2. WHAT INFORMATION DO WE COLLECT?
We may collect different types of information from you, including Personal Information. “Personal Information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, household, or device, and that is not publicly available.
We also collect non-identifying information that does not directly or indirectly identify you, and cannot reasonably be used to identify you, such as deidentified or aggregate information. When non-identifying information is combined with other information so that it does identify an individual person, we treat that combination as Personal Information.
The following are examples of the types of information that may be collected about you when you interact with us, our products and services, or our Site:
Identification Information. For example, name, postal address, email address, unique personal or online identifier, internet protocol (IP) address, account name, Social Security Number (SSN), driver’s license, or governmental identification number.
Customer Records. For example, records of the products or services you have purchased, obtained, or considered, other purchasing or consuming histories or tendencies, or educational, professional, or employment-related information.
Financial Information. For example, debit or credit card information, bank account information, signatures, or billing addresses.
Correspondence. For example, information provided when you call, email, or write to us, respond to voluntary surveys or feedback requests, or enter a contest or promotion.
User-Generated Content. For example, content generated by engaging with ABC’s publicly facing interactive properties (e.g., its social media pages), including comments, recommendations, reviews, ratings, or any other posts or information voluntarily submitted to such properties (“Public Activities”).
Internet or Other Similar Network Activity. For example, browsing or search history; device information, such as hardware, IP address, operating system version, browser type and settings, language and font settings, or other information about the device used to access the Site; or other information about your interaction with a website, application, or advertisement.
Geolocation Information. For example, physical location or movements.
We collect your information when you directly provide it to us, automatically as you navigate through the Site, and from third parties (like our business partners). We may combine information that we collect from and about you, including information collected offline, across your devices, and from third party sources.
We collect information from you when you directly provide it to us, such as when you:
- Place an order for, or otherwise provide information to us in connection with, our products or services;
- Register for an online account with us;
- Call, email, write to, or otherwise correspond with us through any communication channel;
- Enter into contests, sweepstakes or promotions that we offer;
- Respond to our surveys or otherwise provide feedback to us;
- Engage with us through our social media accounts, such as our accounts at Facebook, Instagram, LinkedIn, Twitter, and YouTube; or
- Rate or review us online.
Information collected automatically may include:
- Usage Information. This information includes details of your visits to the Site, including traffic data, logs, location data, and information about the resources you access and use, such as time of visit, pages visited, time spent on each page of the Site. We may also collect information about the site you were visiting before you came to our Site and the site you visit after you leave.
- Device Information. This information includes data about the computers or other devices you use to access the Site (each, a “Device”), such as your operating system type or mobile device model, browser type, domain, Device identifiers, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers.
We may also use automatic data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
From time to time, we may obtain information about you from other trusted third-party partners, such as analytics or marketing providers or public databases, to update or supplement information about you, such as information to validate or update your address or other demographic and lifestyle information. We may also receive information about you from a third party through our refer-a-friend functionality.
If you send someone else a communication from the Site, such as sending an invitation to a friend (“refer-a-friend”), the information you provide (names, email addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. If that person becomes a customer or registers with us, the person’s information will be treated in the same manner as all other customers or registered users. Please be aware that when you use any refer-a-friend functionality on the Site, your email address may be included in the communication sent to your friend.
We collect the information described above, subject to applicable laws, for the following business purposes:
- To provide you with, process payment for, and manage products or services you have requested from us;
- To allow you to register and create an account and profile;
- To provide you with ongoing customer support, including sending you maintenance communications to alert you to changes and updates in our Site policies, products, or services that may affect you;
- To enable you to provide us with feedback, participate in surveys, and contact us, and for us to contact you;
- To administer promotions you enter, such as a contest or sweepstakes;
- To send you communications of interest, such as emails or text messages about ABC and our products, services, and promotional offers;
- To deliver behavioral advertising to you on behalf of ourselves and advertisers based on your activity on the Site and on third-party sites and applications;
- To personalize your overall experience with the Site;
- To customize, measure, and improve our Site, products, services, content, and advertising;
- To protect, enforce, or defend the legal rights, privacy, safety, or property of ourselves, our employees, our agents, or others, and to comply with applicable law;
- For any other purpose with your consent.
- Service Providers. We contract with third-party service providers that we use to help us operate our business and the Site or provide services on our behalf. For example, these services may include payment and billing processing, fulfillment of orders, shipping, IT and related infrastructure provision, customer service, advertising, email distribution, research and analytics, or management of sweepstakes, contests, or promotions.
- Sale or Transfer of Business or Assets. We reserve the right to transfer any information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition, or in connection with a bankruptcy reorganization. In addition, information about our customers and registered users may also be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support, or funding.
- With Your Consent. We will share your Personal Information with others when you specifically permit us to do so.
When you visit the Site, we and our service providers may use the following technologies to automatically collect data about your visit:
- Cookies. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Site. Some cookies contain serial numbers that allow us to connect your activity with the Site with other information we store about you in your profile or as related to your interactions with Site. Some cookies are temporary, whereas others may be configured to last longer. For instance:
- “Session cookies” are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases Session cookies once you exit your browser.
- “Persistent cookies” are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use Persistent cookies for a number of purposes, such as retrieving certain information you have previously provided.
- “Flash cookies,” known as local shared objects, are data files placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device to personalize your visit. Flash cookies are different from standard browser cookies because of the amount of, type of, and how data is stored.
Some or all of the categories of cookies described below may be stored in your browser when you use our Site:
- Strictly Necessary cookies: Strictly Necessary cookies are necessary for the operation of our Site. These cookies are essential in helping you to move around our Site and use the features, such as accessing secure areas of the Site or remembering the goods and services you selected when you get to a payment page.
- Functionality Cookies: Functionality cookies allow us to remember choices you make while browsing. For example, we may use these cookies to detect if you have already seen a pop-up to ensure it does not get shown again, or to process a user request or submission.
- Performance Cookies: Performance cookies help us improve the way our Site works. We utilize these cookies to analyze how our visitors use our Site and to monitor Site performance.
- Marketing Cookies: Marketing cookies are what allow us to target personalized advertising to you. These cookies may also be placed on your device by our third party service providers that remember you have visited the Site in order to provide you with ads that are more relevant to you.
You can choose to have your computer warn you each time a Persistent or Session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. However, cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, please click here. If you choose to disable cookies on your Device, some features of the Site may not function properly. For instance, if cookies are disabled, you will not be able to log into the Site and therefore you will experience an anonymous user experience.
- HTML5. HTML5 is another form of collection, tracking and storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies can be used to track users across website but are not stored in browsers’ cookie files. To our knowledge there is currently no known way for a user of a mobile device to remove HTML5 tracking and storage.
- Pixel Tags and Web Beacons. Pixel tags and web beacons are tiny graphic images placed on the Site or in our emails that allow us to determine whether you have performed specific actions. When you access the Site or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve the Site and promotions.
- Embedded Scripts. We also use embedded scripts, which are programming codes designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
In many cases, the information we collect using cookies and other automatic data collection technologies is used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about Site users to optimize our products and services and understand traffic and usage patterns.
In other cases, we associate the information we collect using cookies and related technologies with Personal Information. Whenever we associate Usage Information or a Device Identifier with your Personal Information, we will treat it as Personal Information.
If you wish to exercise choice with respect to collection and use of the data by third-party tools, you may visit: http://www.aboutads.info/choices/.
In Canada, please visit: http://youradchoices.ca/choices/.
In the EU, please visit: http://www.youronlinechoices.eu/.
Some of the analytic and tracking tools we use are Google Analytics and Google Analytics Advertising. The Google Analytics Advertising features we use include the following:
- Google Display Network Impression Reporting
- Google Analytics Demographic and Interest Reporting
- Integrated services that require Google Analytics to collect data via advertising cookies and anonymous identifiers
To prevent data from being collected by Google Universal Analytics, use the opt-out browser add-on developed by Google for this purpose available here: http://tools.google.com/dlpage/gaoptout?hl=en-US.
7.1 Don’t Volunteer Information
If you have an online account with us, you may choose to deactivate or otherwise manage your account and the Personal Information you provided in your account at any time by visiting your account online.
7.2 Your Online Account
To opt out of electronic, direct mail, or telemarketing communications from ABC or its affiliates (collectively, “Marketing Communications”), you may do so by using the following information. If you do not want to receive emails from us, you may click here or the unsubscribe link in the footer of the any email or contact us using the information below. If using an email below, please include the appropriate message in the subject line, “Unsubscribe promotional offers”, “Do not mail”, or “Do not call”.
|Email us:||Call us:|
If you consent to our collection of your precise Device geolocation through any of our mobile applications, you can withdraw your consent at any time and prevent the further collection of your precise geolocation by accessing the privacy settings of your Device and/or the settings of the mobile application.
For information about how to manage cookies and other automatic data collection technologies, see Section 6 on Cookies and Other Technologies.
To opt out of receiving personalized or “interest-based” online sponsorship credits from our service providers and other participating companies, visit http://www.aboutads.info/choices. For information about controlling the collection of cross-app data from your mobile device for personalized or “interest-based” advertising or sponsorship credit purposes, visit http://youradchoices.com/appchoices. You may also adjust the privacy and advertising settings on your Device. Consult your Device manufacturer’s support materials for information about available settings.
We maintain reasonable administrative, technical, and physical safeguards to protect the confidentiality and security of Personal Information we collect and process. To guard your information delivered to us electronically, the Site uses Secure Sockets Layer (SSL), which encrypts your payment card number, name and address so only we are able to decode your information. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your contact information, to the extent permitted by law, we do not guarantee or warrant the security of any information you transmit to or from the Site, and you do so at your own risk.
The California Consumer Privacy Act of 2018 (“CCPA”) affords certain rights to verified California residents regarding their Personal Information as described in this Section 10.
The following chart describes the CCPA categories of Personal Information we have collected in the preceding 12 months, along with the source of the Personal Information collected, and whether, within the past 12 months, ABC has disclosed and/or sold it for a business purpose to the parties identified in Section 5 on How Do We Share Your Information[RE1] ? above.
|Categories of Personal Information See Section 2 (What Information Do We Collect?) above for more information.||Sources of Personal Information See Section 3 (How Do We Collect This Information?) above for more information.||Information may be disclosed for a Business Purpose||Information may be “sold” for a Business Purpose|
|A. Identifiers, such as name, email address, and SSN.||Information You Provide to Us Information We Collect from Third Parties||Yes||No|
|B. Customer records as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as signature or financial information.||Information You Provide to Us Information We Collect from Third Parties||Yes||No|
|C. Protected classification characteristics, such as age, sex, or citizenship.||Information You Provide to Us Information We Collect from Third Parties||No||No|
|D. Commercial information, such as records of services purchased or considered.||Information You Provide to Us Information We Collect Automatically Information We Collect from Third Parties||Yes||No|
|E. Biometric information, such as finger prints.||ABC does not collect this type of information||No||No|
|F. Internet or other similar network activity, such as Usage Information or Device Information.||Information We Collect Automatically||Yes||No|
|G. Geolocation data.||Information We Collect Automatically||Yes||No|
|H. Sensory data, such as audio, electronic, or visual information||ABC does not collect this type of information||No||No|
|I. Professional or employment-related information.||Information You Provide to Us Information We Collect from Third Parties||Yes||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 35 C.F.R. Part 99)).||ABC does not collect this type of information||No||No|
|K. Inferences drawn from other Personal Information.||Information You Provide to Us Information We Collect Automatically||Yes||No|
If you are a California resident, you may have certain rights under the CCPA related to your Personal Information as described below, subject to limited exceptions.
- Access: You may request, up to two times each year, that we disclose to you the categories and/or specific pieces of personal information that we collect, use, disclose, and may sell.
- Deletion: You may request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service providers to complete the transaction for which we collected the Personal Information, detect security incidents, protect against illegal activity, or comply with a legal obligation, among other things.
To exercise the above rights, please submit a verifiable consumer request to us by:
|Email us:||Call us:||Visit us:|
Only you, or someone legally authorized 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.
A 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.
- If your authorized agent submits a request on your behalf, we will require your authorized agent to provide proof that you authorized the request, and we will require you to verify your identity directly with us.
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 will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor 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.
Personal Information Sales Opt-Out and Opt-In Rights
We do not sell the Personal Information of any of our consumers, including consumers we actually know are less than 16 years of age.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
California’s “Shine the Light” law (California Civil Code § 1798.83) permits you request certain information about our disclosure of Personal Information to third parties for their direct marketing purposes. To make a request, you must email us at Killabug@abcbug.com or visit https://www.abcbug.com/
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Our Site currently does not respond to such “do-not-track” signals.
The Site and ABC’s products and services are not directed at or intended for children under 16 years of age. We do not knowingly collect personal information from individuals under 16 years of age. If you are under 16 years of age, you should not register or provide any personal information to ABC, including on the Site. If we later obtain actual knowledge that we have collected or received personal information from a child under 16 years of age without verification of parental consent, we will take steps to remove that user’s personal information from our systems. If you believe we might have any information from or about a child under 16 years old, please contact us as described in the Contact Us section below.
10.2 The Site is only intended for U.S. users.
To opt out of marketing communications:
To opt out of electronic, direct mail, or telemarketing communications from ABC or its affiliates (collectively, “Marketing Communications”), you may do so by using the following information.
If you do not want to receive emails from us, you may click Killabug@abcbug.com or you may also click the ‘unsubscribe’ link in the footer of any email or contact us using the information below.
If emailing, please include the appropriate message in the subject line: “unsubscribe promotional offers”, “do not mail”, “do not call”.
|Email us:||Call us:||Visit us:|
If you have questions or requests about your California rights, please visit chapter 9 of this policy, above.
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