PRIVACY POLICY

Last Updated: December 31, 2019

Amberman  (the “Company”, “we”, “us”) is committed to protecting the privacy of our customers. This Privacy Policy (the “Policy”) is designed to inform you about the types of personal information we gather (the “Information”), how we may use that Information, how we may disclose that Information, to whom we may disclose that Information, and how we protect that Information. We do not consider Information to include material that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other materials or otherwise, to identify a specific person. The Policy applies to our websites, blogs, applications (mobile or otherwise), social media accounts, forums, technology, software, and/or any other electronic platform now in existence or later developed or used (collectively, the “Platforms”).

This Policy does not apply to third parties that we do not own or control, or to individuals that Amberman does not employ or manage. 

By continuing to use and access our Platforms, you hereby agree to be bound by this Policy. We also have a Terms of Use, which is hereby incorporated into this Policy. You can choose not to share certain Information with us, but it may result in our inability to provide services to or provide special features. Failure to provide certain Information to us may result in your inability to complete a transaction with us. 

INFORMATION THAT WE COLLECT

  • Any Information you provide to us in conjunction with using or purchasing our services or products, or any Information you provide to us thereafter, including name, address, zip code, area code, country, telephone number, email address, birthdate, gender, IP address, browser information, cookies, payment information (e.g., financial institution, credit /debit card number, credit/debit card security code, credit/debit card expiration date, checking account number, checking routing number), and billing address.
  • Information you provide to us, our employees, our agents, our contractors, or our sub-contractors related to your use of our Platforms. For quality and training purposes, as well as compliance purposes, we may monitor or record any conversations with you or anyone acting on your behalf. 
  • Information you enter on forums or other public areas of the Platforms, or transmitted to other users of the Platforms or third parties.  
  • Information obtained about past and contemplated future transactions with us.
  • Information we receive from third parties about you. 
  • Demographic and interest data collected through Google Analytics or a similar analytics system. 

WE COLLECT INFORMATION ABOUT YOU IN THE FOLLOWING WAYS:

Information You Give Us. This includes:

  • The personal data you provide when you register to use our website, including your name, postal address, email address, telephone number, username, password and demographic information (such as your gender);
  • the personal data that may be contained in any video, comment or other submission you upload or post to the website;
  • the personal data you provide in connection with our rewards program and other promotions we run on the website;
  • the personal data you provide when you report a problem with our website or when we provide you with customer support;
  • the personal data you provide when you make a purchase thorough our website; and
  • the personal data you provide when you correspond with us by phone, email or otherwise.

Information from Social Networking Websites. 
Our website includes interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our website, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

Information Automatically Collected. 
We automatically log information about you and your computer or mobile device when you access our website. For example, when visiting our website, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our website, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our website. We collect this information about you using cookies.

Automated Decision Making and Profiling. 
We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.

HOW WE USE THE INFORMATION

  • To provide you with services through our Platforms.
  • To improve our Platforms and services. 
  • To display relevant advertisements and recommendations.
  • To not display irrelevant advertisements and recommendations.
  • To contact you regarding billing information, customer service issues, to send alerts, to solicit reviews, to send promotional and informational messages. 
  • To measure traffic and usage trends on our Platforms, including webpages you visit, add-ons you use, and other information that assists us in improving our Platforms. 
  • For any other purpose for which you provide consent. 

PURPOSES OF PROCESSING

  • What is personal data?
    We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation, this includes any information which, either alone or in combination with other information we process about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
  • Why do we need your personal data?
    We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to our Platforms. If you registered with us, you will have been asked to tick to agree to provide this information in order to access our services, purchase our products, or view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Platforms.

USING YOUR PERSONAL DATA

We may use your personal data as follows:

  • to operate, maintain, and improve our website, products, and services;
  • to manage your account, including to communicate with you regarding your account, if you have an account on our website;
  • to operate and administer our rewards program and other promotions you participate in on our website;
  • to respond to your comments and questions and to provide customer service;
  • to send information including technical notices, updates, security alerts, and support and administrative messages;
  • with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
  • to process payments you make via our website;
  • as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others;
  • for analysis and study services; and
  • as described in the “Sharing of your Personal Data” section below.

DISCLOSURE OF THE INFORMATION

We may share, sell, rent, or trade your Information to the following third parties and for the following purposes:

  • Members of our corporate family (parents, subsidiaries, related and affiliated companies).
  • Employees, contractors, subcontractors.
  • Businesses that sell items through our Platform. 
  • To third parties to market their products or services to you.
  • Vendors that provide services to us.
  • Financial institutions that provide us with capital.
  • Auditors.
  • Payment network request.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request. 
  • Any potential investors, buyers, or other successor in the event of a merger, divestiture, restructuring, or other sale or transfer of assets, whether as a going concern or as part of bankruptcy or similar proceeding, in which personal information about our customers is among the assets transferred. 
  • To enforce or apply our Terms and Use or and other agreements with us, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

SHARING YOUR PERSONAL DATA

We may share your personal data as follows:

  • Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
  • Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services.
  • Third Party Sites

Our website may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.

USER GENERATED CONTENT

You may share personal data with us when you submit user generated content to our website, including via our rewards program, forums, message boards and blogs on our website. Please note that any information you post or disclose on our website will become public information, and will be available to other users of our website and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on our website. Such personal data and other information will not be private or confidential once it is published on our website.

If you provide feedback to us, we may use and disclose such feedback on our website, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first and last name along with your feedback on our website. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.

COMMUNICATIONS FROM US

By agreeing to this Policy, you give us consent to contact you at the mailing address, telephone (cellular or landline) number, text/SMS number, email address, or fax number that you provide during the sign-up process or that you provide to use thereafter. Any such communications may be transactional, informational, or promotional in nature. 

None of the aforementioned communications are a condition for using our Platforms (unless confirmation or deliver is required). If you wish to stop receiving any communications from us, please contact us at [email protected] and let us know the type of communication you wish to stop receiving and the appropriate telephone number, email address, or other contact method to designate as restricted. 

COOKIES AND OTHER TRACKING TOOLS

We and our designated third parties (including advertisers) may use several tracking tools, such as cookies, to collect usage and demographic data about you over time through our Platforms. Your browser may store cookies or other information on your computer in a small file. 

We and our designated third parties (including advertisers) may also use software technology such as GIFs (e.g., web beacons or web bugs). These are placed in the code of a webpage or an email newsletter. When you access a partner site within our Platform, we may track your activity on that site.  

We may use technologies to help determine your physical location, such IP address mapping, Wi-Fi, GPS signals, cell tower positioning, and other technologies to improve and personalize your experience. 

We do not control third party tracking technologies or how they may be used. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

WHAT ARE COOKIES?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our website.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our website; and (2) third party cookies, which are served by service providers on our website, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

COOKIES WE USE
Our Platforms use the following types of cookies for the purposes set out below:

Type of cookie Purpose
Essential Cookies These cookies are essential to provide you with services available through our website and to enable you to use some of its features. For example, they allow you to log in to secure areas of our website and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies These cookies allow our website to remember choices you make when you use our website, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our website which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our website.
Analytics and Performance Cookies These cookies are used to collect information about traffic to our website and how users use our website. The information gathered does not identify any individual visitor. It includes the number of visitors to our website, the websites that referred them to our website, the pages they visited on our website, what time of day they visited our website, whether they have visited our website before, and other similar information. We use this information to help operate our website more efficiently, to gather broad demographic information and to monitor the level of activity on our website.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our website works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

You can find out more about how Google protects your data here: https://policies.google.com/privacy.

You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Targeted and advertising cookies These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.

You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
Social Media Cookies These cookies are used when you share information using a social media sharing button or “like” button on our website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

DISABLING COOKIES

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our website. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our website.

ADVERTISING

We may use other companies to serve third-party advertisements when you visit and use the website. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the website and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.

DO NOT TRACK NOTIFICATIONS

While some web browsers may have a “Do Not Track” feature, we do not alter our behavior or change our services based upon receiving a “Do Not Track” request. Such a feature is the responsibility of the browser. 

CHILDREN’S PRIVACY

You must be 18 years old to use of Platforms. Our Platforms are not intended for children and therefore do not knowingly collect Information from children under the age of 16 years. If we become aware that a child under 16 years of age has provided us with Information, we shall take immediate steps to delete such Information. 

If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.

OTHER WEBSITES

Our website may include links to third-party websites or you may be directed to third-party websites. Those third-party websites may have privacy practices and policies different from ours. We are not responsible for the policies or practices of any third-party website. We encourage you to carefully read the privacy policy of any website you visit.

SECURITY

The security of the Information is important to us, which is why we take measures to reasonably protect it. We limit access to Information we received to those third parties who we believe have a legitimate business or legal purpose to access such information. We maintain physical, electronic, and procedural safeguards to keep Information safe. We also require companies and individuals working with and for us to protect such Information, and that they agree to use it only for limited and designated purposes. 

Please be aware that transmission of information over the internet is not completely secure, no security measures are perfect or impenetrable. We cannot guarantee the security of your Information and are not responsible for circumvention of any privacy settings or security measures contained on the Platforms. Additionally, we cannot control the actions of other users of the Platforms with whom you may choose to share your Information. Any transmission of Information is at your own risk.

We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.

MERGER OR ACQUISITION

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we shall notify you with a prominent notice on our website of any change in ownership or uses of your Information, as well as any choices you may have regarding your Information. 

CONSENT TO INTERNATIONAL TRANSFER

Information we collect may be transferred, stored, or processed in any country in which we or our corporate family, third party service providers, or agents maintain facilities. By using our services, you consent to any such transfer, storage, and processing of information. 

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By accepting this Policy, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

DATA RETENTION

We will retain your Information as long as we have a legitimate business purpose to do so. If you have any questions about your account with us or want us to no longer use your Information, contact us at [email protected]. We will make commercially reasonable efforts to honor your request, to the extent that it does not interfere with our use of your Information to comply with our legal and business obligations, resolve disputes, and enforce any agreements.  

We will only retain your personal data as long reasonably required for you to use our Platforms until you close your account/cancel your subscription unless a longer retention period is required or permitted by law (for example for regulatory purposes).

OPT-OUT REQUESTS

To opt out of tracking tools and online behavioral advertising, click here. This means that we will no longer use Information collected from your online activity collected by us to improve our ability to advertise towards you. To be clear, this does not mean that you will no longer receive any advertising from us or third parties; rather it means that any advertisements from us will not be based on your particular interests. Additionally, we may still collect Information for other purposes consistent with this Policy. 

YOUR RIGHTS

  • Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the website may be ineffective upon opt-out.
  • Access. You may access the information we hold about you at any time via your profile/account or by contacting us directly.
  • Amend. You can also contact us to update or correct any inaccuracies in your personal data.
  • Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
  • Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

CALIFORNIA PRIVACY RIGHTS

California Civil Code § 1978.83 permits users of our Platforms, who are California residents, to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. 

COMPLAINS

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us through the information listed on our website. We will reply to your complaint as soon as we can and in any event, within 30 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.

If you are in the European Union, you can choose to lodge a complaint with your local Data Protection Authority (DPA). The list of DPAs is at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

CHANGES TO THIS POLICY

We reserve the right to modify this Policy at any time and without prior notice. If we decide to change our Policy, we will conspicuously post a link to the updated Policy in places on our Website that we deem appropriate so that you are aware of what Information we collect, how we use it, and under what circumstances, if any, we disclose it. By continuing to use our Platforms, you consent to any such changes. 

CONTACT US

Amberman

650 South Hill Street, Suite 513

Los Angeles, California 90014

[email protected]