Last Revised April 1, 2021

 

PRIVACY POLICY 

  1. Introduction

1.1       Purpose of this Policy.  This Privacy Policy (“Policy”) of 19 Ideas, Inc., a New York corporation (“our,” “us,” or “we”), applies to each one of our users, customers and visitors (“you” or “your”).  This Policy describes how we collect, use, and share your Personal Information (defined in Section 2.1).  This Policy also describes your options to control and set preferences for the collection, use and sharing of your Personal Information.

1.2       Our Third Party Associates.  We rely on our relationships with various Associates (defined below) to conduct our business.  In this Policy, “Associates” will mean third parties with whom we conduct business for our business purposes, including:

(a)        any affiliates that control us, that we control, or that are under common control with us, such as our parents, subsidiaries and sister entities;

(b)        any third parties to whom we provide products, services or data, such as collaborators, advertisers and marketing agencies; and

(c)        service providers who provide or license products, services or data to us, such as customer support providers, credit card and payment processors, order fulfillment providers, market and data analyzers, product developers, real estate owners and managers, event managers, publishers, website hosts, providers of communication systems (such as phone, text and email systems), providers of information technology systems (such as databases and data servers), online platform providers, information technology consultants, business advisors, auditors, accountants and attorneys.

1.3       Our Marketing Channels.  We may use one or more Marketing Channels (defined below) to collect your Personal Information.  In this Policy, “Marketing Channels” will mean the resources used by us or our Associates to receive or collect information, including the following resources:

(a)        www.19ideas.com;

(b)        any other websites, ecommerce stores, servers, online portals, web portals, mobile applications and electronic user interfaces;

(c)        social media pages, email messages, text messages and direct messages;

(d)        phones, computers, web cameras and other communication devices operable to receive your written, text, oral, telephonic and video communications;

(e)        real time communications with our representatives, including interviews, discussions, conversations and conferences via in-person interaction or video, phone or other means;

(f)         any brick-and-mortar facilities (such as stores, offices, trade show buildings and convention centers) as well as any cameras, beacons, sensors and other tracking equipment located at such facilities;

(g)        any means for personal interaction or observation, such as the collection of survey results from you when you are located at such facilities; and

(h)        surveys, forms and other materials used to document your answers, feedback or behavior at such facilities.

1.4       Mobile App Privacy.  This Policy applies to Personal Information we receive through all of our various Marketing Channels.  If we receive Personal Information through a mobile app that we own or operate, the related app license agreement or end user license agreement may provide information about how the app collects and uses such Personal Information.  If the app collects and sends Personal Information to others, such agreement may describe that process as well.  Therefore, to fully understand the privacy of any Personal Information collected by any of our mobile apps, please review the applicable license agreement as well as this Policy.  You may find our app license agreements at our website identified in Section 1.3(a) or at the mobile app marketplace where the app is available for downloading.

1.5       Set of Online Documents.  This Policy relates to our set of online documents, including our Terms of Use, Privacy Notice and Cookie Policy.  Our Terms of Use include and incorporate this Policy.  This Policy includes and incorporates both our Privacy Notice and our Cookie Policy.

1.6       Non-Limiting Words.  In this Policy, we use the words “including,” “includes,” and “such as” in a non-limiting fashion.

  1. Meaning of Personal Information

2.1       Personal Information.  Consistent with the California Consumer Privacy Act, in this Policy, “Personal Information” will mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

2.2       Deidentified Information and Aggregate Consumer Information.  Deidentified Information (defined below) and Aggregate Consumer Information (defined below) are not Personal Information.  We may create Deidentified Information and Aggregate Consumer Information by removing identifiers from your Personal Information and satisfying the other requirements of applicable law.  For example, if your username were janedoe99, we may collect the following information: janedoe99 clicked a particular bicycle advertisement three times while located in New York City on April 23rd of a particular year.  We may remove “janedoe99” and satisfy the other requirements of applicable law in order to create Deidentified Information or Aggregate Consumer Information.

2.3       In this Policy, “Deidentified Information” will mean information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to you, provided that the user of the deidentified information:

(a)        has implemented technical safeguards that prohibit reidentification of you;

(b)        has implemented business processes that specifically prohibit reidentification of the information;

(c)        has implemented business processes to prevent inadvertent release of deidentified information; and

(d)        makes no attempt to reidentify the information.

2.4       In this Policy, “Aggregate Consumer Information” will mean information that relates to a group or category of consumers, from which individual consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device.

  1. No Sale of Your Personal Information

3.1       We do not, and will not, sell any of your Personal Information.

3.2       When companies perform market research for their products and services, they often rely on data that describes the shopping and buying activities of a consumer population.  We may supply Deidentified Information and Aggregate Consumer Information to these types of companies and other third parties.  In exchange for the supply, we may receive payments or other monetary or valuable consideration.

  1. How We Collect Your Personal Information

We may collect your Personal Information in a variety of ways, such as by:

(a)        automatically pulling data from your browser or device, such as your computer or smartphone, by embedding computer code or data files to track your activity or geolocation, by other tracking means or by the methods described in our Cookie Policy;

(b)        receiving information you have provided to us via phone, text, email, electronic message, online form submission or other communications;

(c)        receiving information from our Associates who have shared with us, the information you have made publicly available, such as photos, videos and content you have posted on publicly-available social media platforms;

(d)        communicating with you in-person; and

(e)        photographing or video recording you when you visit any brick-and-mortar facilities of our Marketing Channels.

  1. The Categories of Your Personal Information We May Collect

The following table lists the categories of your Personal Information that we may collect for our business purposes:

Categories of Personal Information Examples of Personal Information
Identifiers

(if you chose to provide them)

Your name, unique personal identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, state identification card number, passport number, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, and any other of your financial information, medical information, or health insurance information.
Characteristics of Protected Classes

(if you chose to provide them)

Your race, color, national origin, religion, gender (including pregnancy), disability, age and citizenship status.
Commercial Information

(if you chose to provide it)

Your records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric Information

(if you chose to provide it)

Photos, videos and images of you, including your face, eyes, fingerprints and voice.
Network Activity and Device Information Your device, browser, internet or other electronic network activity information, including browsing history, search history, information regarding your interaction with an internet website, application, or advertisement, network routing information (where you came from), date/time stamps, clickstream information (when a webpage was visited and how much time was spent on the webpage), device information, browser type, Internet Protocol (IP) address (which may identify your general geographic location), referring/exit webpages, and number of visitors, views, and interactions.
Geolocation Data

(if you chose to provide it)

Your general geographic location and your Internet Protocol (IP) address, which may identify your general geographic location.
Audio and Visual Information

(if you chose to provide it)

Your audio, electronic, visual, thermal, olfactory, or similar information, including voices, sounds, photos and videos of you.
Professional Information

(if you chose to provide it)

Your professional or employment-related information.
Education Information

(if you chose to provide it)

If you are a student, your education information, personally identifiable information and directory information, such as education records, report cards, transcripts, disciplinary records, contact and family information, and class schedules.
Inferred Profile Information Inferences drawn from any of the information described in this table to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
Health Information

(if you chose to provide it)

Your health information, including medical records.
Financial Information

(if you chose to provide it)

Your financial information, including income, account bank balances, payment history, credit history and credit scores.

 

  1. The Categories of the Sources of Your Personal Information

We may obtain your Personal Information from the following categories of sources:

Categories of Sources Description
You We may collect the content, communications and Personal Information you send or provide when you use our products, services or Marketing Channels.

 

Your Devices We may pull your Personal Information from your devices and browsers through tracking methods and by placing cookies as described in our Cookie Policy.

 

Other People We may receive your Personal Information from people who use our products or services, such as when people share or comment on a photo or video of you, send a message to you, or upload, sync, or import your contact information.

 

Our Associates We may receive your Personal Information from our Associates.  Our Associates may collect your Personal Information from you or your devices in accordance with their privacy policies and applicable laws.  For example, our Associates may use Internet-based software that connects or links to our products, services or Marketing Channels.  This may enable our Associates to collect your Personal Information.

 

 

  1. Our Purposes for Using Your Personal Information 

7.1       We may collect, use, keep and share your Personal Information if doing so is necessary for us or our Associates to conduct any of the following activities (“Necessary Purposes”):

Necessary Purposes Description
Your Transaction This includes completing the transaction for which your Personal Information was collected, provide a good or service that is requested by you or is reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.

 

Security This includes detecting security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

 

Repairs This includes debugging to identify and repair errors that impair existing intended functionality.

 

Free Speech This includes exercising free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

 

California Electronic Communications Privacy Act This includes complying with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code, or comply with a similar law of another State.

 

Research In The Public Interest This includes engaging 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 our deletion of your Personal Information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.

 

Internal Uses as You Expect This includes enabling solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

 

Complying with Law This includes complying with a legal obligation.

 

Internal Uses in Context This includes otherwise using your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the Personal Information.

 

 

7.2       We may use, keep and share your Personal Information for the following additional purposes:

Additional Purposes Description
Marketing Activities This includes planning and performing the marketing activities for our products, services and Marketing Channels.

 

Product/Service Improvement This includes evaluating, improving, researching and developing our products, services and Marketing Channels.

 

Personalizing This includes personalizing our products, services and Marketing Channels for you, such as by displaying advertisements that align with your unique interests.

 

Notifying You

(until you opt-out)

This includes notifying you about new releases, alerts, updates, prices, terms, offers, or developments regarding our products or services.

 

Your Testimonials

(with your consent)

This includes posting testimonials in our Marketing Channels if you have given us consent for the testimonials.

 

Tell a Friend

(with your approval)

This includes contacting your friend for any referral or “tell a friend” feature that you have approved.

 

Safety This includes protecting, as we determine necessary or appropriate, the health, safety, security or privacy of our employees, agents, visitors and Marketing Channels.

 

Corporate Transactions This includes transferring or supplying a copy of your Personal Information to a third party that acquires any portion of our business, assets, stock or equity in connection with a reorganization, merger, sale, joint venture, contractual assignment, transfer or other transaction, including any bankruptcy or similar proceeding.

 

Complying with Authorities This includes acting, as we determine appropriate, to: (a) comply with applicable laws, including laws outside your country of residence; and (b) respond to requests from law enforcement authorities and public and government authorities, including those authorities outside your country of residence.

 

Enforcing Our Rights This includes enforcing our rights under the Terms of Use and agreements with you, including pursuing available remedies and limiting the damages that we may sustain.

 

Other Business Purposes This includes our other business purposes.

 

 

  1. The Categories of Third Parties Who May Receive Your Personal Information

8.1       We may disclose your Personal Information to the following categories of third parties:

Categories of Sources Description
Connected People and Businesses This includes people and businesses that own or operate apps, websites, products and services that are connected to our products, services or Marketing Channels.
Associates This includes our Associates involved with our business purposes.
Law Enforcement Agencies This includes law enforcement agencies concerning activity that that we reasonably, and in good faith, believe may violate federal, state, or local law.
Others Permitted by Applicable Law This includes other third parties permitted to receive your Personal Information in accordance with the applicable laws.

8.2       Based on your voluntary conduct, third parties may receive your Personal Information, such as:

(a)        people and businesses to whom you share your Personal Information; and

(b)        people and businesses who receive your Personal Information from those who originally received it from you.

  1. Privacy Policies of Third Parties

Our Marketing Channels may provide links to or the ability for you to connect with resources owned or controlled by third parties, such as third party websites, services, social networks and mobile applications.  Some of these resources may be integrated into our products, services or Marketing Channels.  Clicking on these resources or enabling these connections may enable the applicable third party to collect or share your Personal Information.  These third party resources are beyond our control.  We encourage you to check the privacy policies of these third party resources before providing your Personal Information to them.

  1. How to Control Your Preferences

10.1      Opt-Out Settings.  We may enable you to opt-out of, decline or disable certain features that involve the use of your Personal Information.  For example, we may enable you to select a setting to opt out of marketing emails and messages by modifying your user profile or using our unsubscribe link.

10.2      Cookie Settings.  You may disable certain cookies as described in our Cookie Policy.  However, your election to disable cookies may degrade the functionality of our products, services and Marketing Channels.

10.3      Blocking of Advertisements.  Your browser may enable you to block advertisements.  However, doing so may degrade the functionality of our products, services and Marketing Channels.

  1. California Residents

11.1      If you are a California resident, you can learn more about your consumer privacy rights by reviewing our Privacy Notice.

11.2      Under California Civil Code Section 1798.83 (also known as Information-Sharing Disclosure, Shine the Light), if you are a California resident and your business relationship with us is primarily for personal, family, or household purposes, you may request certain data regarding our disclosure, if any, of Personal Information to third parties for the third-parties’ direct marketing purposes.  To make such a request, use our contact page, and state “Legal Matter” in the subject line.  You may make such a request up to once per calendar year. In accordance with California Civil Code Section 1798.83, we will provide to you, by e-mail, a list of the categories of Personal Information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses and any other information required by California Civil Code Section 1798.83.

  1. European Union Residents

12.1      Legal Bases for Processing Personal Information.  If you are a resident or citizen of a member-country of the European Union, the General Data Protection Regulation ((EU) 2016/679)) (“GDPR”) may provide you with certain rights beyond the rights stated in this Policy.  In accordance with the GDPR, we may process your Personal Information without your consent under several cases, including cases in which:

(a)        it is necessary for us to process such Personal Information for purposes of: (i) performing contracts between you and us, including contracts involving our sale of products or services to you; (ii) protecting your vital interests; or (iii) establishing, exercising or defending legal claims;

(b)        it is necessary for reasons of substantial public interest;

(c)        it is necessary for reasons of public interest in the area of public health;

(d)        it is necessary for archiving purposes in the public interest or for scientific or historical research purposes or statistical purposes;

(e)        you have publicly disclosed such Personal Information that we process; and

(f)         we process such Personal Information for purposes of our legitimate interests.

12.2      Consent.  If we desire to process any of such Personal Information for cases that require your prior consent pursuant to the GDPR, we will not do so without obtaining your prior consent in accordance with the GDPR.

12.3      Transfers of Personal Information.  To the extent we transfer any Personal Information from any member-country of the European Union to any other country, we will satisfy the conditions required for such transfer under the GDPR and other applicable laws.  For example, depending on the circumstance, we may implement any of the following measures to satisfy such conditions: (a) appropriate safeguards to protect such Personal Information, including binding corporate rules, standard data protection clauses, an approved code of conduct, an approved certification mechanism, or any other measure set forth in the GDPR, provided that, in each such case, we will implement the applicable measure in accordance with the requirements of the GDPR; or (b) a procedure or measure to confirm that: (i) such transfer is necessary or that you have explicitly consented to such transfer; (ii) such the transfer is not repetitive, concerns only a limited number of Data Subjects, and is necessary for the purposes of compelling legitimate interests pursued by us; and (iii) we have satisfied the additional requirements set forth in the GDPR.

  1. Specific Privacy Laws

13.1      Education Privacy Laws

We may enter into a contract with you (or engage in a transaction with you) that involves our receipt of Personal Information that includes your education information.  Your education information may be protected under applicable laws, such as the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99).  These laws may provide certain provisions regarding such contract, the handling of your education information, your rights, and the procedures we must follow.  These laws may require that we give you certain education privacy notices beyond the notices in this Policy.  We will comply with these laws.

13.2      Health Privacy Laws

We may enter into a health-related contract with you (or engage in a transaction with you) that involves your health or medical services.  In accordance with this contract, you may provide us with Personal Information that includes your health information.  Your health information may be protected under applicable laws, such as the Health Information Portability and Accountability Act (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH).  These laws may provide certain provisions regarding such contract, the handling of your health information, your rights, and the procedures we must follow.  These laws may require that we give you certain health privacy notices beyond the notices in this Policy.  We will comply with these laws.

13.3      Financial Privacy Laws

We may enter into a contract with you (or engage in a transaction with you) that involves our receipt of Personal Information that includes your financial information.  Your financial information may be protected under applicable laws, such as the Privacy of the Gramm–Leach–Bliley Act (Public Law No. 106-102) and the Privacy Regulations and related implementing regulations, and the standards for safeguarding customer information set forth in 12 CFR Part 364 and 16 CFR Part 314.  These laws may provide certain provisions regarding such contract, the handling of your financial information, your rights, and the procedures we must follow.  These laws may require that we give you certain financial privacy notices beyond the notices in this Policy.  We will comply with these laws.

  1. How to Request Opt-Outs, Corrections, Deletions and Copies

14.1      You may have the ability to update your account profile and related Personal Information by logging in to your user account and following the prompts to update your profile.

14.2      Also, you may provide us with a request to: (a) obtain a copy of your Personal Information in our possession; (b) correct or delete any such Personal Information; or (c) change how we collect or use your Personal Information.  In your request, please make clear the specific pieces of Personal Information you would like to have changed or deleted from our databases.  To submit a request under this Section, state “Legal Matter” in the subject line of your request, and sent your request through our contact page or by writing or emailing us at the following address:

19 Ideas, Inc.
Legal Department
32C Essex Street
Buffalo, New York 14213
Email Address: legal@19ideas.com

14.3      For security purposes, we may require identity verification before processing your request.

14.4      We will respond to your request within a reasonable timeframe and in accordance within the requirements, frequency and timing specified by the applicable laws.  We may decline part or all of your request as permitted by the applicable laws.  For example, we may decline to delete your Personal Information if the applicable laws permit us to retain it for Necessary Purposes or other business purposes.  In such cases, we will let you know the reason for the decline.

  1. Cross Border Transfers/Storage

We might offer our products, services or Marketing Channels on a worldwide basis and might rely upon the services or facilities of our Associates located in the United States and other countries throughout the world.  In accordance with applicable laws, we may: (a) transfer your Personal Information from the United States to countries outside of the United States, where it may be stored and processed for the uses described in this Policy; and (b) transfer your Personal Information from a country outside of the United States to another country, where it may be stored and processed for the uses described in this Policy.

  1. How Long We May Keep Your Personal Information

16.1      We may retain your Personal Information until we no longer have Necessary Purposes or other business purposes to keep your Personal Information (“Retention Period”).

16.2      At the end of the Retention Period or when you delete your user account, whichever comes first, we may permanently destroy, erase, delete, encrypt or disable access to your Personal Information in a manner designed to ensure that it cannot be reconstructed or read.  You will not be able to recover such Personal Information later.

  1. Security of Your Personal Information

The security of your Personal Information is very important to us.  Directly or through our Associates, we use physical, technical, and administrative safeguards designed to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.  However, we cannot warrant the security of any Personal Information that you send us.  There is no guarantee that your Personal Information will not be unlawfully accessed or destroyed by a hacking incident, cyberattack or other breach of our physical, technical or administrative safeguards.

  1. Policy Updates

We may update this Policy from time to time.  The date provided at the beginning of this Policy is the latest revision date of this Policy.  To request a prior version of this Policy, please contact us.

 

End of Privacy Policy

© 2021 by 19 Ideas, Inc.

 

 

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32C Essex Street
Buffalo, NY 14213

© 2021 by 19 Ideas, Inc. All Rights Reserved.