Some website browsers also have a “do not track” or DNT feature that lets you tell websites that you do not want to have your online activities tracked. No uniform technology standard for recognizing and implementing DNT signals has been finalized. We do not currently respond to a browser’s DNT signal. We do not knowingly permit third parties to track your activity over time on our website.
You may manage how your browser handles Cookies and related technologies by adjusting its privacy and security settings. Refer to your browser’s instructions to learn about Cookie-related and other privacy and security settings that may be available. You can opt-out of being targeted by certain third-party advertising companies online at http://www.networkadvertising.org/choices/.
We are committed to protecting your Personal Information. We follow commercially reasonable standards to protect Personal Information, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security. Any transmission or storage of your Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or for our Services, you are responsible for keeping this password (and any other Security Information) confidential. We ask you not to share your password (or other Security Information) with anyone. Please contact us immediately if you think your password has been compromised or there has been an unauthorized use of your account.
In the future, we may offer access to the Site through a mobile application (the “App”). With your permission, the App may request access to other data or applications on your device, such as your contacts or your text messaging application (“Short Message Service” or “SMS”). You can take back your permission through your accessing your device’s privacy setting. For more instructions on how to access these permissions in your device’s settings, go to:
- iPhone: https://support.apple.com/en-us/HT203033
- Android: https://support.google.com/googleplay/answer/6270602?hl=en
THIRD PARTY LINKS
INDIVIDUAL RIGHTS TO PERSONAL INFORMATION
You have the right to request access to and control of your Personal Information. For example:
- Deletion. You may request that we delete your Personal Information. In some cases, we may not be able to delete Personal Information without also deleting your account. You may not be able to use the Site or Services if we delete your Personal Information.
- Correction or Change. You can ask us to correct, change or update Personal Information. You can review and change your Personal Information by logging into the Site and visiting your account profile page.
- Use Limitations or Restrictions. You can request in writing that we not use or disclose your Personal Information, but keep in mind that this direction might terminate our ability to provide any of our Services to you.
- Access. You can ask us for a copy of your Personal Information.
- Report Misuse. You can also report misuse or unauthorized disclosures of Personal Information to us.
You can make any of these requests by contacting us at 1-844-599-7787 or firstname.lastname@example.org. We reserve the right to deny a request if we reasonably believe the action would violate any law or legal requirement or cause the information to be incorrect.
STATE PRIVACY RIGHTS (INCLUDING CALIFORNIA RESIDENTS)
For example, if you are a California resident (or resident in a state with privacy laws similar to California), your state law may provide you with the right to:
- Request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (a “Right to Know Request”). 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;
- The categories of third parties with whom we share that Personal Information;
- The specific pieces of Personal Information we collected about you (in California, it is called a “data portability request”);
- Our business or commercial purpose for collecting or selling* that Personal Information.
- The categories of Personal Information about you we have disclosed for a business purpose in the past 12 months; and
- The categories of third parties to whom we have disclosed your Personal Information for a business purpose in the past 12 months.
*Please note: We do not, and will not, sell personal information without your explicit consent.
- To request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (a “Deletion Request”). Once we receive and confirm your consumer request, we will 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 contractors 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 seq.) or other required state laws, if applicable;
- 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; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
You can make any of these requests by contacting us at 1-844-599-7787 or email@example.com.
Please note that depending on your state only you or an authorized person may make such requests related to your Personal Information.
Additionally, your state may limit the number of consumer requests you can make and what information you must provide for us to process such requests. For example, if you are a California resident you may only make a consumer request for access or Right to Know Request twice within a twelve (12)-month period. Your 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; and
- 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.
We respond to such consumer requests within the time periods and manner required by applicable law.
We will not discriminate against you for exercising any of your state rights. Unless permitted by state law, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.