This Website collects some Personal Data from its Users.
Personal Data: Trackers; Usage Data
Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
Personal Data: Cookies; Usage Data
Personal Data: email address
Personal Data: Cookies; Usage Data
Personal Data: address; city; email address; first name; last name; phone number; state
Personal Data: email address; first name
Personal Data: Cookies; Usage Data
Personal Data: various types of Data as specified in the privacy policy of the service
Personal Data: Cookies; email address
Personal Data: Cookies; Usage Data
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
Roger Wilco LLC (“Chatra”, “our”, “us” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users using Chatra software applications, application programming interfaces, Chatra Webhooks, communication services, networks, and websites, including, but not limited to chatra.io and app.chatra.io (the “Site”).
This Privacy Policy applies only to information that you provide to us through the Site. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the chatra.io. You are advised to consult this policy regularly for any changes. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Chatra Terms of Service, accessible at https://chatra.io/terms-of-service/.
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
In addition to this Privacy Policy, we have a separate Data Processing Amendment that contains further information for customers and service providers.
We use the term “customers” for individuals and businesses who have signed up for a Chatra account, and handle information received from them under the terms of the Chatra Data Processing Amendment.
“End users” refers to individuals using goods and services provided by Chatra customers. For example, individuals who use Chatra when seeking assistance for a particular product or service via live chat are likely to be end users.
“End user data” (which describes data about end users of Chatra customers) includes but is not limited to first names, last names, phone numbers and email addresses. It’s only used by us to identify you to Chatra customers so they can provide you with customer service, ensuring that they’re able to help you in the way(s) you require.
For more information on how we process data on behalf of Chatra customers, please see our Data Processing Amendment.
Information Collection and Use
Our primary goals in collecting information are to provide and improve our Site, services, features and content, to administer your use of the Site (together, the “Service”) and to enable users to enjoy and easily navigate the Service.
Personally Identifiable Information
In the course of using the Service, we may ask you to provide us with, or grant us access to, or permission to obtain, certain personally identifiable information that can be used to contact or identify you; personally identifiable information may include, but is not limited to, your name, company name, email address, postal address, phone number, profile photo, and credit card number and other billing information (“Personal Information”).
We also collect the other information that you provide as part of registration and personalization of your Account (e.g., without limitation, zip code (on its own) history of purchases you make via the Site and individual preferences) (“Non-Identifying Information”).
We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Service, complete your transactions, and administer your inquiries.
Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Chatra Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Site and Service are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
We may also use your Personal Information to contact you with chatra newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. (See “Changing or Deleting Information,” below.)
Log Data
When you visit the Site, whether as a Member or a non-registered user just browsing (any of these, a “chatra User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Service and for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs We also use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Log Data (besides IP) as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
Cookies
Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your login information and preferences for future logins to the Site. Second, we utilize session ID cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by Chatra Users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and Service and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Service.
To ensure the functionality of our chat software and to allow the identification of users when they return to our Site, we save user identification token and other information to the local storage and/or cookie in your browser.
This includes, but is not limited to, the persisted state, machine state, session ID as well as chat statistics, an individual user ID, the name of the user, the email-address and the number of visits. These tokens are stored locally and are not shared with third parties. By default this information is stored indefinitely.
These cookies/local storage entries have key-value storage names that differ from session to session.
List of Cookies
Website Name Cookie Purpose Storage Duration
chatra.io, app.chatra.io Google Analytics (_ga) Collects information about how visitors use our sites 2 years
chatra.io, app.chatra.io Google Analytics (_gat) Collects information about how visitors use our sites 1 min
chatra.io, app.chatra.io Google Analytics (_gid) Collects information about how visitors use our sites 24 hours
chatra.io, app.chatra.io Google Analytics (_utma) Determines unique visitors and pageviews 2 years
chatra.io, app.chatra.io Google Analytics (_utmb) Establishes and continues a user session 30 min
chatra.io, app.chatra.io Google Analytics (_utmz) Stores the type of referral used by the visitor 6 months
chatra.io, app.chatra.io, chat.chatra.io chatra.* Ensures the functionality of our chat software
chatra.io Disqus (__jid) Authentication for commenting 2 years
chatra.io Disqus (event.gif) Authentication for commenting 2 years
chatra.io Facebook (tr) Advertising pixel for prospecting and retargeting 180 days
chatra.io partnerId Determines the ID of Chatra referring partner (if any) 30 days
Chatra.io, app.chatra.io, chat.chatra.io galaxy-sticky Load balancer cookie that connects you to a correct chatra server Till the browser is closed
End-user cookies
To ensure the functionality of our chat software and to allow the identification of end-users when they return to our Site, we save user identification token and other information to the local storage and/or cookie in your end-user browser.
This includes, but is not limited to the persisted state, machine state, session ID as well as chat statistics, an individual user ID, the name of the user, the email-address and the number of visits. These tokens are stored locally and are not shared with third parties. By default this information is stored indefinitely.
These cookies/local storage entries have key-value storage names that differ from session to session.
Web Beacons
We also use “web beacons”, “pixel tags”, “clear GIFs” or similar means (individually or collectively “Web Beacons”) on our Site. A Web Beacon is an electronic image, often a single pixel, embedded on web pages. Web Beacons are ordinarily not visible to users. Web Beacons allow us to count the number of users who have visited certain pages of the Site, to deliver branded services and to generate statistics about how our Site is used.
Phishing
Identity theft and the practice currently known as “phishing” are of great concern to Chatra. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Information Sharing & Disclosure
Your logo on the Site
Subject to your approval, we may also feature your company logo, company name and testimonial on the homepage or any other pages of the Site.
Aggregate Information & Non-Identifying Information
We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
Service Providers
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, payment processing, product production, shipment services, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site and Service are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. For more information check our Data Processing Amendment.
Compliance with Laws & Law Enforcement
Chatra cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Chatra or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.
Business Transfers
Chatra may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
Changing or Deleting Your Information
All Members may review, update or correct the Personal Information in their account by contacting us or via the account section of the Site. If you would like us to delete your Account in our system, please contact us at support@chatra.io with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Security
Chatra is very concerned with safeguarding your information. The security of your personal information is important to us. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. When you enter sensitive information (such as credit card number or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). In some cases, we also encrypt sensitive information where it is stored on our systems. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
International Transfer
Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you choose to provide information to us, Chatra transfers Personal Information to the United States or European Union and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Users outside of the U.S.
Important Information for Users Outside of the U.S. – Transfer of Data
WE PRIMARILY STORE DATA ABOUT YOU, INCLUDING PRIVATE INFORMATION, ON SERVERS LOCATED AND OPERATED WITHIN THE UNITED STATES OR EUROPEAN UNION. IF YOU RESIDE OUTSIDE OF THE UNITED STATES, IN ORDER TO PROVIDE AND OPERATE THE SERVICES, WE MAY SEND AND STORE YOUR PRIVATE INFORMATION (ALSO COMMONLY REFERRED TO AS PERSONAL DATA) OUTSIDE OF THE COUNTRY WHERE YOU RESIDE OR ARE LOCATED, TO THE UNITED STATES OR EUROPEAN UNION. THEREFORE, OUR COLLECTION AND USE OF YOUR PRIVATE INFORMATION IS SUBJECT TO THE UNITED STATES' LAWS RELATED TO PRIVACY AND USE OF PERSONAL DATA AND INFORMATION. THESE LAWS, INCLUDING WHAT IS DETERMINED TO BE "PERSONAL DATA AND/OR INFORMATION," ARE DIFFERENT AND MAY BE LESS PROTECTIVE THAN THOSE APPLICABLE TO YOU IN YOUR COUNTRY OF RESIDENCE. BY ACCEPTING THE TERMS OF THIS PRIVACY POLICY, YOU ACKNOWLEDGE, AGREE AND CONSENT TO (1) THE TRANSFER TO AND PROCESSING OF PRIVATE INFORMATION ON SERVERS LOCATED OUTSIDE OF THE COUNTRY WHERE YOU RESIDE, (2) OUR COLLECTION AND USE OF YOUR PRIVATE INFORMATION AS DESCRIBED HEREIN AND IN ACCORDANCE WITH THE LAWS OF THE UNITED STATES THAT MAY BE DIFFERENT AND MAY BE LESS PROTECTIVE THAN THOSE IN YOUR COUNTRY AND (3) THAT YOU ARE TAKING A RISK BY USING THE SERVICES. IF YOUR PERSONAL INFORMATION IS TRANSFERRED FROM THE EUROPEAN ECONOMIC AREA TO CHATRA, PLEASE SEE THE PROCESSING AND USE OF EU RESIDENTS DATA SECTION BELOW.
Processing and use of EU residents data
We store and process personal information of European Union Residents (both customers and end-users) in accordance with GDPR regulation. Personal information is stored and processed by Chatra on servers located within European Union (Germany). See section “service providers” to learn about sub-contractors we use to process your data.
Enforcement
Chatra is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). We may be required to disclose personal data to public authorities and law enforcement agencies in response to lawful request by public authorities, including to meet national security and law enforcement requirements.
Do not track signals
You may have implemented a "do not track" signal through your browser. As there currently is no fixed standard for do not track signals, we currently do not respond to do not track signals from your web browser.
Links to Other Sites
Our Site contains links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
Our Policy Toward Children
This Site is not directed to persons under 18. We do not knowingly collect personally identifiable information from children under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at support@chatra.io. If we become aware that a child under 16 has provided us with Personal Information, we will delete such information from our files.
Contacting Chatra
If you have any questions about these Terms, please contact Chatra at:
Roger Wilco LLC,
Millen, White, Zelano & Branigan
Attn: Jeff Cohen
2200 Clarendon Blvd., Suite 1400A
Arlington, VA 22201
1-703-232-1443
info@chatra.io
This Privacy Notice (“Privacy Notice“) describes the privacy practices of Klaviyo Inc. and its subsidiaries and affiliates (collectively, “Klaviyo” or “us” or “we“).
Klaviyo provides marketing technology services to other businesses – our clients. To take advantage of our services, our clients share with us information about their individual consumers, including contact details and shopping histories. We analyze that information and develop and send communications to the consumers only at the direction of the client who provided the information, and only on that client’s behalf. We may also collect personal data for our own business purposes in connection with our business, such as business contact details of potential customers or job applicants’ resumes. We do not collect employee or HR related data in the EU or Switzerland, or transfer such information either into or out of the EU or Switzerland.
This Privacy Notice applies to:
The klaviyo.com website and any other websites or online services controlled by us and which display this Privacy Notice, and
Marketing technology services that we provide to our clients.
Click on the links below to jump to sections of the Privacy Notice:
Information We Collect
Information We Collect for Klaviyo’s Own Business Purposes
Information We Collect from or on Behalf of Our Clients
Cookies and Other Information Collected by Automated Means
Automated Data Collection for Klaviyo’s Own Business Purposes
Automated Data Collection on Behalf of Our Clients
Our Use of Personal Information
Our Use of Personal Information for Klaviyo’s Own Business Purposes
Our Use of Personal Information on Behalf of our Clients
Information We Share
Careers
Privacy Preferences, Rights, And Choices
International Data Transfers
EU-US Privacy Shield & Swiss-US Privacy Shield Certifications
How We Protect Information
Links To Websites And Third Party Content
Changes To Our Privacy Notice
Data Retention
California Privacy Rights
How To Contact Us
INFORMATION WE COLLECT
Information We Collect for Klaviyo’s Own Business Purposes
We may collect information about individuals who interact with Klaviyo when using our website or services (such as employees of our clients), job applicants, and other individuals.
How we collect the information
We may collect information:
Directly from individuals
From third party vendors, data brokers, or business partners
From recruiters
Types of information we collect
The types of information we collect include:
Personal and business contact information (such as name, business name, address, telephone number, email address, and mailing address)
Payment information (such as credit card or other financial account numbers)
We do not collect employee or HR related data in the EU or Switzerland, or transfer such information either into or out of the EU or Switzerland.
Information We Collect from or on Behalf of Our Clients
We may collect information about individual consumers from our clients or – at clients’ request– from their service providers. Our clients determine the scope of the information transferred to us, and the information we receive may vary by client. Typically, we may collect clients’ consumers’ contact details and demographic data, shopping histories, and details about consumers’ interactions with marketing communications.
COOKIES AND OTHER INFORMATION COLLECTED BY AUTOMATED MEANS
We, our service providers, and our business partners, may collect certain information about the use of our websites by automated means, such as cookies, web beacons and other technologies. Likewise, as part of our services, we may offer our clients the ability to install these types of technologies on their websites or in the emails they send to their customers; and if a client does so, we collect information on its behalf. A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We and our service providers and business partners may collect information about your online activities over time and across third-party websites when you use our websites and mobile applications.
Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please see the “Privacy Preferences, Rights and Choices” section below for information about how you may opt out of, or limit the use of, your browsing behavior for online behavioral advertising purposes.
The information we collect by automated means varies based on whether we are collecting information for our own business purposes or whether we are collecting information from or on behalf of our customers to provide our services.
Automated Data Collection for Klaviyo’s Own Business Purposes
The information collected by automated means for our own business purposes includes:
Details about the devices that are used to access our websites (such as the IP address, and type of operating system and web browser)
Dates and times of visits to, and use of, our websites
Information about how our websites are used (such as the content that is viewed on our websites and how users navigate between our webpages, and the date and time of access)
Details about how individuals interact with our emails (such as whether the email is opened and which links are clicked in the email)
URLs that refer visitors to our websites
Search terms used to reach our websites
Web browsers may offer users of our websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly.
Automated Data Collection on Behalf of Our Clients
The information collected by automated means on behalf of our clients may include:
Details about the devices that are used to access our clients’ websites (such as the IP address, and type of operating system and web browser)
Dates and times of visits to, and use of, our clients’ websites
Information about how our clients’ websites are used (such as the content that is viewed on our clients’ websites and how users navigate between webpages, and the date and time of access)
Details about how individuals interact with our clients’ emails (such as whether the email is opened and which links are clicked in the email)
URLs that refer visitors to our clients’ websites
Search terms used to reach our clients’ websites
Web browsers may offer users of our clients’ websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly.
OUR USE OF PERSONAL INFORMATION
Our Use of Personal Information for Klaviyo’s Own Business Purposes
We may use personal information to:
Provide our services to our clients
Communicate about the products and services we offer, and respond to requests, inquiries, comments, and suggestions
Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read)
Operate, evaluate and improve our business, our websites, and other products and services we offer (including to develop new products and services)
Invoice and collect payment for our services
Establish and maintain an individual’s profile in our service
Tailor the content we display in our communications, in our services and in mobile apps
Administer surveys and other market research
Comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests)
Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide
Process employment applications
Monitor recruiting statistics, to inform our recruitment activities
We may aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
Our Use of Personal Information on Behalf of our Clients
We use personal information we collect from or on behalf of our clients to provide services to our clients at their direction. We do not use this information for Klaviyo’s own purposes. We use personal information only as directed or authorized by our client. Typically, we are directed or authorized to use personal information collected on behalf of the client to:
Help customize marketing strategy for our clients
Personalize marketing content for our clients’ customers
Target customers for our clients’ marketing campaigns
Analyze and enhance our clients’ communications and strategies (including by identifying when emails sent to you have been received and read)
Analyze results from marketing campaigns for our clients
INFORMATION WE SHARE
We may share personal information for the purposes set out in this Privacy Notice with:
Service providers that perform services on our behalf, such as technology providers (including providers of payment processing, technology support, web hosting, and email communications)
Survey and market research providers
Advertising and marketing partners
Analytics organizations
Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will – where required by applicable law – make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Notice. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.
In addition, we may share your information to comply with legal and regulatory requirements, and protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.
CAREERS
If you submit your information in connection with job opportunities at Klaviyo, we will use and disclose the information to process your application (including to contact you and/or your references and former employers if appropriate), to monitor recruitment statistics, and to comply with government reporting requirements. We also retain statistical information about applicants to help inform our recruitment activities. We will process this information based on our legitimate interest of evaluating job candidates or, when you provide us with sensitive information, based on your consent.
PRIVACY PREFERENCES, RIGHTS, AND CHOICES
Individuals have certain rights and choices regarding Klaviyo’s processing of their personal information. Please note, however, that if the exercise of these rights limits our ability to process personal information, we may be precluded from providing our products or services to individuals who exercise these rights, or from otherwise engaging with such individuals going forward.
Individuals whose personal information Klaviyo processes on behalf of a client should contact that client to exercise the rights and choices described in this section.
We reserve the right to verify the identity of the individual in connection with any requests regarding personal information to help ensure that we provide the information to individuals to whom the information pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.
For information about the rights and choices users have with respect to cookies and online tracking, please see the “Cookies and Other Information Collected by Automated Means” section of this Privacy Notice.
General Objections to the Processing of Personal Information
To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to Klaviyo’s use or disclosure of your personal information will mean that Klaviyo will not be able to provide products or services to you or to otherwise engage with you.
Access to Personal Information
You may request access to correct, amend, or delete the personal information that we maintain about you. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your personal information. We may reject your request to access or correct your information, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection. If you wish to exercise this right please contact us here at privacy@klaviyo.com
We will also provide an EU or Swiss individuals with opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.
To limit the use and disclosure of your personal information, please submit a written request to privacy@klaviyo.com.
Portability of Personal Information
You may request that we transfer your personal information to another data controller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
Deletion of Personal Information
You may request that we delete your personal information. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
Marketing Emails
You may unsubscribe from receiving marketing or other commercial emails from Klaviyo by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our website terms).
Online Behavioral Advertising
Some of the business partners that collect information about users’ activities on our websites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior for purposes of targeted advertising. For example, users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
INTERNATIONAL DATA TRANSFERS
We may transfer personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. For example, if you are located outside of the United States, we typically transfer your personal information to the United States, where Klaviyo is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information.
EU-US PRIVACY SHIELD & SWISS-US PRIVACY SHIELD CERTIFICATIONS
Klaviyo participates in the EU-US Privacy Shield framework and Swiss-U.S. Privacy Shield framework.
Klaviyo complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or Switzerland to the United States. Klaviyo has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
In particular, if Klaviyo transfers to its service providers any personal information that Klaviyo received in reliance on its Privacy Shield certification, Klaviyo is responsible for the third parties’ processing of that personal information, unless Klaviyo proves that it is not responsible for the event giving rise to the damage. Please be aware that Klaviyo may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Klaviyo is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
In compliance with the EU-US and Swiss-US Privacy Shield Principles, Klaviyo commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Klaviyo at:
privacy@klaviyo.com
Klaviyo has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
As further explained in the Privacy Shield Principles more fully described here, you may be entitled to invoke binding arbitration pertaining to certain residual complaints that have not been resolved by any other means.
HOW WE PROTECT INFORMATION
We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we maintain against accidental, unlawful, or unauthorized access, disclosure, alteration, use, loss, or destruction. However, we cannot guarantee that the safeguards we maintain will ensure the security of the personal information.
LINKS TO OTHER WEBSITES AND THIRD-PARTY CONTENT
We may provide links to websites and other third-party content that is not owned or operated by Klaviyo. The websites and third-party content to which we link may have separate privacy notices or policies. Klaviyo is not responsible for the privacy practices of any entity that it does not own or control.
CHANGES TO OUR PRIVACY NOTICE
Klaviyo reserves the right to change this Privacy Notice at any time. When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided.
DATA RETENTION
We will retain personal information only for as long as necessary to fulfill the purpose(s) for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. We will then destroy the personal information or anonymize the information, in accordance with applicable law.
CALIFORNIA PRIVACY RIGHTS
California law permits visitors who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at privacy@klaviyo.com.
HOW TO CONTACT US
You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or if you wish to access, delete or correct you information, by emailing privacy@klaviyo.com.
If you are a resident within the European Economic Area, you also have the right to file a complaint with the supervisory authority of your member state.
Privacy Policy
This Privacy Policy was last updated on May 18, 2018. If you want an easier to digest format, read our Data Promise instead.
This website (the “Site”) is operated by Privy, Inc. (“Privy”, “we”, “us” and/or “our”) and has been created to provide our Site visitors (“you”, “your”) with information about our company and our e-mail collection tools. This Privacy Policy (this “Policy”) sets forth Privy’s policy with respect to information, including personally identifiable data (such personally identifiable data “Personal Information”), that is collected from you through the Site or through our other service offerings (collectively, including the Site, the “Services”). Certain Services may be made available to you on websites owned by our end customers (each, an “End Customers”), and the information collected via these embedded widgets (“Tools”) is directed to Privy and governed by this Policy.
The Services and our business may change from time to time. As a result, at times it may be necessary for Privy to make changes to this Policy. Privy reserves the right to update this Policy at any time and from time to time without prior notice. Please review this Policy periodically, and especially before you provide any Personal Information. This Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Policy shall indicate your agreement with the terms of such revised Policy.
1. Information Collected
When you interact with us through the Site or other Services, we may collect Personal Information and other information from you, as further described below:
Personal Information That You Provide:
We collect Personal Information from you when you voluntarily provide such information, such as when you contact us with inquiries, subscribe to our or a Privy End Customer’s e-mail newsletter, register for access to the Services or use certain Services. For instance, Privy may collect the following information about you: name, address, zip code, telephone number and e-mail address. The information collected may vary. For example, our End Customers may customize the data that is requested via the Tools and may collect other information, such as your favorite color or birthdate. Wherever Privy collects Personal Information we make an effort to provide a link to this Policy.
By voluntarily providing us with Personal Information, you are consenting to our use of it in accordance with this Policy. If you provide Personal Information to the Site or through the other Services, you acknowledge, agree, and expressly consent that such Personal Information may be transferred from your current location to the offices and servers of Privy and the authorized third parties referred to herein located in the United States.
Other Information:
Non-Identifiable Data: When you interact with Privy through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you, unless it is combined with Personal Information. Privy may store such information itself or such information may be included in databases owned and maintained by Privy affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. It is important to note that Privy uses no Personal Information in this process.
Cookies: In providing the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site or the Tools. Our cookies help provide additional functionality to the Services and help us analyze the Services usage more accurately. Certain information collected through the use of cookies may be used to serve you more relevant online advertisements by us or third parties. We may, or a third party may, place and recognize a unique cookie on your browser specifically to identify you for the purposes of providing you with customized ads or content across channels. The cookies may be linked to data you voluntarily submit to us, e.g., your email address, which we may share with a third party. If we share such Personal Information it will be in hashed, non-human readable form for security purposes only. If you'd like to opt-out of such collection and use of data, please go to the Digital Advertising Alliance’s consumer opt-out page here: www.aboutads.info/choices or the Network Advertising Initiative’s opt-out mechanism here: http://networkadvertising.org/optout_nonppii.asp. For the avoidance of doubt, except with respect to EU Data, we may share with third parties data collected from your use of websites of End Customers with third parties and such third parties might use that data, together with data collected by such third parties from other sources to cause advertisements to be targeted to you. Such data typically includes the URL you are on. As used herein, “EU Data” means data of data subjects located in the European Economic Area (including the United Kingdom as of the Effective Date of this Privacy Policy).
In addition, you can generally inform the web services with which our Services integrate (such as social buttons, widgets, and other embedded features or content) that you do not want certain information about your webpage visits to be collected. Enabling “Do Not Track” in your web browser settings is an easy way to accomplish this. The “Do Not Track” browser setting is supported by recent versions of major browsers, including Firefox 5+, Internet Explorer 9+, Safari 5.1+, and Google Chrome. Please consult http://donottrack.us on how to enable this privacy setting on your browser. You can also change the way your browser handles cookies. Already existing cookies can be deleted. Please consult www.allaboutcookies.org on how to manage or delete cookies in your browser. This Policy covers the use of cookies and similar files by Privy only and does not cover the use of cookies, flash cookies, and similar files by any third-party advertisers or websites linked to the Site. We also may use Google Analytics and other similar services. Google Analytics uses cookies to help analyze how users use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google, Inc. (“Google”). Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
Aggregated Personal Information: In an ongoing effort to better understand and serve the users of the Services, Privy often conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Privy may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Privy may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
2. Use of Information:
Privy uses the Personal Information you provide in a manner that is consistent with this Policy. If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Information you provide to answer your question or resolve your problem. In addition to the foregoing purposes, we and our affiliates may use your information to: (a) improve the content and functionality of the Services; (b) better understand our users; (c) improve our marketing and promotional efforts and customize the Services content, layout, and Services to better suit your needs; and (c) resolve disputes, troubleshoot problems and enforce our Service Terms (as defined below).
In addition, Privy and its affiliates may use your information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated.
3. Disclosure of Information
There are certain circumstances in which we may share your Personal Information or other information with third parties without further notice to you, as set forth below:
End Customers: If you enter your Personal Information in any Tool on an End Customer’s website, we may share such Personal Information with the applicable End Customer and such End Customer’s service providers, as requested by such End Customer.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.
Related Companies: We may also share your Personal Information with our affiliates for purposes consistent with this Policy.
Agents, Consultants and Related Third Parties: Privy, like many businesses, sometimes hires other companies or individuals to perform certain business-related functions. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: Privy may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, including lawful requests by public authorities, including to meet national security or law enforcement requirements, (b) protect and defend the rights or property of Privy, (c) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (d) protect against legal
4. Security
Privy takes reasonable steps to protect the Personal Information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Site may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Information to Privy via the Internet.
5. Third Party Sites
This Policy applies only to the Services. The Site and other Services, including the Tools, may contain links to other websites not operated or controlled by Privy, including those operated by End Customers (the “Third Party Sites”). The policies and procedures described here do not apply to the Third Party Sites or services, or to the use of information submitted via a Tool on such End Customer’s website by the applicable End Customer or its service providers. The links from the Site or placement of Tools on certain Third Party Sites does not imply that Privy endorses or has reviewed the Third Party Sites. We suggest contacting those sites, services, entities or persons directly for information on their privacy policies.
6. Children’s Online Privacy Protection
Privy does not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Policy by instructing their children never to provide Personal Information through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to Privy, please contact us, and we will endeavor to delete that information from our databases.
7. Exclusions
This Policy does not apply to any Personal Information collected by Privy other than Personal Information collected through the Services. This Policy shall not apply to any unsolicited information you provide to Privy through the Services or through any other means. This includes any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Privy shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
8. Access to Information; Contacting Privy
To keep your Personal Information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via the Services. Please also feel free to contact us if you have any questions about this Policy or the information practices of this Site. You may contact us as follows: support@privy.com.
9. Your California Privacy Rights
Applicable California privacy legislation permits visitors who are California residents to request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request to access such information, please contact us as follows: support@privy.com. Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
10. EU Personal Data
With respect to the processing of personal data relating to data subjects located in the European Economic Area (including the United Kingdom as of the Effective Date of this Privacy Policy) by Privy solely on behalf of the End Customer, the terms of the Data Processing Addendum shall apply. The following terms have the meanings given in the General Data Protection Regulation (EU) 2016/679 (“GDPR”): “personal data”, “data subject” and “process”.
Bumkins Finer Baby Products
5454 East Washinton Street
Suite #2
Phoenix, AZ 85034
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Phone: 480.481.3618 | 1.866.BUMKINS
Fax: 877.286.3511
Owner contact email: customerservice@bumkins.com