Privacy

PRIVACY POLICY

Last Updated: February 24, 2023

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE OR ENGAGE IN COMMUNICATIONS WITH US.

THE SITE IS INTENDED FOR USERS LOCATED IN THE UNITED STATES ONLY, AND THEY ARE NOT INTENDED FOR USERS LOCATED IN ANY OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA.

INTRODUCTION

Snubbies, LLC (“Snubbies” also referred to as “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to information you about how we treat your personal information.  We have established this Privacy Policy (“the “Policy”) to inform you about the privacy practices that we apply to personal information and inform you about your rights and choices in this regard.

Personal information means any information or set of information, whether alone or in combination with other Personal Information, processed by Snubbies, which is sufficient to identify an individual (“Personal Information”). Personal Information does not include information that is anonymous, nor does it include publicly available information that has not been combined with non-public Personal Information.

What processing activities are covered by this Policy?  This Policy applies to the processing of Personal Information when you visit our website https://www.snubbies.com/ and any features, subdomains, content, functionality, services, media, applications, or solutions offered on or through the website (collectively referred to as the “Site”) as well as when you use our services or purchase our products.  By accessing and using the Site, using our services, purchasing our products, or by otherwise signaling your agreement when the option is presented to you, you consent to the collection, use and disclosure of information described in this Policy. This Policy only governs the Site, and it does not govern other off-line data collection, or any other website or service operated by third parties that do not specifically refer to this Policy. Any materials submitted through the Site and your use of the Site are subject to the Terms of Use [hyperlink].

Processing” shall mean any operation or set of operations that is performed upon Personal Information or sets of Personal Information, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction and the verb “to process” shall be construed accordingly.

HOW DO WE COLLECT AND USE PERSONAL INFORMATION?

We collect and process the following Personal Information from you for the purposes set forth below.

Category

Description and Purpose

Contact Information

When you visit the Site, subscribe to newsletters/alerts, use our services, purchase our products, complete a contact form on our Site, or otherwise contact us, we will collect your name, username, email, phone number, or other contact details.

 

We process Contact Information to operate our Site and business, to provide our Site and services, to respond to your request, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Account Information

 

In order to access and use certain features of the Site, you may have to t complete a registration.  When you create an account and register with us, we may collect your Contact Information and the username and password that you create.

 

We process Account Information to operate our Site and business, to provide our Site and services; to ensure the privacy and security of our Site and services, to maintain our databases and back-ups; to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Transaction Information

When you make a purchase, or conduct a transaction on the Site, in addition to your Contact Information, we, or our third party payment processor as applicable, may collect your first and last name, address, state of residence, date of birth, picture, payment information (credit card number, security code, and expiration date), and verification information required by law, which may include your social security number and a copy of your government issued ID. We also keep a record of your transactions on the Site, which may be associated with your Account Information. 

 

We use Transaction Information to operate our Site and business, to respond to your request, to ensure the privacy and security of our Site and services, to verify your identity, to process payments and transactions, to detect fraud and prevent loss, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the compliance with legal obligations to which we are subject, and the performance of a contract between you and us and/or taking steps at your request, to enter into such a contract.

Cookies and Similar Technologies

We use cookies and use similar technologies as described in the “Cookies and Similar Technologies” section of this Policy. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly.

Device and Usage Information

When you visit the Site, we automatically collect information from your browser and your device, which includes the date and time of your visit as well as your location, Internet Protocol (IP) address or unique device identifier, domain server, browser type, access time, and data about which pages you visit.

 

We process Device and Usage Information to operate our Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site, to develop new services, to enhance your experience and provide you with a more personal and interactive experience, and for usage analytics purposes. The legal basis for this processing is our legitimate interests in monitoring and improving our Site.

Communications and Inquiries

If you contact us, in addition to your Contact Information, we will receive the subject matter of your message and any comments, content, or other information that you choose to provide.

 

We process Communications and Inquiries to operate our business, to respond to your request, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

 

Other Processing Activities. We may also process Personal Information when necessary for the following:

  • The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for this processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.)
  • Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper protection of our business.)
  • Compliance with federal, state, or local laws (The legal basis for this processing is compliance with a legal obligation to which we are subject.)
  • Compliance with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities and cooperation with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate federal, state, or local law (The legal basis for this processing is compliance with a legal obligation to which we are subject.)
  • Collection, use, retention, or disclosure of information that is deidentified or aggregated.
  • Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your Personal Information was provided to us.

We may process your Personal Information in connection with any of the purposes and uses described in this Policy on one or more of the following legal grounds:

  • Because it is necessary to perform the tasks you have requested or to comply with your instructions or other contractual obligations between you and us;
  • To comply with our legal obligations as well as to keep records of our compliance processes;
  • Because our legitimate interests, or those of a third-party recipient of your Personal Information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
  • Because you have chosen to publish or display your Personal Information on a public area of the Site, such as a comment area;
  • Because it is necessary to protect your vital interests;
  • Because it is necessary in the public interest; or
  • Because you have expressly given us your consent to process your Personal Information in a particular manner.

We do not use Personal Information for making any automated decisions affecting or creating profiles other than as described herein.

Location of Processing. We are headquartered and have operations in the United States, and Personal Information may be transferred to, stored, and processed in the United States in locations in which we or our partners, service providers, or agents maintain facilities. By sending us Personal Information or using the Site, you agree and consent to the processing of your Personal Information in locations in the United States. We rely on recognized legal bases to lawfully process and transfer your Personal Information, such as express consent, when transfer is necessary for us to deliver services pursuant to an agreement, or when the transfer is subject to safeguards that assure the protection of the Personal Information.

Cookies and Similar Technologies

What are first and third-party cookies? A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). “Session” cookies are temporarily stored on your device and remain there until they expire at the end of your browsing session. “Persistent” cookies remain stored on your device until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

What are “similar technologies”? In addition to cookies, there are other data collection technologies, such as Internet tags, web beacons, pixels (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.

 Other third-party technologies. Some third parties may use data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

What cookies and similar technologies are in use on the Site? The Site use the cookies and similar technologies to improve functionality, to measure and track how you interact with the Site, to perform analytics, to market to you, to track ad-driven activity, and to otherwise tailor our communications with you.

SMS Text Advertising: The website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.

The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Social Media Cookies and Similar Technologies. The Site uses Social Media cookies and other similar technologies to collect information about your use of social media websites.

Analytics Cookies and Similar Technologies.  Analytics cookies and other similar technologies used by us collect information about your use of the Site and enable us to improve the way they work and operates. Specifically, analytics cookies provide us with information regarding what the most frequently visited pages on the Site are, help us record and debug any issues you may have with the Site, and show us how effective our advertising is. These analytics cookies do not allow us to see the usage of a single user but does allow us to see overall patterns of usage on the Site. We do not examine this information for individually identifying information, but we do use this information to understand the traffic on our Site.

Advertising Cookies and Similar Technologies. Advertising and other similar technologies used by us are used to display targeting promotions or advertisements based on your use of the Site and interests and to manage our use of advertising resources. These cookies collect information about your activities on this and other sites to provide you with interest-based advertising. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

Facebook. We use Facebook’s technologies to serve relevant advertisements and to track Facebook ad-driven visitor activity. Facebook Connect also gives you the option to post information about your activities to your profile page to share with others within your network by using a single sign-in service to authenticate your identity. You may learn more about Facebook’s policies by visiting https://www.facebook.com/policy.php, and you can also find instructions for opting out of receiving advertisements via that page.

Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and to better understand how they find and use the Site. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions. The information stored is reduced to a random identifier. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page located at https://support.google.com/analytics/answer/181881?hl=en.

Google Tag Manager. We use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) does not use cookies and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal data under certain circumstances. Google Tag Manager does not access this information.  Google Tag Manager is subject to the Google Privacy Policy located at https://www.google.com/intl/en/policies/privacy.

Google Marketing. We use Google’s marketing technologies (DoubleClick) to track user activity and to serve personalized advertisements. Your browser is assigned a pseudonymous ID, which is used to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information on how Google uses this information, you can visit https://policies.google.com/technologies/ads and https://support.google.com/displayvideo/answer/7621162. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922 and https://adssettings.google.com. Google’s Privacy Policy is available at: https://www.google.com/policies/privacy.

LinkedIn Analytics. We use LinkedIn’s technologies for analytics and to add tags to our Site to allow for conversion tracking of LinkedIn ad campaigns. These tools allow us to learn about user activity and LinkedIn audiences, to find trends in user engagement, and to analyze trends with those groups. For more information on LinkedIn’s marketing technologies and to view LinkedIn’s Privacy Policy, visit https://www.linkedin.com/legal/privacy-policy. You can opt-out of LinkedIn Ads by visiting https://www.linkedin.com/help/linkedin/answer/62931?trk=microsites-frontend_legal_privacy-policy&lang=en.

Amazon Analytics

Shopify Analytics.  We use Shopify Analytics to learn about user activity and purchase activity and to receive behavior reports, marketing reports, order reports, sales reports, information related to product analytics.  These tools allow us to analyze our Site’s and product store’s recent activity and analyze performance metrics.  For more information, visit https://www.shopify.com/legal/privacy/customers.

Choices About Cookies. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being stored. These settings may affect your enjoyment of the Site’s functionality. Adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings. The links below provide additional information about how to disable cookies or manage the cookie settings:

Google Chrome:          https://support.google.com/chrome/answer/95647?hl=en

Firefox:                       https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Microsoft Edge:           https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09 

Safari:                         https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac  and https://support.apple.com/en-us/HT201265

For more information about how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at https://youradchoices.com/control, https://thenai.org/about-online-advertising/faq, and http://www.networkadvertising.org/choices.

Online Tracking Signals. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on the Site or on third-party websites or online services where we may collect information.

Accuracy and Updating Your Personal Information. Our goal is to keep your Personal Information accurate, current, and complete. If any of the Personal Information you have provided to us changes, please update it in your user/account profile, or let us know via the “Contact Us” details at the end of this Policy.  For instance, if your email address changes, you may wish to let us know so that we can communicate with you.  If you become aware of inaccurate Personal Information about you, you may want to update your information.  We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Complaints. If you believe that your rights relating to your Personal Information have been violated, you may lodge a complaint with us by contacting us via the “Contact Us” details at the end of this Policy.

HOW DO WE SHARE YOUR PERSONAL INFORMATION?

When we are acting as the data controller or where permitted by applicable law, we may share each of the categories of Personal Information described above in the following contexts. 

Category

Disclosure Contexts

Corporate Affiliates

We share Personal Information with our corporate subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents.

Acquisitions and Similar Transactions

We may disclose your Personal Information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Disclosures with Your Consent

We may ask if you would like us to share your Personal Information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your Personal Information in this context with your consent.

Legal Obligations and Rights

We disclose Personal Information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share Personal Information in order to establish or exercise our legal rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of contract. We may also disclose Personal Information as needed to protect vital interests.

Service Providers

We share Personal Information with our agents, contractors and service providers. Among other things, service providers help us to administer the Site; support our provision of services; send marketing communications; provide technical support; and assist with other legitimate purposes permitted by law.  For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.

Professional Advisors

We share Personal Information with our insurers and other professional advisors, including attorneys, accountants, consultants, and auditors, that need access to your information to provide operational or other support services on our behalf.

Deidentified or Aggregated Data

We share aggregated information and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, (i) for compliance with reporting obligations; (ii) for business or marketing purposes; and (iii) to assist us and others in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, marketing, and/or functionality.

 

HOW LONG DO WE PROCESS YOUR INFORMATION?

We retain and use your Personal Information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.

We take reasonable steps to delete the Personal Information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your Personal Information if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Information is contrary to our legal obligations or business objectives.

To the extent permitted by law, we may retain and use anonymous, de-identified, and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement. When we delete data, it will be removed from our active servers and databases; but it may remain in our archives when it is not practical or possible to delete it.

We are required by law to maintain records of consumer requests submitted under the California Consumer Privacy Act and how we responded to such requests for at least 24 months. We only use this information for recordkeeping purposes.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We have put security measures in place to protect Personal Information from being accidentally lost, used, altered, or disclosed or accessed in an unauthorized manner and to detect fraudulent identify-verification activity, including when transmitting Personal Information in response to data subject requests. From time to time, we review our security procedures to consider appropriate new technologies and methods.

However, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect Personal Information, we cannot guarantee or warrant the security of any information transmitted to or from the Site or services. Your use of the Site is at your own risk. We cannot guarantee that your data will remain secure in all circumstances. 

The safety and security of your Personal Information also depends upon you.  Where you use a password for access to restricted parts of the Site, you are responsible for keeping your password confidential.  Do not share your password with anyone.

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

YOUR RIGHTS AND CHOICES

Please use the “Contact Us” details at the end of this Policy to exercise your rights and choices under this Policy.

Email Preferences. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails or by contacting us via the “Contact Us” details at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.

Accuracy and Updating Your Personal Information. Our goal is to keep your Personal Information accurate, current, and complete. If any of the Personal Information you have provided to us changes, please update it in your user/account profile, or let us know via the “Contact Us” details at the end of this Policy. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Complaints. If you believe that your rights relating to your Personal Information have been violated, you may lodge a complaint with us by contacting us via the “Contact Us” details at the end of this Policy.

Individual Rights. You may have certain rights relating to your Personal Information under local data protection laws, and we discuss the rights provided in various jurisdictions below. We honor individuals’ rights where required under applicable law, and, depending on the applicable laws, these rights may include the right to:

  • Access your Personal Information;
  • Know more about how we process your Personal Information;
  • Rectify inaccurate Personal Information and, taking into account the purpose of processing the Personal Information, ensure it is complete;
  • Erase or delete your Personal Information;
  • Restrict our processing of your Personal Information;
  • Transfer your Personal Information to another controller, to the extent possible;
  • Object to certain processing of your Personal Information;
  • Opt-out of certain disclosures of your Personal Information to third parties;
  • If you’re under the age of 16, or such other applicable age of consent, opt-in to certain disclosures of your Personal Information to third parties;
  • Not be discriminated against for exercising your rights described above;
  • Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects; and
  • Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

All requests should be sent to the contact details noted in the “Contact Us” section of this Policy. Your Personal Information may be processed in responding to these rights. If you are exercising a right that is the responsibility of a third party, including one of our customers, we will direct you to contact the appropriate data controller who is responsible for responding to your request.

California Residents

All terms used in this section shall have the meanings given in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”), when applicable. 

CCPA Notice at Collection. We collect and process Personal Information for as described in the “How Do We Collect and Use Personal Information” section of this Policy. The relevant CCPA categories for this information are listed below. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes.

Category

CCPA Categories

Contact Information

For purposes of the CCPA, Contact Information includes the following categories of personal information:

·       Identifiers

·       Personal Information Under California’s Customer Records Statute

·       Professional or Employment-related Information

Account Information

For purposes of the CCPA, Account Information includes the following categories of personal information:

·       Identifiers

·       Internet or Other Electronic Network Activity Information

Transaction Information

For purposes of the CCPA, Transaction Information includes the following categories of personal information:

·       Identifiers

·       Personal Information Under California’s Customer Records Statute

·       Commercial Information

·       Audio, Electronic, Visual, or Similar Information

·       Biometric Information

·       Geolocation Data

·       Sensitive Information

Cookies and Similar Technologies

For purposes of the CCPA, Cookies and Similar Technologies includes the following categories of personal information:

·       Identifiers

·       Internet or Other Electronic Network Activity Information

·       Geolocation Data

·       Sensitive Information

Device and Usage Information

For purposes of the CCPA, Device and Usage Information includes the following categories of personal information:

·       Identifiers

·       Internet or Other Electronic Network Activity Information

·       Geolocation Data

·       Sensitive Information

Communications and Inquiries

For purposes of the CCPA, Communications and Inquiries includes the following categories of personal information:

·       Identifiers

·       Personal Information Under California’s Customer Records Statute

·       Commercial Information

·       Audio, Electronic, Visual, or Similar Information

·       Professional or Employment-related Information

Job Applicant Information

For purposes of the CCPA, Job Applicant Information includes the following categories of personal information:

·       Identifiers

·       Personal Information Under California’s Customer Records Statute

·       Professional or Employment-related Information

·       Education Information

 

Data Practices During Last 12 Months. The disclosures below describe our data practices during the last twelve months:

  • Personal Information Collected: We have collected the categories of Personal Information listed below during the preceding 12 months:
    • Identifiers
    • Personal Information Under California’s Customer Records Statute
    • Commercial information
    • Internet or other electronic network activity information
    • Geolocation data
    • Audio, electronic, visual, thermal, olfactory, or similar information
    • Professional or employment-related information
    • Education Information
    • Sensitive Information
  • Categories of Sources: We have collected the Personal Information identified in this Policy from you, our customers, and from other third-party sources, including data partners.
  • Business and Commercial Purposes for Collecting: We have collected the categories of Personal Information listed above for the following purposes:
    • To operate our Site and business
    • To provide our Site and services
    • To respond to your request
    • To ensure the privacy and security of our Site and services
    • To maintain our databases and back-ups
    • To manage our relationships with you
    • To communicate with you
    • To keep records of our communications with you
    • To verify your identity
    • To process payments and transactions
    • To detect fraud and prevent loss
    • To serve you the content and functionality you request
    • To develop new services
    • To serve you the content and functionality you request
    • To enhance your experience and provide you with a more personal and interactive experience
    • Usage analytics purposes
    • To verify your eligibility and suitability for employment or other relationships with us
    • To comply with your instructions or requests
  • Personal Information Sold or Shared: We have not sold or shared categories of Personal Information during the preceding 12 months.
  • Personal Information Disclosed for a Business Purpose. We have disclosed for a business purpose the categories of Personal Information listed below during the preceding 12 months. We have shared these categories of Personal Information with the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) service providers (data analytics, data storage, mailing, marketing, payment processing, Site administration, technical support); and (4) operating systems and platforms.
    • Identifiers
    • Personal Information Under California’s Customer Records Statute
    • Commercial information
    • Internet or other electronic network activity information
    • Geolocation data
    • Audio, electronic, visual, thermal, olfactory, or similar information
    • Professional or employment-related information
    • Education Information
    • Sensitive Information
  • Business and Commercial Purposes for Disclosing: We have disclosed to the identified categories of third parties the categories of Personal Information listed above for the following purposes:
    • To operate our Site and business
    • To provide our Site and services
    • To respond to your request
    • To ensure the privacy and security of our Site and services
    • To maintain our databases and back-ups
    • To manage our relationships with you
    • To communicate with you
    • To keep records of our communications with you
    • To verify your identity
    • To process payments and transactions
    • To detect fraud and prevent loss
    • To serve you the content and functionality you request
    • To develop new services
    • To serve you the content and functionality you request
    • To enhance your experience and provide you with a more personal and interactive experience
    • Usage analytics purposes
    • To verify your eligibility and suitability for employment or other relationships with us
    • To comply with your instructions or requests

Financial Incentives. We offer various financial incentives. The terms of the financial incentive will be presented to you at the time you sign up. You may withdraw from any of the financial incentives by contacting us at 888-483-4969 or by email to support@snubbies.com. The value of your data is the value of the offer presented to you. We have calculated the value of the incentive by using the expense related to the offer..

Do Not Sell or Share My Personal Information. Under the CCPA, you have the right to direct us to stop selling or sharing your Personal Information to third parties and to refrain from doing so in the future. For purposes of the CCPA, we do not sell or share Personal Information as defined under applicable law.

Limited Use of Sensitive Information. We only use or disclose Sensitive Personal Information for purposes permitted by the CCPA and to which the right to limit does not apply.

CCPA Individual Rights. California consumers have the rights described below. However, these rights do not apply in all instances and are subject to certain exceptions as a matter of law. By way of example, these rights do not apply where we collect or sell a consumer’s Personal Information if: (1) we collected that information while the consumer was outside of California, (2) no part of a sale of the consumer’s Personal Information occurred in California, and (3) no Personal Information collected while the consumer was in California is sold. 

Request to Know. As a California resident, you have the right to request: (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we have collected about you; (3) the categories of sources from which the Personal Information is collected; (4) the categories of Personal Information about you that we have sold or shared and the categories of third parties to whom the Personal Information was sold or shared; (5) the categories of Personal Information about you that we disclosed for a business purpose and the categories of third parties to whom the Personal Information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, selling, or sharing Personal Information; and (7) the categories of third parties to whom we disclose Personal Information. Our response will cover the 12-month period preceding our receipt of a verifiable request unless a longer period is requested by you.

Request to Delete. As a California resident, you have a right to request the erasure/deletion of certain Personal Information collected or maintained by us. As described herein, we will delete your Personal Information from our records and notify any service providers and contractors (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.

Right to Correct. As a California resident, you have a right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes for which we process the Personal Information. We will use commercially reasonable efforts to correct the inaccurate Personal Information as directed by you.

Right to Limit Use and Disclosure. As a resident of California, you have the right to limit our use and disclosure of your Sensitive Personal Information to that use which is necessary to perform our services and provide our goods as requested by you, or as otherwise permitted by law. We only use or disclose Sensitive Personal Information for purposes permitted by the CCPA and to which the right to limit does not apply.

Right to Opt Out. As a resident of California, you have the right to direct us to stop selling or sharing your Personal Information to third parties and to refrain from doing so in the future. For purposes of this right, we do not sell or share Personal Information as defined under applicable law.

Submission Process. You may submit a request to exercise one of the above rights via a toll-free telephone call to 888-483-4969, by email to support@snubbies.com, or by submitting your request through the chat function available on our Site. If a request is submitted in an incorrect manner or if it is deficient, we will either (1) treat the request as if it had been submitted via the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies, as applicable.

Verification Process. We are required to verify the identities of those who submit requests to exercise the above rights. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the Personal Information that we already maintain about you. As a part of this process, you will be required to provide your name, address, and telephone number. We will inform you if we cannot verify your identity.

  • If we cannot verify the identity of the person making a request for categories of Personal Information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our Privacy Policy.
  • If we cannot verify the identity of the person making the request for specific pieces of Personal Information, we are prohibited from disclosing any specific pieces of Personal Information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of Personal Information about the consumer.
  • If we cannot verify the identity of the person making a request to delete, we may deny the request.
  • If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.

Authorized Agents. Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Time Period to Comply with Requests.  Snubbies will disclose and deliver the required information as requested by you pursuant to this Section free of charge, correct inaccurate Personal Information, or delete your Personal Information, based on your request, within 45 days of receiving a verifiable request, but will confirm receipt of your request within 10 business days of receipt of same. We will promptly take steps to determine whether the request is a verifiable consumer request, as set forth herein, but this shall not extend our duty to disclose and deliver the information, to correct inaccurate Personal Information, or to delete Personal Information within 45 days of receipt of the request. However, the time period to provide the required information, to correct inaccurate Personal Information, or to delete Personal Information may be extended once by an additional 45 days when reasonably necessary, provided we provide you with notice of the extension within the first 45-day period.

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers, employees, applicants, or independent contractors for exercising their rights under the CCPA.

California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide Personal Information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your Personal Information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at support@snubbies.com.

Nevada Residents

You may submit a verified request to us at support@snubbies.com to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.  However, please know that we do not currently sell data triggering the Nevada statute’s opt-out requirements.

Colorado, Connecticut, Virginia, and Utah

If you are a resident of Colorado, Connecticut, Utah or Virginia, you may have certain privacy rights under the applicable privacy laws in your state (“State Privacy Laws”). This section describes those rights and how you can exercise them with Snubbies.

Rights Requests

Right to Know, Right to Deletion and Right to Correct

You can request what Personal Information we have collected, used, disclosed, and sold.

You can request to correct inaccuracies in your Personal Information, taking into account the information’s processing purpose.

You can opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects including, but not limited to, automated processing performed on personal information to evaluate, analyze or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location or movements (“Profiling”). To submit a request to opt out pursuant to this section, please contact us using the information provided in the Contact Us section of this Policy.  To opt out of cookie-based or digital advertising-based Profiling, please opt out of the selling/sharing of your information for targeted advertising, as described above. Note that if you opt out of profiling, your experience with Snubbies will be less personalized.

We will not be able to opt you out of Profiling where one of the following exceptions applies:

  • Legal: To comply with applicable laws, rules or regulations; to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by governmental authorities; to cooperate with law enforcement; to investigate, exercise, prepare for or defend actual or anticipated legal claims; or to assist another party with any of its obligations under applicable laws;
  • Security: To prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, or malicious, deceptive, or illegal activity; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;
  • Improvement of Services and Products/Internal Use: To conduct internal research to improve, repair or develop products, services or technology;
  • Transactional: To provide a product or service specifically requested by you; to complete a transaction with you or to complete a contract we have with you; and
  • Public Interest: To protect your vital interests or those of another individual.

You can also request that we delete your Personal Information. We may not delete all of your Personal Information if one of the following exceptions applies:

  • Transactional: To complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you;
  • Security: To detect data security incidents; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;
  • Error Correction: To debug or repair any errors;
  • Legal: To protect against fraud, harassment, malicious or deceptive activities, or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; to assist another party with any of its obligations under applicable privacy laws; or
  • Internal Use: To use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e., to improve our services).

Right to Appeal 

If you are a Colorado, Connecticut or Virginia resident and we were unable to fulfill your request, you may appeal our request by contacting us using the information provided in the Contact Us section of this Policy within fourteen days of our decision, and submitting an appeal request, with a detailed reason for your appeal, as well as your state of residence.

Retention

We will store your Personal Information for as long as is reasonably necessary to fulfill the purposes described in this Privacy Policy or as required by law.

Financial Incentives. We offer various financial incentives. The terms of the financial incentive will be presented to you at the time you sign up. You may withdraw from any of the financial incentives by contacting us at 888-483-4969 or by email to support@snubbies.com. The value of your data is the value of the offer presented to you. We have calculated the value of the incentive by using the expense related to the offer.

To exercise any of these rights or to appeal a decision regarding a consumer rights request, please Contact Us using any of the methods listed in Contact Us section of this Policy.

THIRD-PARTY SITE AND SERVICES

This Policy does not apply to any third-party websites or applications. The Site may contain links to, and media or other content from, third parties. These links are to external resources and third parties that have their own privacy policies. Because of the dynamic media capabilities of the Site, it may not be clear which links are to external, third-party resources. If you click on a third-party link, you will be redirected away from the Site. You can check the URL to confirm whether you have left the Site.

We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on the Site.

Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use.

CHILDREN

Our Site and services are not directed to children under the age of 13, nor is information knowingly collected from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or provide any information to us. If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we have any received information from a child under the age of 13, please contact us using the “Contact Us” details provided below.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

UPDATES AND CHANGES TO THIS POLICY

We may add to, change, update, or modify this Policy from time to time. We will post all changes to this Policy on this page, and the updated policy will be effective immediately upon posting. If we make material changes, we will also notify you through a notice on the homepage of the Site for a reasonable period of time. We may also, in our discretion, notify you of changes to this Policy via email.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of its current terms. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to any changes and to our collection and sharing of your information according to the then-current Policy. If you do not agree with this Policy and our practices, you should not use the Site.

CONTACT US

If you have any questions or concerns, wish to exercise your rights, or want to submit a complaint, please contact us using the information below, and we will do our best to assist you.  When you contact us, please describe in as much detail as possible the nature of your inquiry. We will investigate your inquiry promptly.

In Writing:      Snubbies, LLC

                        4117 Hillsboro Pike, Ste 103-328 Nashville, TN 37215

By Email:        support@snubbies.com

Telephone:     888-483-4969