Last updated April 23, 2021
- websites, portals, mobile applications, channels, and software, including https://www.highlandersdistro.com, social media pages and channels (collectively, the “Sites”); and
- any services, features, media, functions, content, tools, and links contained or offered in the Sites (collectively, the “Services”); and
- if applicable, mobile applications (“Apps”).
No use of the Sites or Services by Persons Under 18 or 21, As Applicable
The Sites, Services and Apps are intended for persons that are no less than eighteen (18) years of age or twenty-one (21) years of age for certain affiliated Sites and Services which may require you to be at least twenty-one (21) years of age to access and use such Sites and Services. Please check the applicable terms and conditions for such sites and services for further information. Individuals under the age of eighteen (18) (or twenty-one (21) for applicable Sites and Services) are prohibited from creating a User Account and profile, accessing the Sites or Services, and/or ordering products on the Transactable Sites. If you become aware that an underage user has created a User Account using false, stolen, or otherwise misleading information, please contact us immediately a email@example.com
What Information Do We Collect?
We may collect certain types of information in order to better provide our Sites and Services to all our users. How this personal information is used depends on your use of the Sites and Services.
Information You Provide: We collect personal information that you voluntarily provide to us when registering on any of the Site or Services, which can include the following:
- Account Data: If you create an account on any of the Sites or Services (a “User Account”), you may submit your full name, phone numbers, e-mail address, home address, phone number, zip code, gender, a profile bio, and birth date. Some users may also be required to submit a (i) means of age verification (e.g., driver’s license) or (ii) medical marijuana recommendation, including their recommending doctor’s name and license number, contact information, verification methodology, and verification number (“Medical Marijuana Information”).
- Credentials: We may collect passwords, password hints, and similar security information used for authentication and account access.
- Public Content. The information that you contribute or post on the Sites or Services that is intended for public consumption, including your reviews, tips, photos, videos, check-ins, comments, likes, posts, events, bookmarks, friends, lists, compliments, and User Account name and profile photo.
- Transaction and Payment Information: If you initiate a transaction through any of our Sites or Services (the “Transactable Sites”), whether the transaction is an order placed with a participating vendor (“Vendor”) or an order placed directly with us, you may submit personal information such as your name, telephone number, billing address, shipping address, delivery address, e-mail address and identification cards. Some users may also submit Medical Marijuana Information for orders placed through any of our Sites or Services.
- Transactional Information – Generally: From time to time, we may make available certain promotional campaigns, contests, sweepstakes or request your participation in surveys or advocacy efforts and require participants to provide certain personal information, such as your full name, phone number, mailing address, e-mail address, and professional information.
Information Created While Using the Sites and Services:
- Communications: When you sign up for a User Account or use certain features, you can opt-in to receive social, transactional, marketing, or administrative messaging from other Company users, businesses, and the Company itself. You may also exchange messages with the Company administrators, or other users. Messages that you exchange through the Sites or Services are saved. If you send or receive messages through the Sites or Services via SMS text message, we may log phone numbers, phone carriers, and the date and time that the messages were processed. We may also store the information that you provide when you communicate with us, including phone calls, letters, e-mails, and other electronic messages, or in person. This may be used to send you newsletters, surveys, offers, and other promotional materials. You may always opt-out of our direct marketing e-mails by following the instructions contained within our promotional e-mails, SMS text messages or, in some cases, by logging into your User Account and changing your communication preferences.
- Location Data: When using the Sites and Services, we may collect your IP Address, location data advertised by web browsers and mobile devices, your physical address if you provide it to us, and similar location data to identify your location in order to provide location-based services, such as showing you Services or products available in your area, customizing in-store experiences, delivering products to you at your request, and analyzing your use of our Sites and Services. You understand that some of our Services require knowing your location to function properly, so if you disable location features of your computer, phone, or browser, some of our Services may become unavailable to you.
- Browsing Data: We may automatically collect information about you when you use the Sites and Services. In addition to transactional and location information described above, the information we automatically collect includes log data and device information including browser type, domain name, the website that led you to our Sites, the website to which you go after leaving our Sites, the dates and times you access our Sites, device ID, and browsing activities within our Sites or Services (e.g., links you click, searches you run, the date and time of your visit or order, the amount of time you spend on specific pages, the businesses you call, e-mail, or chat using our Sites or Services, including our mobile applications, and the orders and purchases you make through our Sites or Services). We may collect certain information with the help of cookies and other web technologies–please see our Cookies Policy below for more information.
- Order History: Some users may also submit data that may be considered personal medical information, such as medical marijuana recommendations for orders placed through the Transactable Sites. This can include order history. We use this information to facilitate your transaction, from receiving orders to sending communications about them to you. Things like order history can help populate forms for future transactions. Some of this information will be shared with third parties, to help facilitate the transaction you initiate.
Information Collected by Third Parties:
- Payment Data: When placing orders through our Transactable Sites, some credit card transactions and order fulfillment are handled by established third-party Vendors, including banking managers, processing agents, and distribution institutions, who then shares that information with us. Vendors only the information required to verify and authorize your credit card or other payment information and to process and ship your order. We encrypt this information using industry-standard technology but use of your credit card information is governed by the privacy policies o that Vendor.
- Vendors: Vendors may provide us with information about you – either directly or indirectly through their service providers. Retailers may store personal information about you when you use a point-of-sale service provider, such as POSaBIT, Paytender, Shift Processing, Vector Processing or SQUARE, which are third party service providers that provides point-of-sale services to enable Vendors to process and fulfill transactions, manage inventory, maintain records, and report transactions in compliance with applicable law. Vendors may direct their point-of-sale service provider to share such personal information with us in order to ensure our and our service provider’s records regarding your order are consistent so we can efficiently and effectively facilitate your order fulfillment.
- We may collect information regarding your push notifications, when you use our Apps. If you use our Apps, we may also request to send you push notifications regarding your account or mobile application. If you wish to opt-out of receiving these types of communications, you may turn these notifications off from within your device’s settings.
How We Use Your Information
We use personal information collected via our Sites and Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive to:
- Facilitate account creation and logon process with your third-party accounts (such as your Google or Facebook account).
- Send you marketing and promotional communications from us our third-party marketing partners in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.
- Improve, upgrade, and enhance our Sites and Services.
- Track your usage of the Sites and Services and analyze system administration, debug, and identify repairs, and back up our systems to allow for disaster recovery.
- Send administrative information to you such as information about new products, services, and features or about changes to our terms, conditions, and policies to promote the Sites and Services.
- Fulfill and manage your orders payments, returns, and exchanges made through the Sites and Services.
- Deliver targeted advertising, content, and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
- To post testimonials on our Sites, Services or Apps that may contain personal information provided we obtain your consent to use your name and testimonial.
- Administer prize draws and competitions using your information to administer prize draws and competitions when you elect to participate in competitions.
- Request Feedback by contacting you about your use of our Sites, Services or Apps.
- Respond to legal requests and prevent harm.
- Prevent illegal activities by detecting security incidents to protect, investigate, prevent, and potentially take action against possible deceptive, fraudulent, unauthorized, malicious or illegal activities, and to respond to claims that Site or Services content is inauthentic, counterfeit, or otherwise violates the rights of third parties.
- Manage user accounts and keeping them it in working order.
- Engage in other legitimate business activities as permitted by law.
Marketing SMS Text Messages
If you provide your mobile phone number and agree to receive Company marketing SMS text messages, your agreement serves as written consent for the Company to send you recurring special offers and other marketing SMS texts. Messages may be sent using an automatic telephone dialing system. Your consent is not required as a condition to purchase to products. Message and data rates may apply. To unsubscribe from marketing text messages, reply with the word STOP.
How We Share your Information
We only share information with your express consent in limited circumstances, to comply with laws, and to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal bases:
- Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
We may need to process your data or share your personal information with Third Parties in the following situations:
- We may share your personal information at your direction, including with third parties such as Vendors to fulfill orders or requests you place on our Sites or Services. Similarly, by participating in one of our campaigns or programs, you direct us to share your information as contemplated in that campaign or program.
- If you use our Sites or Services to place an order for cannabis or non-cannabis products from us and there is designated a point-of-sale system we integrate with as our service provider, we will share information from or about you with these third-party service providers so that they may facilitate your requested transaction, including by providing information such as tax calculations and product availability as well as real-time status updates. For orders of cannabis products, the applicable point-of-sale service provider may also use your order-related information as required to process and report cannabis transactions under applicable law. Most of your order information will only be shared with a point-of-sale service provider after you submit your order, but we will share your delivery zip or postal code, certain Medical Marijuana Information, and requested products, and any other information required to provide accurate tax calculations in the jurisdiction in which your order is placed, in advance of order submission in order to obtain tax calculations, product availability, and other information relevant to your potential order. (Your Medical Marijuana Information is not used for marketing purposes, other than in the aggregate, or at your request, or with your consent.) Vendors may also directly share your order-related information with their point-of-sale service provider for the fulfillment, processing and reporting of your order.
- Some of our Sites and Services integrate with a third-party service provider to run and maintain a loyalty program and we will share information from or about you with these third-party service providers so that they may facilitate your requested transaction, including by enabling you to sign up for rewards programs or use rewards you have previously earned with us. The applicable loyalty program service provider will also use information about your order to enable you to earn rewards for orders placed via our Sites or Services.
- The Company does not disclose your personal information to third parties for the purpose of directly marketing their services to you unless you first agree to such disclosure. However, we may allow third-party Cookies to collect the same type of information for the same purposes that the Company does for itself, including to serve ads when you visit the Sites or Services. In doing so, the Company adheres to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. These companies may also use information about your visits to our Site(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
- We may share user information in the aggregate with third parties, including with the general public in our marketing materials and in our non-public discussions with third parties such as advertisers, brand managers, and content distributors.
- We may investigate and disclose information from or about you to third parties like law enforcement if we have a good faith belief that such investigation or disclosure: (i) is reasonably necessary to comply with federal, state, or local legal process and legally binding law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us (including in response to public authorities to meet national security or law enforcement requirements); (ii) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Sites or Services; or (iii) protects our rights, reputation, property, or that of our users, affiliates, clients, partners, or the public. We may disclose your information if we believe doing so is appropriate or necessary to prevent any liability, or fraudulent, abusive, or unlawful uses, or to protect the Company, our Sites and Services, or any rights, property, or personal safety of the Company or others.
Social Media Logins
If you choose to register or log in to our services using a social media account, we may have access to certain information about you. Our Site and Services may offer you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.
Managing and Deleting Your Information
Your Right to Access and Manage Your Information
You have the right to access, review, correct, or update the information you provide to us as part of your registration for a User Account with our Sites or Services. You can exercise this right and manage your own information by updating your User Account directly or by submitting a Data Request to us pursuant to the section below. You are responsible for the information you provide to us, and you should maintain the accuracy of the personal information in your User Account so that we can best provide products and services to you.
You may also be able to disallow our use of certain location data through your device or browser settings. Please note, however, that disabling location services may adversely impact your experience with the functionality of our Site or Services and enabling such services may be necessary in some cases to allow certain transactions.
Your Right to Delete Your Information
You have the right to delete certain personal information you provide to us as part of your registration for a User Account with our Sites or Services, or that you submit through the Transactable Sites. Keep in mind, we need this information to provide account management and access, and if you choose to delete information, you may not be able to take advantage of certain features of the Sites and Services. Should you choose to delete information, you can exercise this right by submitting a Data Request to us pursuant to the section below. We will never discriminate against you should you choose to exercise these rights.
You also cannot delete information associated with past purchases because we, and third-party businesses listed on the Sites or Services, may be required to maintain records of purchases for a limited period pursuant to federal, state, or local law. Also, any public postings or other communications you have made on the Sites or Services, such as in forums or blogs, generally cannot be removed, so please be mindful of the information you include there.
If your personal information has been submitted to us by a third-party business using the Sites or Services as Customer Data and you wish to exercise your rights to access, revise, or delete such data, please inquire with the relevant third-party business and submit a Data Request to us pursuant to the section below.
If you would like to access, revise, or delete any personal information, please submit a written Data Request by contacting us pursuant our Contact Us section below.
We will take such steps as we deem necessary to verify your identity before proceeding with your Data Request. For example, we may ask you for a piece of information held in your records that you might reasonably be expected to know. We cannot disclose personal information pursuant to a Data Request to anyone other than the individual in question. Once any queries around the information requested have been resolved, copies of the information will be sent to you electronically wherever possible or, if this is not technically possible, by mail.
If you submit multiple Data Requests and these Data Requests are excessive or manifestly unfounded, we will charge $20.00 to cover the administrative costs involved in dealing with each Data Request. In extreme circumstances, we reserve the right to refuse your Data Requests if they are excessive or manifestly unfounded.
We will attempt to respond to proper and confirmed Data Requests within thirty (30) days, or as otherwise required by applicable law. If you are not satisfied with the way your Data Request was handled, you may refer your Data Request to your country’s data protection authority. In the European Economic Area (EEA), any such request should be directed to the appropriate Data Protection Authority in the EU Member States and in Iceland, Liechtenstein, and Norway.
Your Right to Cancel, Opt-Out or Modify Marketing Communications
You have the right to cancel or modify the e-mail and SMS marketing communications you receive from us. You can exercise this right by following the instructions contained within our promotional e-mails and SMS messages or, in some cases, by logging into your User Account and changing your communication preferences. Generally, if you receive a marketing email from us, you can also opt out of some features by clicking the “opt out” or “unsubscribe” link in the email. If you receive a marketing SMS text from us, you can opt out of future marketing texts by replying to the text with the word STOP. Please note that this will not affect subsequent or different subscriptions–if your opt-out preferences are limited to certain types of e-mails, the opt-out will be so limited.
While you can manage some of your e-mail preferences, please note that you cannot op- out of receiving certain administrative, transactional, or legal messages from the Company which we may send in the course of legitimate business if you are signed up for a User Account and/or use certain features. However, such announcements can be terminated by asking us to close your User Account.
California Residents Privacy Notice
What Information Do We Collect About California Residents?
This section lists the categories of personal information we have collected about our California residents over the past twelve months. These categories of personal information correspond with the following categories of personal information provided under the CCPA.
|Categories of Personal Information||How We Collect this Information||How We Use this Information||How We Share this Information||Was this Category Disclosed for a Business Purpose?|
|Personal Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.||We collect this information when you voluntarily provide such information through our Sites and Services, such as when signing up for a User Account, using our Services, or otherwise interacting with us. We may collect such information automatically and passively. We may also receive such information from third parties like Vendors.||We use this information to provide you with our Sites and Services; communicate with you; offer you personalized offers; perform data analysis and market research; improve our user experience, Sites and Services; comply with legal obligations; protect our Sites and Services; and defend our legal rights.||We share this information with our affiliates, service providers, and business partners such as Vendors.||We have disclosed this category of information for a business purpose, including, for example, if you placed an order with a Retailer who needs to use it to fulfill your order.|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||We collect this information when you voluntarily provide such information through our Sites and Services, such as when signing up for a User Account, using our Services, or otherwise interacting with us. We may collect such information automatically and passively. We may also receive such information from third parties like Vendors.||We use this information to provide you with our Sites and Services; communicate with you; offer you personalized offers; perform data analysis and market research; improve our user experience, Sites and Services; comply with legal obligations; protect our Sites and Services; and defend our legal rights.||We share this information with our affiliates, service providers, and business partners such as Vendors.||We have disclosed this category of information for a business purpose, including, for example, if you placed an order with a Retailer who needs to use it to fulfill your order.|
|Protected classifications such as age.||We collect this information when you voluntarily provide us such information through our Sites and Services such as when signing up for a User Account, making a purchase, or participating in a promotional campaign. We may also receive such information from third parties like Vendors.||We use this information to provide you with our Sites and Services; offer you personalized offers; perform data analysis and market research; improve our user experience, Sites and Services; comply with legal obligations; protect our Sites and Services; and defend our legal rights.||We share this information with our affiliates, service providers, and business partners such as Vendors.||We have disclosed this information for a business purpose, including, for example, if you chose to participate in a survey distributed by a survey provider.|
|Commercial Information such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||We collect this information from your use of the Sites and Services and from our business partners.||We use this information to provide you with our Sites and Services; communicate with you; offer you personalized offers; perform data analysis and market research; improve our user experience, Sites and Services; comply with legal obligations; protect our Sites and Services; and defend our legal rights.||We share this information with our affiliates, service providers and business partners such as Vendors.||We have disclosed this category of information for a business purpose, including, for example, if you placed an order with a Vendor or service provider who needs your order details to fulfill your order.|
|Internet or other electronic network activity information, such as information regarding your interactions with our Sites and Services, browsing history, and search history.||We collect this information from your browser and device using cookies, tags, pixels, and other similar technologies and from our third-party service providers.||We use this information to improve our user experience, Sites, and Services. We use this information to provide you with our Sites and Services; offer you personalized offers; perform data analysis and market research; improve our user experience, Sites and Services; comply with legal obligations; and protect our Sites and Services.||We share this information with our affiliates, with service providers and (on an aggregate basis) with business partners such as Vendors.||We have disclosed this information for a business purpose, including, for example, if we used a service provider to help us perform analytics about the functionality of our Sites.|
|Geolocation data, such as the location of your device.||We collect this information when you voluntarily provide such information; from your browser using cookies and other similar technologies; and from your IP address.||We use this information to provide you with our Sites and Services; offer you personalized offers; perform data analysis and market research; improve our user experience, Sites and Services; and comply with legal obligations.||We share this information with our service providers. We may also share anonymized results.||We have disclosed this information for a business purpose, including, for example, if we used a service provider to provide you with directions from your location.|
|Audio, electronic, visual, thermal, olfactory, or similar information, such as recordings of user testing sessions.||We collect this information when you voluntarily provide such information and from your use of the Sites and Services.||We use this information to provide you with our Sites and Services; perform data analysis and market research; improve our user experience, Sites and Services; and comply with legal obligations.||We share this information with our service providers and Vendors.||We have disclosed this information for a business purpose, including, for example, if we used a marketing service provider to analyze recordings of user testing sessions to provide feedback on potential Service improvements.|
|Professional or employment related information, such as job title information you provide in response to a survey.||We collect this information when you voluntarily provide us such information through our Sites and Services such as when participating in market research or a promotional campaign.||We use this information to provide you with our Sites and Services; perform data analysis and market research; and improve our user experience, Sites and Services.||We share this information with our affiliates, service providers, and, on an aggregate basis, business partners such as Vendors.||We have disclosed this information for a business purpose, including, for example, if you chose to participate in a survey distributed by a survey provider.|
|Education information, such as degree information you provide in response to a survey.||We collect this information when you voluntarily provide us such information through our Sites and Services such as when participating in market research or a promotional campaign.||We use this information to provide you with our Sites and Services; perform data analysis and market research; and improve our user experience, Sites and Services.||We share this information with our affiliates, service providers, and, on an aggregate basis, business partners such as Vendors.||We have disclosed this information for a business purpose, including, for example, if you chose to participate in a survey distributed by a survey provider.|
|Inferences based on the foregoing categories.||We collect this information from your use of the Sites and Services.||We use this information to provide you with our Sites and Services; offer you personalized offers; perform data analysis and market research; and improve our user experience, Sites and Services.||We share this information with our affiliates, service providers, and business partners.||We have disclosed this information for a business purpose, including, for example to perform market research.|
Your Rights as a California Consumer
As a California consumer, you have certain rights regarding your personal information. You have the right to request from us the following information: (1) the categories of personal information we have collected about you; (2) the categories of sources from which your personal information is collected; (3) the business or commercial purpose for collecting or selling your personal information; (4) the categories of third parties with whom we share personal information; and (5) the specific pieces of personal information we have collected about you. You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
How to Exercise Your Rights
To exercise any of the rights listed in the section above, please submit a verifiable Data Request by contacting us pursuant to the Contact Us section below.
You are not required to have an account with us in order to submit a request and we will only use personal information provided in a request to verify the requestor’s identity or authority to make such a request. Please note you may only make a verifiable Data Request for access or data portability twice within a 12-month period.
The Company must verify the identity of the requestor. You may designate an authorized agent to make a request on your behalf by providing proof of a valid power of attorney, your valid government issued identification, and the authorized agent’s valid government issued identification. We cannot respond to requests where the identity and authority of the requestor cannot be confirmed.
Any disclosures we provide will only cover the 12-month period preceding the verifiable Data Request’s receipt. If we are unable to comply with a request, we will inform you of the reason why.
We Do Not Sell Your Personal Information
We do not “sell” (as such term is defined in the California Consumer Privacy Act) the personal information we collect, and we will not sell it without providing you the opportunity to opt-out.
Keep in mind that California law defines “sale” broadly in such a way that the term sale may include using targeted advertising we use on the Services, or how third-party services are used on our Services. Like most online publishers, we use these services to enable us to provide the Services and relevant offers to you, including at your request.
To limit such advertising, please review our Cookies Policies section above for more information.
California residents who choose to exercise the rights described in this section will not be denied any goods or services, charged different prices or rates, or be provided a different level or quality of goods or services unless those differences are related to your personal information.
California “Shine the Light” Policy
California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, allows individual California resident customers who have provided their personal information to us in obtaining products or services for personal, family or household use to request information about our disclosure of certain categories of personal information to third parties for their direct marketing purposes.
Such requests must be submitted to us by contacting us in accordance with the Contact Us section below. Within thirty (30) days of receiving an express written 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 year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted in ways other than those specified above.
We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. These measures include, but are not limited to, minimizing access to personal information to employees with a need to access it, and encrypting personal information provided through our Site using SSL/TLS. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites and Services is at your own risk. You should only access the services within a secure environment.
In addition, there are steps you can take to help protect your information, including choosing a robust password for your device and/or account that nobody else knows or can easily guess, and keeping your log-in and password private.
The Company is not responsible for the actions or activities of unauthorized third parties who compromise our security measures, and so we cannot be responsible for such unauthorized party’s access, acquisition, or distribution of your personal information. If you believe your personal information has been compromised, we encourage you to notify us immediately using the contact information in the Contact Us section below.
Please note that we retain some personal information about you in accordance with our record retention policies, as required by law, or as required for the achievement of the purposes of the processing as mentioned above (e.g., to enforce any agreements or provide a product/service).
It is important for you to protect against unauthorized access to your User Account, password, and computer. Sign off your User Account when finished, especially if you are using a shared computer. You can learn more about steps you can take to protect your personal information at: https://www.consumer.ftc.gov/articles/0272-how-keep-your-personal-information-secure.
Data Retention Policy
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your Rights as a Resident of the European Economic Area
You may review, change, or terminate your account at any time. If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you have questions or comments about your privacy rights, you may email us at firstname.lastname@example.org.
International Data Transfer
Though we currently do not share information globally, we may in the future, both internally within the Company and externally with our partners around the world. If you are located outside of the United States, please be aware that information we collect, including your personal information, may be transferred to, and processed, stored, and used within the United States. This transfer is necessary to provide our Sites and Services.
Attn: Legal Department
111 Pacifica Suite 100
Irvine, CA 92618
United States of America