Last updated: January 10, 2020
I. LOCATION AND INTERNATIONAL TRANSFER
NOTE TO CALIFORNIA RESIDENTS
Your California Privacy Rights. California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes. Requests should be submitted via email to firstname.lastname@example.org and should include CALIFORNIA PRIVACY RIGHTS in the subject line. We will need your first and last name, mailing address, and email address in order to process your request. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, if any, along with the names and addresses of these third parties, if any. Please be aware that not all information sharing is covered by the requirements of Section 1798.83 and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
Our websites do not accept or process such Do Not Track signals or similar mechanisms. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
II. INFORMATION WE COLLECT
Personal Information is collected when you voluntarily create an account, use the Site and/or App, and corresponding with us by phone, text, email, live chat, or otherwise (“Personal Information”). Personal Information we may collect includes, but is not limited to the following categories:
Contact and Demographic Information. When you create and account, you voluntarily provide your contact information, including your first and last name, user name, mailing address, and email addresses. You also provide demographic information such as your birth date, age, and gender. If you leave comments, reviews, or post information using the Site, App, our social media pages, or other affiliated websites, that information may be tracked. If you communicate to us by e-mail, mail, text, live chat, or otherwise we will record the e-mail address, postal address and cell number from which you send your correspondence. Any telephone calls to and from us may be monitored and recorded for quality assurance and training purposes.
Transactional Information. Transactional information helps us understand who you are and what types of offers may interest you. This also allows us to improve the products and services we offer. Transactional information may include the products you purchase, pages you visit, preferences, and special offers or promotions redeemed.
Mobile Device Information. When you access and use the Site or App from your mobile devices, we receive data from your mobile device. This may include your location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
Social Media Sites. We use social media accounts, including but not limited to Facebook, Twitter, and Instagram. We may collect additional Personal Information, if you choose to post any information on these accounts.
Cookies. A cookie is a small data file stored on your hard drive that your browser provides to us when you visit certain web pages. Cookies are text files containing small amounts of information that are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org
- Keeping you signed in
- Understanding how you use our website
Third-Party Cookies. We may engage third-party service providers, including Google, Facebook, and Instagram to serve ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies tags to track your online activities and purchases in order to deliver targeted advertising based on your interests. You can learn more about Google’s advertising cookies and opt-out options by visiting http://www.google.com/policies/technologies/types/. You can learn more about Facebook’s advertising cookies and opt-out options by visiting https://www.facebook.com/policy/cookies/. You can learn about Instagram’s advertising cookies and opt-out options by visiting https://help.instagram.com/1896641480634370?ref=ig.
Pixel Tags. Pixel tags (a.k.a. clear gifs) are tiny graphics with a unique identifier, similar in function to cookies, which allow us to monitor the use of our Site and to deliver banner advertisements to you about our products and services as you browse the Internet. Pixel tags generally work in conjunction with cookies, registering when a particular computer visits a particular page. You cannot decline pixel tags; however, if you turn off cookies the pixel tag will simply detect an anonymous visit. In addition, we use pixel tags in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
Internet Protocol (IP) Address. Our servers also automatically identify your computer or mobile device by its Internet Protocol (IP) addresses. An IP address is a number that is automatically assigned to your computer by your Internet Service Provider. Your IP address does not identify you by name, however, it may reveal your geographic area and your Internet Service Provider. We may match your IP address to your Personal Information.
Click-Through URLS. We may send you e-mail messages with a “click-through URL” linked to the content of our Site. When you click onto one of these URLs, you will pass through our server before arriving at the destination webpage. We may track this click-through data to help us determine subscriber interest in the subject matter and measure the effectiveness of our subscriber communications. You can avoid being tracked simply by not clicking on any links or images in the e-mail.
Domain Name Tracking. When you use the Site, we automatically record the name of the domain from which you accessed the Site. Additionally, if you reach the Site by means of a link from another site, our computers will note the fact that you came to us from that linked site. We may also record the domain name and URL for the next website you go to after leaving the Site.
Analytics. We may use one or more third-party analytics programs including, but not limited to, Google Analytics to help analyze how users utilize the Site. Google Analytics uses its own cookies to distinguish users and to collect standard Internet log information and visitor behavior information. The information generated by the cookie about your use of the Site (including IP address) is transmitted to Google. This information is used to create statistical reports on user activity for www.Heelr.com. In addition to reporting website usage statistics, Google Analytics can also be used, together with some of the advertising cookies (described above), to help show more relevant ads on Google properties (like Google Search) and across the web. For more information about Google Analytics, including opt-out options visit https://support.google.com/analytics/answer/6004245.
III. OUR USE OF YOUR INFORMATION
Our primary purpose for collecting Personal Information and Aggregate Information (collectively “User Information”) is to provide you with products and services you request. We may also use your User Information for the following purposes:
- To facilitate the creation of and secure your account
- To identify you as a user in our system
- To communicate with you in written, electronic, and verbal form
- To provide information on products or services
- To improve and optimize our services and Site
- To develop new products and services
- To send newsletters, marketing materials, and promotional offers
- To customize the advertising and content you see
- To verify information
- For any other purpose disclosed at the point of collection
We may also use your User Information to verify your geographic location. We may use your geographic location data to personalize our products and services, to recommend content, determine whether the information you have requested is available in your location. If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose.
IV. DISCLOSURE OF YOUR INFORMATION
Promise Brands does not sell your User Information; we may, however, share your information as follows:
Third Parties. We may share your User Information with third-party companies such as developers and partner companies for marketing purposes.
Affiliated Companies. We may share User Information with our parent company, subsidiaries and other related companies, who may use the User Information for the purposes described above.
Service Providers. We may disclose your User Information to third-party service providers hired to perform internal business functions on our behalf including, but not limited to, providing marketing assistance, sending direct mail or email, website or database hosting companies, e-mail service providers, analytics companies, and payment processing companies. Unless otherwise stated, these companies do not have any right to use the User Information we provide to them beyond what is necessary for them to assist us.
Business Transitions. We reserve the right to transfer all User Information in our possession in the event we go through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets. Similarly, your User Information may be passed on to a successor-in-interest in the event of a reorganization, reconstruction, liquidation, bankruptcy, or administration. Users will not be notified of any such change of ownership or control of their User Information.
V. THIRD-PARTY ADVERTISERS AND LINKS
VI. DATA SECURITY
No transmission of data over the Internet is guaranteed to be completely secure and we cannot guarantee that your submissions to the Site or App, any content residing on our servers, or any transmissions from our server will be completely secure. It may be possible for third parties to intercept or access transmissions or private communications unlawfully. Any such transmission is done at your own risk. To help protect yourself and your information, choose a unique password for our Site and App, and do not use a password on our Site or App that you would use on any other website or online service.
VII. CHILDREN’S PRIVACY
The Site and App are intended for adult use only and is not directed towards children, minors, or anyone under the age of 18. If you are under the age of 13, you are not authorized to provide us with any personal information. If the parent or guardian of a child under 13 believes that the child has provided us with any personal information, the parent or guardian of that child should contact us at the email address below and ask to have this personal information deleted from our files. We appreciate your cooperation with this federally mandated requirement.
VIII. INFORMATION CHOICES
You may opt out of receiving marketing/promotional emails from us by following the instructions in those emails or by reviewing the settings in your account. You may opt out of receiving marketing/promotional text messages from us at any time by replying STOP to a marketing/promotional text message. If you opt out of receiving marketing/promotional emails and/or text messages, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests about your personal information, including changes to your contact preferences, and changes to or deletions of your information or content you post, by emailing email@example.com. In some cases, we may not be able to delete your personal information and will retain and use your information for as long as necessary to fulfill an internal business purpose, comply with our legal obligations, resolve disputes, and/or to enforce our agreements. You may decline to share certain data with us in which case we may not be able to provide you with some of the features and functionality of the Site or App.
X. HEELR CONTACT INFORMATION
NAI Opt-Out for Interest-Based Advertising
Although Heelr is not currently a member of the Network Advertising Initiative, you may be able to opt-out of receiving certain tailored online ads from members of the Network Advertising Initiative by following the instructions in the following link: http://optout.networkadvertising.org/?c=1.