Last updated: May 3, 2023
What is Personal Information?
Your Age and Your Location
Our Website is not intended for children and we do not knowingly collect information from anyone under the age of 18 or that the law does not consider an adult capable of entering into agreements or providing informed consent (a “minor”). If you are the parent, legal guardian or custodian of a minor and determine or suspect we may have received any information from or about your minor, please notify us immediately. We will confirm you are the parent, legal guardian or custodian and then promptly take steps to delete the minor’s information anywhere it may be in our possession or under our control.
How We Obtain Information
As mentioned above, you may choose to give us information by entering personal information into our Website. Whether you are requesting information or asking us to contact you for any reason. We always have the right to use your personal information to respond or handle your request. Even when you simply use our Website, we may automatically collect and store non-personal elements of information related to your use. Generally, all this non-personally identifiable information is recorded in such a way that it does not reflect or reference any identifiable individual. However, even though this information does not identify you, as mentioned above, the law may include this information within the definition of personal information. For example, non-personally identifiable information may include the type of Internet browser and operating system you are using, your IP address, the domain of the website you came from (sometimes called a referring URL), how many times and the dates and times of your visits and the average amount of time you spend on the Website. Sometimes the Website may also be able to identify the application or device you are using, your mobile network (e.g., carrier name and phone number) and the interaction of your apps, browser and devices with the Website. Technology may enable us to determine when you search on the Website for particular words and the content your browser opens. We may keep track of the pages you visit, the content your browser displays, as well as third party advertisements and content and even the hypertext links you select on the Website. Gathering this information can help us better understand how to improve the Website and the user experience when you visit. Sometimes, with varying degrees of accuracy, your location can be determined by your IP address, GPS, sensor data from your device or from nearby technology (e.g., Wi-Fi access points; cell towers; Bluetooth-enabled devices) and the capability to capture this type of information often depends on your device location settings, which you generally have the ability to turn on or off.
Our Website may also use technology to remember whether you’ve been there before. A “cookie” (i.e., a text file placed on your hard disk by a web page server) is one example, but there are currently many different types of technology that perform similar functions (e.g., pixel tags, server logs, invisible GIFs, web beacons, application data caches). Some of the technology the Website uses makes things more efficient and may provide faster loading times for content that benefit users who visit the Website repeatedly. Similarly, unique, non-personal identifiers (“tags”) enable us to track information without identifying you or any individual. Tags may
Our Website does not support Do Not Track and we do not respond to Do Not Track requests. “Do Not Track” or “DNT” is a preference you can set in your browser to inform websites you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Contacting Us/Chatting with Us
When you enter your name, email address, phone number or other information on our Website, ask us to contact you, or you request information using our Website, you understand, acknowledge and agree that by doing so you are requesting us and giving us your permission and explicit consent to allow us to use your personal information to respond to you and/or handle your request. If you ask us to respond by email, you will always be given the ability to opt out of receiving future unsolicited marketing emails by using an unsubscribe link at the bottom of each email we send you, or by contacting us at the address below.
How We Store, Use, Share and Disclose Information
Using: There are a number of purposes for which we use the information, including personal information, that we obtain and although some are already mentioned, they are worth repeating:
- To help operate, administer, maintain and improve the quality and performance and operation of the Website and obtain analytical data and metrics so we can better understand how the Website is being used and improve your experience when using the Website;
- To track outages or troubleshoot problems and detect, prevent and respond to possible fraud, abuse and security risks;
- To provide information or to contact you in response to your requests or otherwise as permitted by law;
- To personalize your experience as when you use the Website repeatedly and sometimes notify you of offers or other content we may offer or make available to returning users;
- To allow us to deliver and improve content, including content and materials from unaffiliated third parties (e.g., advertisers, promotional partners, suppliers and others) (“Third Party Content”), we believe may be of interest to users of the Website; and
- To protect us and others from harm and to detect, respond and help us prevent fraud, abuse and security risks (e.g., SPAM, malware or malicious code) that could do harm.
Sharing and Disclosing
We may disclose your personal information under the following circumstances:
- If we have your consent;
- To fulfill the purposes for which we obtained it, as well as satisfying any legal, audit or reporting requirement;
- To respond to threats or attacks on the security or integrity of the Website;
- To enforce any and all terms and conditions of our Agreement with you applicable to the Website;
- To detect, prevent, or address fraud, security, or other technical issues, including our investigating potential abuse or violations;
- To protect and/or defend against damage or harm or violations of any our rights, property or safety, or the rights, property or safety of others, including, without limitation, the public as and if required by law;
Links to Other Websites and Social Media
You Can Control Your Privacy Choices
We want you to have choices and control over how we collect and use your personal information. If you contact us, ask us to provide you with information or receive unsolicited marketing or promotional emails from us, you will always be able to opt out of receiving those types of email communications from us.
You always have the right to ask us to provide you with a digital file containing a copy of your personal information and request that we delete all or any portion of your personal information. We still must and do reserve the right to retain any of your personal information as long as necessary to fulfill and service any transactions or requests you have made or initiated that require our performance and for legal and audit purposes.
To be sure your rights are clear, in summary, you have the right:
- To know what categories of personal information we collect;
- To know the purposes for which we collect and use personal information and to whom personal information is disclose and/or shared;
- To know what specific personal information we have about you and with whom we shared or provided it;
- To tell us not to sell your personal information;
- To request us to delete all or any portion of your personal information;
We have the right to deny or delay responding to your requests, if retaining your information is necessary for us to:
- Complete and fulfill a transaction, any contractual obligation, any associated request, customer service or other purpose related to your continued existing relationship with us;
- Complete and take any action consistent with the purpose for which we collected the information and for which you previously consented or agreed, whether based on the Agreement you have with us or otherwise,
- Detect and identify security incidents, protect against illegal activity and provide evidence necessary to prosecute, cooperate with law enforcement or other governmental agencies or enforce our rights;
- Repair or correct errors, malfunctions or deficiencies in our products, the Website, our systems or communications capabilities; and/or
- Comply with our legal and regulatory obligations.
If we need to retain any information for business or legal purposes, we will keep it only as long as necessary for us to comply with those requirements. You can appreciate, we also need to be sure your personal information isn’t accidentally or maliciously altered or deleted without your permission or knowledge, so there could be a delay in deleting information in our systems and backups to make sure we are following your instructions.
Exercising Your Privacy Rights
If you want to exercise any of the rights you have, you can send us your request by email at email@example.com or by regular mail to, H/L, 100 Webster Street, Oakland, California 94607, Attention: Privacy. Bear in mind only you or someone legally authorized to act on your behalf under the laws that apply to you is allowed to send us requests to exercise your rights. Your request must also include enough information to enable us to verify you are the individual that is the subject of your request or to authenticate anyone else authorized to make the request on your behalf. We may request additional information or confirmation from you to do so. You should describe your request, consistent with your rights, in enough detail so we can understand and respond to it properly and you should understand it will only cover the 12 month period preceding your verifiable and understandable request. If you don’t, or if we cannot verify your identity or the authority of another person to make the request on your behalf and make sure the request relates to your information, we will not be able to honor your request until you meet these conditions. We will generally respond to a complete and proper request, at no charge to you, within 45 days of receiving your verifiable and understandable request. If we need more time, we will notify you, but it won’t be longer than another 45 days. If we send you a digital file to allow for data portability, we will use a widely used file format which should allow you to transmit the information easily.
Compliance, Questions and Comments