(updated: March 16, 2020)
1. Information We Collect
A. Personally Identifiable Information
While using our site, we may ask you to provide us with certain personal data that can be used to contact or identify you (“Personal Data”). Personal Data may include, but is not limited to:
First and last name
Address, State, Province, ZIP/Postal Code, City
We sometimes ask for credit card information when such information is voluntarily submitted by our visitors. We will only use your personal information for the following purposes: (1) to deliver the products and/or services to you that you have requested; (2) to validate your compliance with the terms and conditions; (3) for content improvement and feedback purposes; (4) to reach you, when necessary, regarding your use of the web site or product(s); and (5) for the few situations described below to better serve you.
We will NEVER share your personally identifiable information with third parties unless you have given us explicit permission to do so, such as in order to fulfill a third party offer that you have accepted from us. By permitting us to collect this information, you will be able to receive information on other products and services that may be of interest to you, including related third party offers that we may send to you. You also enable us to personalize your experience with us so that we can provide you with the highest quality of service.
By submitting your email address to us, you agree to receive email from us. You can cancel your participation in any of these email lists at any time by clicking the opt-out link or other unsubscribe option that is included in the respective email. We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do.
By submitting your email address, you also agree to allow us to use your email address for custom audience targeting on sites like Facebook, where we display custom advertising to specific people who have opted-in to receive communications from us.
In addition, you agree that by submitting your telephone contact information on this web site and/or registering to receive the product and/or service offered herein, such act constitutes a purchase, an inquiry, and/or an application for the purposes of the Amended Telemarketing Sales Rule (ATSR), 16 CFR ‘310 et seq. and any applicable state and local “do not call” regulations. We retain the right to contact you via telemarketing in accordance with the ATSR and the applicable state regulations.
B. Non-Personally Identifiable Information
Information Collected Automatically
Log & Device data: When you visit our site, we may automatically record information (“log data”), including information that your browser sends whenever you visit our site. This log data may include your web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location.
Our third party service providers may provide us information that tells us how our marketing ads, often placed on third party sites, performed and who clicked on them. This information does not identify any specific individual and is generally non-identifying. If we were to associate it with you we would treat it as personal data.
We also may collect various types of non-personally identifiable information to help us make your experience more enjoyable, measure site activity to identify future improvements that should be made, and compile aggregate data to help serve site visitors better.
For example, we may use session and persistent “cookies,” session logs, web beacons, GIF/pixel tags, banner ads, third-party click tracking analytics tools (such as Google Analytics), third party retargeting networks that may display our advertisements to you on other sites that you visit to remind you about us, and third party networks that serve user-requested emails (e.g., for a refer-a-friend email) to collect non-personally identifiable or other aggregated information about site visitors.
Cookies are text files that are used by your computer’s web browser to store your preferences, and enable us to enhance your user experience with our web sites. Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our site. Check your browser’s help function to learn more about your cookie setting options.
We may use the following types of cookies:
Advertising and analytics: These cookies collect information about who is visiting our site and how users engage with our site. This information does not identify any individual user. It is aggregated and anonymous. Information included in this analysis is number of visitors to our site, time of day visited our site, if this is a new or repeat visitor, and other comparable information. This information is used to help us understand the usage of our site, improve and operate our services more efficiently and to monitor the activity of our site. Please see below for a listing of our analytics providers.
Essential cookies: These cookies help run our site and make your experience better. These include cookies that all you access to a members only part of the site or help the content of our site load quickly. These cookies are only used to provide you with these services.
Functionality cookies: These cookies allow the site to remember preferences you have selected such as login details or other selections you may have made. These are designed to make it easier to use our site and not have to set the same preferences every time.
Social Media cookies: We use social media tools on our site and these cookies allow the social media network to record when you have liked or engaged with a social media tool on our site. In some situations, the social network may send us data that you have set to share. If you do not want the social media network to share information with us, please check your privacy settings with the social media network.
Advertising cookies: These cookies allow us to track browsing habits as you visit the site. Based on your browsing history and with our permission, we use third party advertising partners who can then display to you a relevant ad when you are on a third party site such as a social media platform. Within these cookies, we may also know your precise location such as latitude, longitude, GeoIP, and other location specific information. Please see below for your choices on cookies in the use of advertising.
To help us make emails more useful and interesting, we often receive a confirmation when you open an email from us if your computer supports such capabilities. You can opt out of receiving emails from us. Please see the Your Choices section below.
We might also use a pixel tag which is a small graphic file that allows us and third parties to monitor the use of the site and provide us with information based on your interaction with the site. These tags may collect the IP address and the browser type from the device on which you loaded the page. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements.
Other data technologies may be used that collect comparable information for security and fraud detection purposes.
If you have any questions about cookies you can go to http://www.youronlinechoices.com/uk or http://www.allaboutcookies.org.
Emails or newsletters that we send electronically may use techniques such as web beacons or pixel tags to gather email metrics and information to improve the reader’s experience, such as the number of emails that are opened, whether they were forwarded or printed, the type of device from which they were opened, and the location (e.g. city, state, and county) associated with the applicable IP address.
If you visit our web sites with an open ID (such as Facebook), you may also be sharing and integrating data with third-party social media sites, and we may track aggregate data about the number of visits to our web sites with an open ID, the number of items “liked” on our web sites, or items on our web sites that you choose to share with a third-party social media site.
Other parties such as advertising partners and analytics companies may also be collecting information about your online activity across various websites over time. The information collected by those third parties may include identifiers that allow those third parties to tailor the ads that they serve to your computer or other device.
Because there is not yet a common understanding of how to interpret web browser-based “Do Not Track” signals other than cookies, we do not currently respond to “Do Not Track” signals that are undefined.
Please note that you do have the option to configure most web browsers to NOT accept cookies. However, be aware that disabling cookies may keep you from having access to some functions or services on our web sites or the web-hosted software that runs on our web sites.
Use of Your Information – Grounds for Using Your Personal Data
The information that we collect and store relating to you is primarily used to enable us to provide our services to you. In addition, The New Brave, LLC is relying on the following lawful grounds to collect and process any personal data you may have provided:
- Legitimate Business Interests: To provide you with information requested from us relating to our products or services and to provide information on other products which we feel may be of interest to you if you have consented to receive such information, which are legitimate business interests. To notify you about any changes to our Website, such as improvements or service/product changes, that may affect our service. If you are an existing customer, we may contact you with information about goods and services similar to those which were the subject of a previous sale to you.
- Performance of Contract: To meet our contractual commitments to you and in performance of contractual obligations to you.
- User Consent: We may use your data, or permit selected third parties to use your data, so that you can be provided with information about unrelated goods and services which we consider may be of interest to you. We or they may contact you about these goods and services by any of the methods that you consented to at the time your information was collected. If you are a new customer, we will only contact you or allow third parties to contact you only when you have provided consent and only by those means you provided consent for. If you do not want us to use your data for ourselves or third-parties, you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data.
- Please be advised that we do not reveal information about identifiable individuals to our advertisers, but we may, on occasion, provide them with aggregate statistical information about our visitors such as your area of residence or age group.
2. Sharing and Disclosure
We do not share your personal information with others except as indicated within this policy or when we inform you and give you an opportunity to opt out of having your personal information shared.
We will share your information in the following ways.
- With third party service providers, agents, or contractors. We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods. Or, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, to collect debts, and to analyze and enhance data (including data about users’ interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We do not authorize them to use or disclose your personal information except in connection with providing their services.
- Analytics. Specifically for analytics providers, we use Google Analytics Google Analytics which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
Please note at this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.
Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page at http://www.google.com/intl/en/policies/privacy/
Facebook: You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
To see more about Facebook’s participation in the Digital Advertising Alliance please visit the Choices section of this notice.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
We may participate in Facebook.com’s Custom Audience or LinkedIn’s Audience program which enables us to display personalized ads to persons on our email list when they visit Facebook or LinkedIn respectively. We provide Personal Information such as your email address to the social media provider to enable it to determine if you are a registered account holder. You may opt-out of participation in this program by contacting us as noted below. You may also opt out of receiving these ads from the social media network directly.
- Payment Providers: We may provide paid products and/or services within the site. When we do, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own privacy notice. The payment processors we work with adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are: SamCart, Stripe, and Paypal.
3. Storing your personal data/Transfer of Data
This site is operated in the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using this site and providing us with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as the European Union. Our service providers use appropriate safeguards to transfer your personal data to the United States.
- Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into via our site will be encrypted to ensure its safety.
- The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential.
4. Third party links
We may have links on our site to other sites that we do not operate. If you click on a third-party link, you will be taken directly to that site which is governed by its own privacy notice. We strongly encourage you to read that privacy notice. We do not control that site and assume no responsibility for the content, policies or its practices.
5. Choices and Individual Rights:
We aim to take reasonable steps, so you can correct, amend, delete or limit the use of your Personal Data.
We outline your choices below:
- E-mail. As described above, if you do not wish to receive promotional e-mails from us, you may opt out at any time. If you opt out of a promotional e-mail, we may still send you transactional and administrative emails about this privacy notice or about the products or services you have purchased.
- Cookies. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.
- Advertising. You can opt out of online targeted advertising by opting out within the advertisement itself or by visiting Digital Advertising Alliance, http://www.aboutads.info/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/. You can also opt out of the Digital Advertising Alliance using your mobile device settings.
- Your rights under certain circumstances. To initiate any of these actions please contact us at email@example.com.
- To access and receive a copy of the Personal Data we hold about you.
- To rectify any Personal Data held about you that is inaccurate.
- To request the deletion of Personal Data held about you.
- You have the right to data portability for the information you have provided to us. You can request to obtain a copy of this information in a commonly used electronic format so that you can manage and move it. We will need to verify your identity before being able to respond to such requests.
- Please note that in some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
- Right to Lodge a Complaint. For European Union residents, if you feel that our processing of your personal data infringes on data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state where you habitually reside, your place of work or the location of the alleged infringement. If you are located outside of the European Union, you may have rights under privacy laws in the jurisdiction where you live.
6. Third Party Actions
We do not control and are not liable for the actions of any third parties who we may promote. We pride ourselves in working with quality companies, but have no control over the actions of those third parties. While we are not liable for any of the actions of those third parties, you should feel free to give us feedback from time to time on your experiences with any third parties to whom we work with so that we may enhance our future service to all customers.
7. Children’s Privacy
Our site is not directed to children under 18 years of age. We do not knowingly intend to collect personally identifiable information from them. If your minor child has provided us with personally identifiable information, please contact us at the phone number or mailing address listed in Section 11.
8. IP Addresses
We may use your IP address to help prevent fraud, to help diagnose problems with our server, to gather broad demographic information, and to offer you products and services.
9. Third Party Web Sites
This web site and/or the products and/or services offered herein may direct you to web sites that are owned and/or controlled by third parties. We have no control over those third parties and are not responsible for the content or the privacy practices of those sites or companies.
10. Commitment to Data Security
All information collected from you is stored in a technically and physically secure environment. Furthermore, employees, contractors, and vendors who have access to your personally identifiable information in connection with providing services for us are required to keep the information confidential.
We use SSL encryption to protect sensitive information online, and we do everything we can to protect user information offline. Unfortunately, no transmission over the Internet can be guaranteed to be 100% secure. As a result, while we take reasonable measures to protect your information, we cannot ensure or warrant the security of the information that you transmit to us, and you do so at your own risk.
11. Contacting Us
If you need to contact us, you can email us at firstname.lastname@example.org or call us at 980-277-2752.
12. Note To California Residents
If you live in the State of California, under the California Civil Code, you have the right to request that companies who conduct business in California provide you with a list of all third parties to which the company has disclosed Personal Information during the preceding year for direct marketing purposes.
If you are a California resident and want to request information about how to exercise your third party disclosure choices, you must send a request to the following address with a preference on how our response to your request should be sent (email or postal mail). Please send an email to the Privacy Administrator at email@example.com.
The subject line of the email must be labeled “Your California Privacy Rights”. For all requests, please include your name, street address, city, state, and zip code.
We do not accept requests via the telephone, by mail, or by facsimile. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
The New Brave, LLC will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
14. Sensitive Data
We request that you do not send us any sensitive data such as social security or national identification numbers, information related to racial or ethnic origin, political opinions, religious beliefs, health data, biometrics or genetic, criminal background or trade union membership information. If you do send us this information, then you are consenting to its processing in accordance with this privacy notice. To avoid processing of sensitive data, do not submit it.