(EFFECTIVE AS OF SEPTEMBER 14, 2022)
At SG, we strive to inform and educate all users of our Website about how to appropriately safeguard their privacy when using our Services. While our Website is neither designed nor intended to be used by Children under the age of 13, and while we do not knowingly collect personal information (as defined herein) online from children under the age of 13, we are nonetheless committed to complying with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children under the age of 13 to access and/or use our Services. In the event children do access our Website, we urge all children to check with their parents before entering information through our Website and/or Services, and we recommend that parents discuss with their children the restrictions regarding the online release of Personal Information (as defined below) to any person, entity, or others that are unknown to them.
1. Information We Collect.
b) Usage Information. As with most websites, we may use automatic data collection technology when you visit the Website to record information that identifies your computer, to track your use of our Website, and to collect certain basic information about you and your web or internet surfing habits. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Website and the Services (the “Usage Information”). In order to personalize your experience while visiting our Website, we, like other websites, collect such information by using cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users. You can reject cookies by following the directions provided in your Internet provider’s “help” file or instructions. If you reject cookies, you may still visit the Website, but may not be able to use some areas of the Website. Please note that we do not collect Personal Information in this way, but if you’ve provided us with Personal Information, we may associate that information with the information that is collected automatically. Automatic data collection may be performed on our behalf by our services providers.
a) To identify you when you sign into your Website account;
b) To respond to your requests and to provide you with the Services;
c) To respond to your inquiries and contact you about changes to our Services;
d) To send you notices (e.g., e-mails, mailings, etc.) regarding products or services you are receiving, and for billing and collection purposes (where applicable);
e) To send you notices (e.g., e-mails, mailings, etc.) regarding products or services you are receiving, and for billing and collection purposes (where applicable);
f) To send you information we think you may find useful or that you requested;
g) To enhance and improve the Website such as through personalized features and content;
h) To analyze the use of the Website and the Service and the people visiting to improve our content and Website and the Service;
i) To investigate, prevent, or take action with respect to illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
j) For any other purposes disclosed at the time the information is collected or to which you consent; and
3. Disclosure of Personal Information to Third Parties. SG does not sell your Personal Information to any third party and SG does not disclose your Personal Information to third parties for their direct marketing purposes. However, we may sometimes disclose Personal Information to service providers in order to provide the Services, enhance the Website, or for other business purposes. We, like many businesses, sometimes hire other companies to perform certain business- related functions including, for example, mailing information, maintaining databases, hosting services, and processing payments (where applicable). When we employ a third party or company to perform these types of functions, we provide them with the information that they need to perform their specific function, which may include Personal Information. If we or all or substantially all of our assets are acquired, we expect that the information that we have collected, including Personal Information, would be transferred along with our other business assets. We may disclose your Personal Information and Usage Information to government authorities and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas. We may also disclose your Personal Information and Usage Information when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users of our Website, or anyone else that could be harmed by such activities.
5. Accessing and Modifying Account Information. You may update the information that is stored in your user account by e-mailing us at email@example.com. With respect to children, parents or legal guardians can review any Personal Information collected about their child under 13 years of age, have this information deleted, request that there be no further collection or use of their child’s Personal Information, and/or allow for our collection and use of their child’s Personal Information while withholding consent for us to disclose it to third parties. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child’s parent or legal guardian.
6. You May Opt Out. At SG, we value and respect your preferences. As such, if you wish to stop receiving promotional e-mails, you may do so by e-mailing firstname.lastname@example.org. You may also choose to unsubscribe from our emails by following the instructions in the bottom of the email or the “unsubscribe” button.
8. Shine the Light Law. Under California Civil Code Section 1798.83, California residents who have an established business relationship with us may choose to opt out of our sharing their contact information with third parties for direct marketing purposes. If you are a California resident and you wish to opt out, please send an e-mail to email@example.com. Please note that we do not monitor, honor, or recognize any opt-out or do not track mechanisms, including general web browser settings.
9. Your Rights Under the GDRP.
a) In addition to the policies set forth herein, residents of the European Union or the
EEA are afforded the following additional rights and protections as required by the General Data Privacy Regulation (“GDRP”). The additional rights and protections set forth in this section apply only to residents of the European Union or the European Economic Area (“EEA”). These rights are subject to certain exceptions. To exercise any of these rights, please submit a written request to SG using the contact information set forth below. SG reserves the right to charge a fee in connection with the handling of your request as permitted by law. You may also opt out of receiving additional marketing material or information from SG by using the “unsubscribe” feature in the emails we send.
i. Right to Access. The right to be provided with a copy of your Personal Information (the right of access).
ii. Right to Rectification. The right to require us to correct any mistakes in your Personal Information.
iii. Right to Be Forgotten. The right to require us to delete your Personal Information— in certain situations.
iv. Right to Restriction of Processing. The right to require us to restrict processing of your Personal Information—in certain circumstances (e.g., if you contest the accuracy of the data).
v. Right to Data Portability. The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
vi. Right to Object. The right to object (i) at any time to your Personal Information being processed for direct marketing (including profiling) or (ii) in certain other situations to our continued processing of your Personal Information (e.g., processing carried out for the purpose of our legitimate interests).
vii. Right Not to Be Subject to Automated Individual Decision-Making. The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
b) The Legal Basis for Processing Your Personal Information. In order to comply with the GDRP, we are required to set forth the legal basis for the processing of your Personal Information. In accordance with the purposes for such collection and use, as set forth above, the basis for processing your Personal Information may typically be one of the following:
i. Our own legitimate business interests, or the legitimate business interests of our third party partners, promotors, affiliates, distributors, suppliers, and vendors, including, for example, providing direct marketing to our visitors and Website Users related to our Services and endeavors that may be of interest to our Users;
ii. The performance of a contract that we have in place with you;
iii. Your consent where appropriate;
iv. Compliance with our legal obligations, including to meet national security or law enforcement requirements.
d) Addendum to How Long We Store Your Personal Information. On occasions, there may be legal requirement to maintain Personal Information for a minimum period of time. Except in those circumstances, we do not keep you information for any longer than is needed for the purpose for which the Personal Information was collected.
10. Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (“CCPA”) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
i. Disclosure of Personal Information We Collect About You. You have the right to know (i) the categories of Personal Information we have collected about you, (ii) the categories of sources from which the Personal Information is collected, (iii) our business or commercial purpose for collecting or selling Personal Information; (iv) the categories of third parties with whom we share Personal Information, if any; and (v) the specific pieces of Personal Information we have collected about you. However, we are not required to (i) retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained, (ii) reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or (iii) provide the Personal Information to you more than twice in a 12-month period.
ii. Personal Information Sold or Used for a Business Purpose. In connection with any Personal Information we may sell or disclose to a third party for a business purpose, you have the right to know (i) the categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold and (ii) the categories of Personal Information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your Personal Information, a website must refrain from selling your Personal Information, unless you subsequently provide express authorization for the sale of your personal information.
iii. Right to Deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will (i) delete your Personal Information from our records and (ii) direct any service providers to delete your Personal Information from their records. Please note that we may not delete your Personal Information if it is necessary to (i) complete the transaction for which the Personal Information was collected, (ii) fulfill the terms of a written warranty or product recall conducted in accordance with federal law, (iii) provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or (iv) otherwise perform a contract between you and us, (v) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; (vi) debug to identify and repair errors that impair existing intended functionality; (vii) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; (viii) comply with the California Electronic Communications Privacy Act; or (ix) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent, (x) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us, (xi) comply with an existing legal obligation; or (xii) otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
iv. Protection Against Discrimination. You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things (i) deny goods or services to you, (ii) charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, (iii) provide a different level or quality of goods or services to you; or (iv) suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.