Collection of Personally Identifiable Information
Personally identifiable information allows us to identify and communicate with an individual. Through the use of the Site and through your consent to receive email or pursuant to List Management Arrangements, we may collect or maintain personally identifiable information such as your name, postal address, telephone number, mobile phone, or email address, or (b) other information about you, such as your zip code, gender, age, industry, personal interests, categories of interests, or other demographic information.
To better provide you with offers, we may append traditional data to email records by matching information that you provide to us with third-party data sources. For example, we may match your personally identifiable information to information from third-party data sources, such as past purchase information and your future Web usage from other sites. We may also use data collected through our other Web sites and combine this data with your personally identifiable information to enhance the data we collect on the Site and the data we receive from and manage for third-parties. By providing your personal information to us, some of your past and future Web usage and other information will no longer be anonymous to us.
The following are certain situations in which we may collect personally identifiable information from you:
Subscriptions, Forms, and Surveys. We may receive and retain your personally identifiable information from you when you complete and submit a subscription, form or survey.
Correspondence. If you send us personal correspondence, such as emails or letters, or if other users or third-parties send us correspondence about you, we may choose to collect such information.
Business Partners and Affiliates. We may receive and retain your personally identifiable information from one of our business partners or affiliates.
Registration for Sweepstakes. We collect personally identifiable information from you if you register online for one of our sweepstakes. When you register with us, we may ask for personally identifiable information like your name and e-mail address, as well as non-personally identifiable information, such as your birth date, gender, ZIP code, occupation, industry, personal interests and other demographic information.
Third-Party Advertisers. We may use third-party advertising companies to serve advertisements when you visit the Site. These companies may use information about you, including information about your visits to the Site and other Web sites, in order to provide you with advertisements about goods and services that may be of interest to you.
You should consider any communication that you transmit to us as non-confidential and you agree that we are not liable or responsible if information that belongs to you is intercepted and used by an unintended recipient.
Use of Personally Identifiable Information
The types of information that may be collected by us and third-party advertising companies include the following:
the type of Internet browser you use;
the type of computer operating system you use;
the domain name of a Web site you visit, as well as information related to Web sites and Web pages you are viewing when an advertisement is requested;
whether or not you visit specific pages of the Site or other Web sites;
the location of your Internet service provider’s point of presence;
the date and time of a visit to a Web site;
search keywords passed from another server;
the number of times you have clicked on an advertisement; and other interactions between you and a Web site.
Third-Party Advertisers. We may use third-party advertising companies to serve advertisements to you when you visit the Site. We may disclose information about your visits to the Site to third-party advertising companies to market more effectively to you. Our third-party advertising company may link your personally identifiable information, such as your name, address and e-mail address, to other information which they collect, such as past purchase information and your future Web usage from other sites. By providing your personal information on the Site, some of your future Web usage will no longer be anonymous to our third-party advertising company.
Our third-party advertising company may also merge your personally identifiable information with previously collected non-personally identifiable information. In these cases, because our third-party advertising company may link your name, address and e-mail address to your past Web usage, some of your past and future Web activity will no longer be anonymous to the advertising company.
Notwithstanding the foregoing, we reserve the right, and you authorize us, to share or disclose your personally identifiable information when we determine, in our sole discretion, that the disclosure of your personally identifiable information is necessary to identify, contact, or bring legal action against you or if:
you are interfering with another’s rights or property, including, without limitation, our rights or property;
you are violating any applicable law, rule or regulation;
it is in connection with an investigation of fraud;
it is in connection with an effort to safeguard the person or property of one of our employees, agents, or representatives or a third-party;
it is necessary or required by any applicable law, rule or regulation;
it is in response to a subpoena or a court order; and/or
is requested by properly authorized authorities in the event of any act of terrorism or instance of local, regional or national emergency.
You may at any time opt-out of our use of your personally identifiable information by sending an email requesting to opt-out of our use of your personally identifiable information at the following email address: email@example.com. After we process your opt-out request, we will stop using your personally identifiable information.
We manage email lists through List Management Arrangements. You may wish to remove yourself from specific marketing lists and may do so by utilizing the unsubscribe option that is included in each email we send. You may also elect not to receive email from specific senders at any time by utilizing the unsubscribe option that is included in each email the send.
Unsubscribe requests are either processed on an advertiser-specific basis or on a list-specific basis depending on the election that you make when utilizing the unsubscribe option. Unsubscribing from one list managed by us will not remove you from all lists managed by us. Unsubscribing from one advertiser will not prevent you from receiving email from other advertisers.
Please note, however, that after you opt-out of our use of your personally identifiable information, third-parties may continue to use any personally identifiable information that may be in their possession and you may still receive offers from third-parties. You must contact these third-parties directly to opt-out of their use of your personally identifiable information. We are not responsible for any third-party’s use or failure to stop using your personally identifiable information.
Right to Contact Via Telephone
By providing us with your personally identifiable information, agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR 310 et seq.), as amended from time to time (the “Rule”) and you further agree that we may contact you in connection with your requests for products or services, even if you are listed on the National Do Not Call list, as permitted by law. Notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, we reserve the right to contact you via telemarketing in accordance with the Rule.
Newsletters and CAN-SPAM Compliance
We are fully compliant with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (the “CAN-SPAM Act”). We are not responsible for any email communications that you may receive from third-parties.
“Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer’s hard drive. We, our external service providers, internal service providers, and third-party advertising companies, may set and access cookies on your computer to track and store preferential information about you. We, and our external service providers, internal service providers, and third-party advertising companies gather anonymous information about you through cookie technology on an aggregate level only. For example, a third-party advertising company may assign a cookie (and a Web beacon, described below) to you, to limit the amount of times you see a particular advertisement or to help better determine which advertisements to serve to you. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer.
We use log files. Log files are not linked to personally identifiable information, and provide us with the following types of information: internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use.
“Web beacons,” also called single-pixels (1×1) or clear GIFs, are electronic images that allow a website to access cookies and help track marketing campaigns and general usage patterns of visitors to those Web sites. Web beacons can recognize certain types of information, such as cookie numbers, time and date of a page view and a description of the page where the Web beacon is placed.
Internal use of web beacons. We may use web beacons internally to count users and recognize users through cookies. Access to cookies helps us personalize your experience when you visit the Site.
Email. We may include web beacons in HTML-formatted email messages that we or our affiliates or agents send. Including web beacons in email messages helps us determine your interest in and the effectiveness of such emails.
External use of web beacons. We may also use web beacons externally. For example, we may report aggregate information about the Site’s users, such as demographic and usage information, to our partners and other third-parties. We may also include other company’s web beacons within the Site or in emails.
Group Aggregate Data
We reserve the right to provide aggregate or group data about our users for lawful purposes. Aggregate or group data is data that describes the demographics, usage, or characteristics recipients of, and participants in, our email campaigns as a group, without disclosing personally identifiable information.
We protect information we maintain with internal and external firewalls and physical and technological security measures. In certain areas of the Site, we may use industry-standard SSL-encryption to protect data transmissions. For this Site and web sites owned and operated by us, we use log files. These log files may include internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. If an unauthorized third-party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third-party’s ability to view, use or disseminate such information.
Links to Other Web sites
Access and Use of the Site
The Site is intended to be accessed and used only by adults and is not directed to children under the age of 13. We do not knowingly permit registration or submission of personally identifiable information by anyone under the age of 13.
If a material change to our policies for treating your personally identifiable information occurs in the future, we will only use your personally identifiable information collected from the time of the policy change forward for these new purposes unless we have your consent.
Questions or Concerns
Attention: Privacy & Compliance Department
Coloma, MI 49038
Privacy Rights of California Residents
California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our partners in List Management Arrangements to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. Within thirty days of receiving such a request to the email address stated in the Notifications section above, we will provide a list of the categories of personally identifiable information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year and the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this section.
California Consumer Privacy Act Rights
The California Consumer Privacy Act (“CCPA” or the “Act”) confers privacy rights for California consumers and imposes corresponding obligations subject to the Act. The rights conferred to consumers include: the right to know what personal information covered businesses are collecting about them and how that information is being used and shared; the right to delete personal information held by covered businesses; the right to stop the sale of personal information by covered businesses; and the right to non-discrimination in service and price when exercising privacy rights.
The following is intended to explain California consumers’ rights and the obligation Keono has under the CCPA. Keono employees in California should refer to the Privacy Notice in their Associate Handbook.
RIGHT TO KNOW/REQUEST FOR ACCESS TO PERSONAL INFORMATION
As a consumer under the CCPA, you have the right to request that Keono disclose what personal information we collect, use, disclose, and sell about you. We call this your “right to know.”
To take advantage of your right to know, you must submit a request by filling out a request to our online consumer privacy team.
You can submit your request by mail. Our mailing address is:
Consumer Care Advocate
Coloma, MI 49038
To respond to your right to know request, the CCPA permits Keono to verify your identity. This will require that you supply certain personal information for validation as well as satisfactorily answer a series of authentication questions administered through our consumer privacy team. If you mail us and request a consumer access report, an Keono associate will call you to administer an authentication test in which you will be required to answer certain questions to verify your identity.
If we are unable to satisfactorily verify your identity, we will be unable to fulfill your right to know request. In that case, please see the information below concerning Keono’s data collection, maintenance, and sale practices.
TYPES OF PERSONAL INFORMATION KEONO COLLECTS
Right to Know about Personal Information Collected, Disclosed or Sold Business and Commercial Purposes for which Personal Information is Collected: We collect personal information for our own business purposes, including internal research, internal operations, auditing, detecting security incidents, improving our services, quality control, and legal compliance. We also collect personal information for commercial purposes. Keono licenses the categories of personal information described below from the third-party sources categorized below in developing Keono’s marketing and advertising products as previously described. Keono licenses such data products to categories of third parties as described in the table below. Categories of Personal Information Collected
Personal identifiers (e.g., name, alias, postal address, IP address, email address, account name)
Personal Characteristics (e.g., characteristics of protected classifications under California and federal law like race and gender)
Personal Property or Buying Activity/Interest (e.g., commercial or transaction information)
Internet Activity (interest based on web site type, source URL)
Inferences (e.g., inferences drawn to create a profile about a consumer reflecting the consumer’s preferences)
Categories of Sources from Which Personal Information Was Collected Marketing Products Public Record and Publicly Available InformationWebsite DirectoriesWebsite ListingsReal Property Recorder InformationAssessor InformationProfessional License InformationVoter Records (where allowed by law)Information from Other Data BrokersDemographic Marketing InformationSurveys and QuestionnairesSummarized or Aggregated Purchase InformationTelephone CompaniesConsumer-Provided Contact InformationIdentifying Information from Credit Bureaus (where permitted by law)Categories of Third Parties with Which Personal Information is Sold Agriculture, Forestry and Fishing (for example, farm cooperatives)
Automotive (for example, car manufacturers and dealerships)
Business Services/Agency (for example, data brokers)
Communications (for example, wireless carriers)
Construction (for example, real estate development companies)
Consumer Packaged Goods (for example, companies that sell personal and household products)
Education (e.g., colleges and universities)
Energy and Utilities (for example, electric and gas companies)
Entertainment (for example, movie and television studios and streaming services)
Financial Services (for example, banks and investment companies)
Government (for example, state and federal agencies and political parties and candidates)
Healthcare (for example, hospitals)
Insurance (for example, insurance carriers)
Manufacturing (for example, consumer product manufacturers)
Media and Publishing (for example, magazines, retail catalogs)
Non-Profit (for example, charitable organizations)
Real Estate (for example, real estate brokerage companies)
Retail (for example, department stores, hardware stores)
Services-Non Professional (for example, consulting firms)
Services-Professional (for example, advertising agencies and financial planners)
Sports (for example, professional sports teams)
Technology (for example, software and hardware providers, social media platforms)
Transportation (for example, railway companies, airlines, rental car companies)
Travel and Tourism (for example, cruise lines, hotels, online travel services)Categories of Service Providers with Whom Personal Information is Disclosed for a Business PurposeCloud computing and storage vendors; security contractors; consultants, analysis providers, marketing analytics platforms; programmatic advertising marketplaces/platforms; premium social publishers; measurement platforms;
Except for consumer surveys that are used to build our marketing models, Keono does not collect data directly from consumers for use in our data products. Please also note that Keono does not collect biometric information from consumers who are not Keono employees. Lastly, Keono does not collect sensory information such as voice, visual, thermal, olfactory, or similar sensory information.
DISCLOSURE AND SALE OF PERSONAL INFORMATION
During the last year, Keono has sold personal information it has collected to our third-party clients for their business and commercial purposes. More specifically, Keono licenses personal information to our clients for the purpose of enabling marketing and advertising campaigns. We also license personal information for the purpose of identity verification and fraud detection and prevention. Keono does not sell personal information to individual consumers.
During the last year, Keono has disclosed personal information to service providers (e.g., cloud computing and storage vendors; security contractors, consultants and analysis providers), for Keono’s own operational business purposes.
Keono does not sell personal information about consumers younger than 18 for the purpose of marketing or advertising directly to the minor. Keono does use personal information from minors younger than 18 to suppress matching records from marketing lists and to facilitate identity verification and fraud prevention.
RIGHT TO DELETE PERSONAL INFORMATION
Pursuant to the CCPA, California consumers have a right to request deletion of personal information about them that Keono has collected or maintained.
You can also submit your request by mail. Our mailing address is:
Consumer Care Advocate
Coloma, MI 49038
To respond to your right to delete request, the CCPA permits Keono to verify your identity. This will require that you satisfactorily answer a series of authentication questions. This may also require that you submit certain personal information for us to compare and match to data we have about you. If you call or mail us and request deletion of personal information, an Keono associate will call you to administer an authentication test in which you will be required to answer certain questions to verify your identity.
If we are unable to satisfactorily verify your identity, we will either request additional information as permitted by the CCPA or provide a limited response (for example, by providing a report with categories of personal information rather than specific pieces of information). Even assuming a verifiable request, Keono will retain certain personal information in our data products as necessary to comply with a legal obligation (including ensuring the deletion request is honored and CCPA record-keeping obligations), detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for the activity. In such cases, Keono will retain only the minimum amount of information that does not qualify for a statutory or regulatory exception, and only use the remaining data for the purposes provided by the statutory or regulatory exception.
RIGHT TO OPT OUT
California consumers have a right to opt out from Keono selling their personal information for marketing purposes by Keono.
You can also submit your request by mail. Our mailing address is:
Consumer Care Advocate
Coloma, MI 49038
You may also contact the California Attorney General. Please visit https://www.oag.ca.gov/, for more information.
The CCPA requires certain businesses to compile and disclose information by July 1 of each year regarding their compliance with the CCPA for the previous twelve-month period.
CCPA Reporting Requirements Metrics for Interim Reporting Period ending June30, 2021 Total Volume of Requests to Know Received 5 Number of Requests to Know Fulfilled 2 Number of Requests to Know Denied 1 Median Number of Days to Respond to Requests to Know 1 Total Volume of Requests to Delete Received** 5 Number of Requests to Delete Fulfilled 1 Number of Requests to Delete Denied 1 Median Number of Days to Respond to Requests to Delete 1 Total Volume of Requests to Opt-Out Received 4 Number of Opt-Out Requests Fulfilled 9 Number of Opt-Out Requests Denied 0 Median Number of Days to Respond to Requests to Opt-Out** 1 **The total deletion requests received includes requests that were abandoned by the consumer prior to completion of an identity verification process.
**This number reflects the number of days until it is processed. We typically respond and start honoring the request within two (2) days
This CCPA Privacy Notice is effective December 31, 2021.
Governing Law; Arbitration