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Privacy Notice
Privacy Notice
Effective date: December 1, 2024
Updated date: December 1, 2024 v1
At Furniture Values International, LLC, ("Co"), Co cares about privacy, transparency, and being upfront about Co's privacy practices, including how Co treats your personal information. This privacy notice explains what, how, and what is done with personal information Co collects when you engage with any online services and when Co provides you services (collectively, the "Service").
In the event of a conflict between any other Co policy, notice, or statement and this Notice, this Notice will prevail as to Consumers unless stated otherwise. This Notice also applies to "Consumers" as defined under applicable U.S. State (e.g., California) Consumer Privacy Laws including regulations promulgated thereunder (collectively, "U.S. Privacy Laws"). Capitalized terms used but not defined in this Notice shall have the meanings given to them under U.S. Privacy Laws.
Topics Covered:
  • 1.When & How Co Collects Personal Information
  • 2.How Co Uses Your Personal Information
  • 3.Information We Share with Third Parties
  • 4.Security, Monitoring, and Data Retention
  • 5.International Transfer
  • 6.State Privacy Rights
  • A.Notice of Data Practices
  • B.Your Consumer Rights and How to Exercise Them
  • C.Non-Discrimination/non-retaliation
  • D.Notice of Financial Incentive Programs
  • E.Co's Rights and the Rights of Others
  • F.Additional Notices for California Residents
  • 7.Choices: Cookies, Tracking, and Communications Options
  • 8.Children's Privacy
  • 9.Changes to this Privacy Notice
  • 10.Contact Us
Definitions:
Definition of Personal Information ("PI") and Sensitive Personal Information ("SPI"):
  • A. PI - Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household as specified under certain U.S. Privacy Laws. PI includes "Personal Information" and "Personal Data" ("PD") as those terms are defined under certain U.S. Privacy Laws.
    Note: For the purposes of this document, PI and PD are considered PI.
  • B. SPI - Is a specific category of PI covered under certain U.S. Privacy Laws. SPI includes information that if accessed without authorization could result in financial impact to consumer.
1. When & How Co Collects Personal Information
Co collects information when you engage with Co - sometimes you provide Co with information, and sometimes information about you is collected automatically.
Co may collect information when:
  • You browse any page of Co's Website
  • You reach out to Co through Co's online "Contact Us" or "Become a Dealer" forms
  • You register and login to Co's online portal
A. PI that You May Provide
Co, its Service Providers (defined below) and/or Third-Party Services (when you interact with Third-Party Services) may collect a.) Personal Information ("PI") which identifies you personally such as your name, e-mail address, phone number, address, and payment information.; In addition, PI, including, without limitation, Co-Collected PI (defined below), once "De-identified" (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements including through anonymization, pseudonymization, and/or hashing) is also non-PI and may be used and shared without obligation to you, except as prohibited by applicable law. However, we do not make assurances that De-identified data is not capable of re-identification. To the extent any non-PI, or PI collected outside of the Service, is combined by or on behalf of Co with PI Co itself collects directly from you on the Service ("Co-Collected PI"), Co will treat the combined data as Co-Collected PI under this Privacy Notice. Residents of various states with U.S. Privacy Laws can learn more about their privacy rights described herein. b.) Additionally, Co, it's Service Providers and/or Third-Party Services may also collect SPI for certain Consumers (as defined in chart below).
B.Information Collected Automatically
Co, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service ("Usage Information"). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Co with Co-Collected PI, Co does not consider Usage Information (including, without limitation, unique device identifiers) to be PI or Co-Collected PI.
The methods that may be used on the Service to collect Usage Information include:
  • Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
  • Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, device recognition technologies, device and activity monitoring and other tracking technologies now and hereafter developed ("Tracking Technologies") may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
Some information about your use of the Service and certain other online services may be collected using Tracking Technologies across time and services and used by Co and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain other online services. See below section regarding certain choices regarding these activities.
Co is giving you notice of the Tracking Technologies and your choices regarding them explained below so that your consent to encountering them is meaningfully informed.
2. How Co Uses Your Personal Information
Co may use information about you, including Co-Collected PI and PI, for any purposes not inconsistent with Co's statements under this Privacy Notice, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:
  • a)Allow you to participate in the features we offer on the Service.
  • b)Responding to inquiries about locating a dealer near you.
  • c)Responding to inquiries about becoming a dealer or Sales Representative.
  • d)To transact with you, provide services or information you request, respond to your comments, questions and requests, send you notices, and register or provide warranty services.
  • e)To enable interactions with Co's Dealers and Sales Representatives interactions and providing support to facilitate online purchases of Co's products, process shipping and returns, register and administer your account, provide you with and support your interactions with Co, diagnose, repair and track service and quality issues, facilitate an order, provide requested product information, communicate with you and authenticate your interaction with Co.
  • f)Marketing - With Co's Dealers' and Sales Representatives' consent, periodically sending promotional emails about new products, special offers or other information which Co thinks you may find interesting using the email address which you have provided. To opt-out of receiving promotional email messages from Co, please click on the "Unsubscribe" link contained at the bottom of each email or by using the information in the "Contact Us" section below.
  • g)For Co's own business purposes, including administering and improving effectiveness of: Co's Service, your Service browsing experience including landing pages, and testing Service features.
  • h)For legal, safety or security reasons, complying with legal requirements, protecting the property, or rights of Co, detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity.
3. Information We Share with Third Parties
Personal data is shared according to the safeguards and practices detailed in this Privacy Notice.
Except as restricted by applicable law, this Privacy Notice, or any other representation Co makes to you, Co may share non-PI, and PI that is not deemed Co-Collected PI hereunder (provided that Co is aware of no restrictions of Co's use, if any), with third parties or Co companies and their affiliates ("Co Affiliates") for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your PI, including Co-Collected PI, to non-PI, including without limitation through hashing it or substituting a unique identifier for the PI and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices. Co's sharing of Co-Collected PI is, however, subject to the following:
  • Marketing: Subject to your communications choices explained herein, and the rights of California residents explained below, we may use your PI to send you marketing communications. Co will not share your Co-Collected PI with third parties, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below) absent your consent (which may be by means of third-party interaction described in the next bullet point).
  • Your Disclosure or Consent: Your activities on the Service may, by their nature, result in the sharing of your Co-Collected PI (as well as your other PI and your non-PI) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not Co.
Co may also share any information about you (including, without limitation, Co-Collected PI) for any purposes not inconsistent with this Privacy Notice, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation:
  • Co's agents, vendors, consultants, and other service providers (collectively "Service Providers") may receive, or be given access to, your information, including, without limitation, PI, and Usage Information, in connection with their work on Co's behalf, provided however, Co does not authorize its Service Providers to use Co-Collected PI provided by Co to the Service Providers to send you direct marketing messages other than related to Co and Co Affiliates absent your consent. For more information on choices Service Providers may offer you, see below.
  • To comply with the law and, where permitted, in response to a government request.
  • If Co believes your actions are inconsistent with Co's terms of use, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of Co, the Service or its users, or any third party.
In addition, Co may share your Co-Collected PI (as well as your other PI and your non-PI), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Co's assets, or transfer of all or a portion of Co's business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding ("Corporate Transactions").
4. Security, Monitoring, and Data Retention
Co provides and maintains reasonable security procedures and technical and organizational measures to protect Co-Collected PI against accidental or unlawful loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Co does not guarantee the security of your information collected through the Service.
To help protect you and others, Co and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including Co-Collected PI and other PI for all purposes not prohibited by applicable law or inconsistent with this Privacy Notice, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Service; ensure compliance with Privacy Notice; investigate violations of or enforce these documents; improve your Services, and to protect the rights and property of Co, Co-Affiliates, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.
Co will only retain your information for as long as necessary for the purposes set out in this Notice.
5. International Transfer
Co is based in the U.S. and the information Co and its Service Providers collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including PI, in the U.S. as set forth in this Privacy Notice.
6. State Privacy Rights
This Notice applies to Consumers:
Consumers can be defined differently depending on the state you reside in.
  • a) In all States, a person who is acting in an individual or household context and ultimately inquiring about or purchasing our product (collectively, "End-Consumer" or "EC");
  • or
  • b) In California only, Consumer also includes CA job applicants, current employees, former employees, or CA independent contractors and CA business to business contacts (collectively, "Non-End-Consumer" or "NEC").
A. Notice of Data Practices
This Notice serves as our notice at collection. We may Collect your PI directly from you; your devices; our affiliates; service providers; public sources of data; credit reporting agencies; or other businesses or individuals. Generally, we Process your PI to provide you services and as otherwise related to the operation of our business, including for one or more of the following Business Purposes: Performing Services; Managing Interactions and Transactions; Security; Debugging; Advertising & Marketing; Quality Assurance; Processing Interactions and Transactions; and Research and Development. We may also use PI for other Business Purposes in a context that is not a Sale or Share under U.S. Privacy Laws, such as disclosing it to our Service Providers, Contractors, or Processors that perform services for us ("Vendors"), to the Consumer or to other parties at the Consumer's direction or through the Consumer's action; for the additional purposes explained at the time of collection (such as in the applicable privacy policy or notice); as required or permitted by applicable law; to the government or private parties to comply with law or legal process or protect or enforce legal rights or obligations or prevent harm; and to assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business ("Corporate Transaction") ("Additional Business Purposes"). Subject to restrictions and obligations under U.S. Privacy Laws, our Vendors may also use your PI for Business Purposes and Additional Business Purposes and may engage their own vendors to enable them to perform services for us.
We do not currently "Sell" or "Share" as defined by applicable U.S. Privacy Laws, your PI. "Share" is transferring a consumer's PI to a third party, for the purpose of cross context behavioral advertising online.
We provide more detail on our data practices in the two charts that follow.
  • a) Category of PI, Categories of Recipients Disclosure of Collection, Consumer and Retention
We collect, disclose, and retain some PI and SPI as follows:
Category of PI Examples Categories of Recipients & Marked Yes or Not Processed Consumer Retention
1. Identifiers Real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address, e-mail address, and account name. Disclosures for Business Purposes: Yes Processed
  • • Vendors (e.g., data analytics providers, payment processors, and marketing services providers);
  • • Other members of our corporate group.
  • • Governmental entities; and/or
  • • Other parties (e.g., litigants) within the limits of Additional Business Purposes.
Sale/Share: No/No
EC/NEC Retained for as long as we have a legitimate purpose.
2. Personal Records Name, signature, description, address, telephone number, and financial information (e.g., payment card information). Some PI included in this category may overlap with other categories. Disclosures for Business Purposes: Yes Processed
  • • Vendors (e.g., data analytics providers, payment processors, and marketing services providers);
  • • Other members of our corporate group.
  • • Governmental entities; and/or
  • • Other parties (e.g., litigants) within the limits of Additional Business Purposes.
Sale/Share: No/No
EC/NEC Retained for as long as we have a legitimate purpose.
3. Personal Characteristics & Demographics PI when not in a protected class such as: DOB, Marital Status, Gender ect… Disclosures for Business Purposes: Yes Processed
  • • Vendors (e.g., data analytics providers, payment processors, and marketing services providers);
  • • Other members of our corporate group; and/or
  • • Governmental entities; and/or
  • • Other parties (e.g., litigants) within the limits of Additional Business Purposes.
Sale/Share: No/No
NEC Retained for as long as we have a legitimate purpose.
4. Customer Account Details/Commercial Information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Disclosures for Business Purposes: Yes Processed
  • • Vendors (e.g., data analytics providers, payment processors, and marketing services providers);
  • • Other members of our corporate group; and/or
  • • Other parties (e.g., litigants) within the limits of Additional Business Purposes.
Sale/Share: No/No
EC Retained for as long as we have a legitimate purpose.
5. Internet Usage Information When you browse our website or otherwise interact with us online, we may Collect browsing history, search history, and other information regarding your interaction with our website, applications, or advertisements. Disclosures for Business Purposes: Yes Processed
  • • Vendors (e.g., data analytics providers, payment processors, and marketing services providers);
  • • Other members of our corporate group; and/or
  • • Other parties (e.g., litigants) within the limits of Additional Business Purposes.
Sale/Share: No/No
EC Cookies website cookies retention 30 days. Encrypted IP addresses and other information is retained for as long as we have a legitimate purpose.
6. Geolocation Data If you interact with us online we may gain access to the approximate location of the device or equipment you are using. Disclosures for Business Purposes: Yes Processed
  • • Vendors (e.g., data analytics providers, payment processors, and marketing services providers);
  • • Other members of our corporate group; and/or
  • • Other parties (e.g., litigants) within the limits of Additional Business Purposes.
Sale/Share: No/No
EC/NEC No retention, if necessary, will be retained for as long as we have a legitimate purpose.
7. Sensory Data We may gather warranty or similar information by audio means when you contact us through our customer service. Disclosures for Business Purposes: Yes Processed
  • • Vendors (e.g., data analytics providers, payment processors, and marketing services providers);
  • • Other members of our corporate group; and/or
  • • Other parties (e.g., litigants) within the limits of Additional Business Purposes.
Sale/Share: No/No
EC No retention, if necessary, will be retained for as long as we have a legitimate purpose.
8. Professional or Employment Information Professional, educational, or employment-related information. Disclosures for Business Purposes: Yes Processed
  • • Vendors (e.g., data analytics providers, payment processors, and benefits providers);
  • • Other members of our corporate group.
  • • Governmental entities; and/or
  • • Other parties (e.g., litigants) within the limits of Additional Business Purposes.
Sale/Share: No/No
NEC Retained for as long as we have a legitimate purpose.
9. Inferences from PI Collected Inferences drawn from PI to create a profile about a Consumer reflecting characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Disclosures for Business Purposes: Not Processed
  • • Vendors (e.g., data analytics providers, payment processors, and marketing services providers);
  • • Other members of our corporate group; and/or
  • • Other parties (e.g., litigants) within the limits of Additional Business Purposes.
Sale/Share: No/No
EC Retained for as long as we have a legitimate purpose.
Category of SPI Examples Categories of Recipients & Marked Yes or Not Processed Consumer Retention
1. Government Issued ID Numbers Social security, driver's license, state ID card, or passport number Disclosures for Business Purposes: Yes Processed
  • • Operational Service Providers;
  • • Benefits Providers;
  • • Corporate Recipients;
  • • Government; and/or
  • • Other Business Recipients.
Sale/Share: No/No
NEC Retained for as long as we have a legitimate purpose.
2. Account Log-In Username and password to online account with Co. Disclosures for Business Purposes: Yes Processed
  • • Operational Service Providers;
  • • Benefits Providers;
  • • Corporate Recipients;
  • • Government; and/or
  • • Other Business Recipients.
Sale/Share: No/No
NEC Retained for as long as we have a legitimate purpose.
3. Precise Geolocation Any data that is derived from a device and that is used or intended to be used to locate an individual w/in a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet Disclosures for Business Purposes: Not Processed
  • • Operational Service Providers;
  • • Benefits Providers;
  • • Corporate Recipients;
  • • Government; and/or
  • • Other Business Recipients.
Sale/Share: No/No
EC/NEC Retained for as long as we have a legitimate purpose.
4. Sensitive Personal Characteristics SPI when in a Protected class such as: DOB, Maritial Status, Gender, Racial or ethnic origin, religious or philosophical beliefs, or union membership. Disclosures for Business Purposes: Not Processed
  • • Operational Service Providers;
  • • Benefits Providers;
  • • Corporate Recipients;
  • • Government; and/or
  • • Other Business Recipients.
Sale/Share: No/No
NEC Retained for as long as we have a legitimate purpose.
5. Communication Content On corporate owned or controlled devices or accounts we may collect contents of mail, email, and text messages, other than where Co. is the intended recipient of the communication Disclosures for Business Purposes: Yes Processed
  • • Operational Service Providers;
  • • Benefits Providers;
  • • Corporate Recipients;
  • • Government; and/or
  • • Other Business Recipients.
Sale/Share: No/No
NEC Retained for as long as we have a legitimate purpose.
6. Biometric Information Fingerprints for personnel authentication. (For the purpose of uniquely identifying an individual) Disclosures for Business Purposes: Not Processed
  • • Operational Service Providers;
  • • Benefits Providers;
  • • Corporate Recipients;
  • • Government; and/or
  • • Other Business Recipients.
Sale/Share: No/No
NEC Retained for as long as we have a legitimate purpose.
7. Health Information Personal Information collected and analyzed concerning an individual's health. Disclosures for Business Purposes: Yes Processed
  • • Operational Service Providers;
  • • Benefits Providers;
  • • Corporate Recipients;
  • • Government; and/or
  • • Other Business Recipients.
Sale/Share: No/No
NEC Retained for as long as we have a legitimate purpose.
There may be additional information we Collect that meets the definition of PI under applicable U.S. Privacy Laws but is not reflected by a category above, in which case we will treat it as PI as required but will not include it when we describe our practices by PI category.
As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and Co may elect not to treat publicly available information as PI. We will not attempt to reidentify data that we maintain as deidentified. We note our general PI retention rules by category of PI in the chart above. However, because there are numerous types of PI in each category, and various uses for each PI type, actual retention periods vary. We retain specific PI pieces based on how long we have a legitimate purpose for the retention.
B. Your Consumer Rights and How To Exercise Them
As described and defined below, subject to meeting requirements for a Verifiable Consumer Request, ("VCR"), Co provides Consumer privacy rights to consumers residing in states with U.S. Privacy Laws and states that pass substantially similar laws.
The Consumer rights we accommodate are as follows:
Right to Limit Sensitive PI Processing
We only Process SPI for purposes that are exempt from Consumer choice under U.S. Privacy Laws.
Right to Know/Access
Consumers are entitled to access PI up to twice in a 12-month period with subsequent requests subject to a service fee.
(1) Categories (available for California Residents Only)
California residents have a right to submit a request for any of the following for the period that is 12-months prior to the request date:
  • The categories of PI we have Collected about you.
  • The categories of sources from which we Collected your PI.
  • The Business Purposes or Commercial Purposes for our Collecting, Selling, or Sharing your PI.
  • The categories of Third Parties to whom we have disclosed your PI.
  • A list of the categories of PI disclosed for a Business Purpose and, for each, the categories of recipients, or that no disclosure occurred.
  • A list of the categories of PI Sold or Shared about you and, for each, the categories of recipients, or that no Sale or Share occurred.
Confirm Processing
You may request to confirm if we are processing your PI.
Specific Pieces
If relevant, you may request a transportable copy, subject to applicable request limits, of your PI that we have Collected and are maintaining. For your specific pieces of PI, as required by applicable U.S. Privacy Laws, we will apply the heightened verification standards as described herein. We have no obligation to re-identify information or to keep PI longer than we need it or are required to by applicable law to comply with access requests.
Do Not Sell / Share / Target
Under the various U.S. Privacy Laws there are broad and differing concepts of "Selling" PI for which an opt-out is required. California also has an opt-out from "Sharing" for Cross-Context Behavioral Advertising (use of PI from different businesses or services to target advertisements). Other states have an opt-out of "Targeted Advertising" (defined differently but also addressing tracking, profiling, and targeting of advertisements). We do not Sell or Share your PI and/or use your PI for Targeted Advertising, as these terms apply under U.S. Privacy Laws.We may disclose your PI for the following purposes, which are not a Sale or Share: (i) if you direct us to disclose PI; (ii) to comply with a Consumer rights request you submit to us; (iii) disclosures amongst the entities that constitute Co as defined above, or as part of a Corporate Transaction; and (iv) as otherwise required or permitted by applicable law.
Right to Delete
Except to the extent we have a basis for retention under applicable law, you may request that we delete your PI. Our retention rights include, without limitation:
  • to complete transactions and services you have requested;
  • for security purposes;
  • for legitimate internal Business Purposes (e.g., maintaining business records);
  • to comply with law and to cooperate with law enforcement; and
  • to exercise or defend legal claims.
Note also that, depending on where you reside, we may not be required to delete your PI that we did not Collect directly from you.
Correct Your PI
Consumers may bring inaccuracies they find in their PI that we maintain to our attention, and we will act upon such a complaint as required by applicable law.
Automated Decision Making/Profiling
We do not engage in Automated Decision Making or Profiling.
How to Exercise Your Consumer Privacy Rights
To exercise your Consumer privacy rights, you or an authorized agent, should contact us through the methods described in the "Contact Us" section. Please be aware that we do not accept or process requests through other means.
Your Request Must be a VCR
As permitted or required by applicable U.S. Privacy Laws, any request you submit to us must be a VCR, meaning when you make a request, we may ask you to provide verifying information, such as your name, e-mail, phone number and/or account information. We will review the information provided and may request additional information (e.g., transaction history) to ensure we are interacting with the correct individual. We do not verify opt-outs of Sell/Share/Target or Limitation of SPI requests unless we suspect fraud.
We verify each request as follows:
  • Right to Know (Categories) (available for California residents only): We verify your Request to Know Categories of PI to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you. If we cannot do so, we will refer you to this Notice for a general description of our data practices.
  • Right to Know (Specific Pieces): We verify your Request To Know Specific Pieces of PI to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you together with a signed declaration under penalty of perjury that you are the Consumer whose PI is the subject of the request. If you fail to provide requested information, we will be unable to verify you sufficiently to honor your request, but we will then treat it as a Right to Know Categories Request if you are a California resident.
  • Do Not Sell/Share/Target & Limit SPI: No specific verification required unless we suspect fraud. We do not Sell or Share your PI and/or use your PI for Targeted Advertising, and we only Process SPI for purposes that are exempt from Consumer choice under U.S. Privacy Laws.
  • Right to Delete: We verify your Request to Delete to a reasonable degree of certainty, which may include matching at least two reliable data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three reliable data points provided by you with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized deletion. If we cannot verify you sufficiently to honor a deletion request, you can still make a Do Not Sell/Share/Target and/or Limit SPI request.
  • Correction: We verify your Request to Correct PI to a reasonable degree of certainty, which may include matching at least two reliable data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three reliable data points provided by you with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized correction.
To protect Consumers, if we are unable to verify you sufficiently, we will be unable to honor your request. We will use PI provided in a VCR only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
Agent Requests
You may use an authorized agent to make a request for you, subject to our verification of the agent, the agent's authority to submit requests on your behalf, and of you. You may contact us through the methods described in the "Contact Us" section. Once your agent's authority is confirmed, they may exercise rights on your behalf subject to the agency requirements of applicable U.S. Privacy Laws.
Appeals
You may appeal Co's decision regarding a request by responding to the decision and providing us with additional information to consider.
Our Responses
Some PI that we maintain is insufficiently specific for us to be able to associate it with a verified Consumer (e.g., clickstream data tied only to a pseudonymous browser ID). We do not include that PI in response to those requests. If we deny a request, in whole or in part, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer PI that we Process to respond to your Consumer request(s). In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request. Consistent with applicable U.S. Privacy Laws and our interest in the security of your PI, we will not deliver to you any SPI in response to a Consumer privacy rights request.
C. Non-Discrimination/Non-Retaliation
We will not discriminate or retaliate against you in a manner prohibited by applicable U.S. Privacy Laws for your exercise of your Consumer privacy rights. We may charge a different price or rate, or offer a different level or quality of goods or service, to the extent that doing so is reasonably related to the value of the applicable PI.
D. Notice Of Financial Incentive Programs
If we offer discounts or rewards to Consumers for providing us PI, or set price or service differences related to the collection, retention, sale, or sharing of PI, we will provide you a notice of financial incentive as required by law.
E. Co's Rights and The Rights Of Others
Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your rights under U.S. Privacy Laws. In addition, we are not required to honor your requests to the extent that doing so would infringe upon Co's or another person's or party's rights or conflict with applicable law.
F. Additional Notices for California Residents
In addition to the CCPA, certain Californians are entitled to certain other notices, as follows: This Notice provides information on our online practices and your California rights specific to our online services. Without limitation, Californians that visit our online services and seek to acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:
California Minors
Although our services are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our services, and posted content on the service, can request removal by contacting us at the methods in the "Contact Us" section, detailing where the content is posted and attesting you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines we do not control.
Shine the Light
We do not share personal information as defined by California Civil Code Section 1798.83 ("Shine The Light Law") with third parties for their direct marketing purposes absent your consent. To opt-out of future sharing with third parties for their direct marking purposes, contact us using the methods in "Contact Us" section. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us at compliance@aspenhome.net or by sending a letter to 601 N 75 Ave, Phoenix, AZ 85043, (Attention: Compliance Department). Any such request must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.
7. Cookie Notice and Choices: Cookies, Tracking, and Communications Options
Co may use cookies on Service (or website).
This Cookie Notice provides detailed information about how we use cookies and tracking technologies:
a) What is a cookie and why does Co use them?
Cookies are small pieces of data that are stored on your computer or other device when websites are loaded in a browser.
They are used to provide Service functionality, provide analytics, and to "remember" you and your preferences. Some cookies may be used to "remember" you across devices.
  • Session Cookie - single visit (through a "session cookie"). They are temporary and are erased after you close your web browser.
  • Persistent Cookie - multiple repeat visits (using a "persistent cookie"). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in.
Both websites and HTML emails may also contain other tracking technologies such as "web beacons" or "pixels." These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.
b) What kind of cookies does Co use?
The website may use various types of cookies, identified below, to improve the users experience or Co ability to service you better. Cookies may be essential to the functionality of the Service, or to track your preferences, or for advertising and analytics. Any of these may be first-party cookies or third-party cookies. We or our third-party service providers may use "cookies" to collect information about your and other visitor's browsing behavior such as IP address, type of browser used, domain name and pages visited in order to better serve you.
The following is a list identifying some types of cookies and whether this Co may be using them as identified with an "( X )":
  • ( X ) Strictly Necessary Cookies: These are cookies without which you would not be able to use this site. For example, Strictly Necessary Cookies adjust the website data transmitted to match your Internet connection, get you to the secure versions of the website and help provide services you specifically request. If you set your browser to block these cookies, some parts of the website will not work. Strictly Necessary Cookies do not store any Personal Information.
  • (__) Performance Cookies: We may use these cookies to count visits and traffic sources, to measure and improve website performance. They help us to know which pages are the most and least popular and see how visitors move around the website. Performance Cookies do not store any Personal Information.
  • ( X ) Functional Cookies: These cookies allow the website to remember choices you make and provide enhanced functionality and more personalized features. Depending on context, Functional Cookies may store certain types of Personal Information as needed to provide functionality.
  • (__) Targeting Cookies: Targeting cookies help us manage and display our advertisements, based on your activity on the website and other websites; this is known as interest-based advertising. Targeting cookies mainly rely on uniquely identifying your browser and internet device. Opting out of interest-based advertising does not mean you will no longer see advertising online, but it does mean that the companies from which you opt out will no longer show ads that have been tailored to your interests.
c) Managing and controlling cookies
Most web browsers let you choose whether to accept cookies and may also let you delete cookies already set. Such browser settings are typically found in the "options", "tools" or "preferences" menu. You may also consult the browser's "help" menu.
There are online tools available for clearing all cookies left behind by the websites you have visited, such as www.allaboutcookies.org, and most advertising networks offer you a way to opt out of Interest Based Advertising. If you would like to find out more information, please visit www.aboutads.info/choices or www.youronlinechoices.com. We do not represent that these third-party tools, programs or statements are complete or accurate. You will need to do this on each browser that you use to access our Services, and clearing cookies on your browser(s) may disable your preference settings. Also, our Services may not function properly or as intended if you block all or even certain cookies.
Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no consensus among industry participants as to what "Do Not Track" means in this context. Like many online services, Co currently does not alter Co's practices when Co receives a "Do Not Track" signal from a visitor's browser. To find out more about "Do Not Track," you can visit www.allaboutdnt.com, but Co is not responsible for the completeness or accuracy of this third-party information. Some third parties, however, may offer you choices regarding their Tracking Technologies.
You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled "Tell our customers not to measure your use of their websites or tailor their online ads for you."
We may also use Microsoft Advertising Services. To learn about the data Microsoft collects and how your data is used by it and to opt-out of certain Microsoft browser Interest-based Advertising, please visit https://account.microsoft.com/privacy/ad-settings/.
We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to optout of certain Google browser Interest-Based Advertising, please visit http://www.google.com/settings/ads.
In addition, we may serve ads on other online services that are targeted to reach people on those services that are also identified on one of more of our databases ("Matched List Ads"). This is done by using Tracking Technologies or by matching common factors between our databases and the databases of the other online services. For instance, we may use such ad services offered by Facebook or X (Twitter) and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, and find out what options Facebook offers you to control such ads. If we use X (Twitter) Matched List Ads, you should be able to review your ad options in account settings on X (Twitter). You may submit a do not sell request to the third party. We are not responsible for such third parties' failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
Co is not responsible for effectiveness of, or compliance with, any third-parties' opt-out options or programs or the accuracy of their statements regarding their programs.
Communications:
If used, you can opt out of receiving certain promotional communications (emails or text messages) from Co at any time by following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Co may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Co's ongoing business relations.
If third-party cookies are used, you can also manage your cookie preferences through our online Cookie Consent Manager <if used - hyperlink will be active here>.
8. Children's Privacy
The Service is intended for a general audience and not directed to children less than 13 years of age. Co does not intend to collect personal information as defined by the U.S. Children's Online Privacy Protection Act ("COPPA") ("Children's Personal Information") in a manner that is not permitted by COPPA. If Co obtains knowledge that Co has collected Children's Personal Information in a manner not permitted by COPPA, Co will delete it from our database to the extent required by COPPA. California residents under the age of 18 may have additional rights as outlined in this notice.
9. Changes to this Privacy Notice
Co may update this privacy notice from time to time. Co will notify you of any changes to this Privacy Notice by posting an updated version on this website. To the extent any provision of this Privacy Notice is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
10. Contact Us
If you have any questions, or to submit a consumer rights request, you may contact Co, using our preferred method, by emailing us at compliance@aspenhome.net or by calling 602-442-5600 and asking for the Compliance Manager.