PRIVACY POLICY

Privacy Policy. Effective as of 21 October 2020.

We respect your privacy and we’re committed to protecting personal data we have about you. If you have questions, comments, or concerns about this Privacy Notice please see https://displaycopy.com/contact/ for information about how to contact us. 

We collect personal data:

  • When you provide it to us through our website, social media pages, or in-person at one of our locations;
  • Automatically through digital logging and analytics tools, cookies, and pixel tags; and as a result of your use of our website; and
  • From third-party sources, including ad networks that provide online behavioral advertising and retargeting/remarketing site; service providers such as commercial email and marketing providers, sweepstakes providers, and survey providers; analytics providers such as Google Analytics and Adobe Omniture; and through your interactions with us or our accounts and pages on social media websites. 

You may participate in our information collection process. When asked to provide information, you may decline to do so; however, if you decline to provide information necessary to enable us to permit you to use the website, you might not be able to use the site fully or at all. In addition, as described, you might be able to change your browser settings to prevent the automatic collection of certain information.

Also, we might collect data from or about you that is not identifiable to you or otherwise associated with you, such as aggregated data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.

If you purchase products from us, you must provide us with information to process that request, (including but not limited to email address, first and last name, billing address, shipping address (if applicable), payment information, and any other information you may optionally provide, such as telephone number).

You can choose to sign up for email notifications about us and/or our affiliates by providing us with your email address. 

If you contact us with questions, requests, or complaints, or to exercise your legal rights, we collect personal data sufficient to answer your questions, address your requests, and/or handle your complaints, as applicable. In certain situations, we may also require you to provide personal data to authenticate your identity in order to carry out your requests.

When you use our site we collect information about your use of the Site. For example, when you browse or use our online Site, we use logging and analytics tools, including Google Analytics and Adobe Omniture, to collect information about your device, the network used to access the site, and information about your use of the site. Information collected automatically might include the software and hardware attributes of the device you use to access the site, unique device ID information, regional and language settings, performance data about the site, network provider, and IP address (a number assigned to your device when you use the Internet). In addition, information is collected passively in the form of log files and third-party analytics that record website activity. For example, log file entries and analytics data are generated every time you visit a particular page on our website, and track the dates and times that you use the site, the pages you visit, the amount of time spent on specific pages, your interactions with the site, other similar usage information, and general data (including the name of the web page from which you entered our site).

We also use certain technologies such as cookies and pixel tags, that allow us and other third parties to store information locally on your device, identify your device, track your activity within our site, track your interactions with other sites, and track activity over time and across websites and devices.

These technologies let us enhance your use of our site by saving and collecting information about your visit to our site. These technologies also help us diagnose problems with our servers, evaluate the effectiveness of our marketing and advertising campaigns, and they permit analytics providers to gather information about your visit to the site and permit advertisers to collect information about your online activity and target advertising to you that is relevant to your interests as determined from your online activity (also known as “online behavioral advertising”), and to gather broad demographic information about our site’s users.

Please see the relevant section of this Notice for more information about cookies and other web tracking technologies on the Site; for information about how you can reject, delete, or prevent cookies from being placed on your system; and how you can opt out of, limit, or prevent certain web tracking technologies and/or advertising providers from collecting information about you.

In addition:

  • Online Behavioral Advertising. We allow third parties, including Google (and its DoubleClick ad network), Bing Ads, Criteo, and others, to use cookies, pixel tags, and other tracking technologies to track your online activity over time and across websites, recognize repeat visitors to the Site, and collect information about your interests and demographics based on your browsing habits and online actions. We use this information to learn about our visitors and deliver our advertisements on sites across the Internet (including on Google, Bing, Facebook, and LinkedIn). For more information about these ad networks, including how to opt out of certain tracking items, please see the Your Choices section of this Privacy Notice.
  • We receive personal data from partners. For the purposes of this Privacy Notice, “partners” means service providers, licensors, vendors, manufacturers, distributors, affiliates, or other third parties with which we have a business relationship.

These partners include service providers and vendors that provide live chat functionality on the site; commercial email providers; marketing and advertising site; survey, special offer, and sweepstakes providers; and analytics providers such as Google Analytics and Adobe Omniture. We also receive personal data from the operators of third-party job sites and platforms where we post job openings.

If you choose to interact with us or our partners on social media such as by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, interacting with or commenting on our posts or pages, or participating in activities, we may collect certain information from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience.

How We Process Personal Data

We process personal data for two general purposes:

  • For our business operations (including communicating with you, fulfilling orders, providing information about our products and site, and complying with applicable legal requirements); and
  • To market and promote our, and our partners’, products and offerings.

We disclose personal data to our service providers and partners to allow them to provide site to us and assist in carrying out your requests, and to our partners in aggregate, demographic form in connection with our marketing and business development efforts.

In addition, we may disclose information we maintain, including personal data: when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity or security of the Site or our interests, rights, property, or safety, and/or that of our personnel, members, users, visitors, and others.

See the Your Choices section below for information about how you can make decisions about how we process personal data, including how to opt out of certain marketing communications.

We process your personal data as part of our operations, which include:

  • Processing orders, providing you with information tailored to your requests, responding to inquiries, and delivering products;
  • Providing a more personalized, relevant, and curated experience to customers and visitors;
  • Operating, maintaining, and improving the quality of the site and the site, content, and products we make available;
  • Communicating with you by email, mail, text message (SMS, MMS), telephone, push notification, and other methods of communication, in each case with your consent, if such consent is required in accordance with applicable laws, about products, site, order status, and other topics;
  • Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;
  • Endeavoring to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our personnel, customers, visitors, and other third parties; and
  • For other purposes as permitted or required by law.

Marketing Uses. We process your personal data to send messages to you about us, our partners, and the products and site we and our partners offer, which may from time to time include contests, rewards, sweepstakes, events, new offerings, and special offers for products and site. These communications will only occur with your prior consent, if such consent is required in accordance with applicable laws.

We also process personal data collected through social media platforms and web tracking technologies to market to and understand our audience.

We do not disclose personal data to third parties for their own direct marketing purposes.

Sharing of Personal Data. Some of the above processing involves sharing collected personal data with third parties, including service providers, affiliates, and other partners.

  • We share personal data with third parties when you ask us to do so;
  • We share personal data among our affiliated entities;
  • We share personal data with service providers that provide site to us and/or to you directly, including: payment processors and point-of-sale platforms, order processing and fulfillment site; partners that assist us with marketing, advertising, and business development such as analysts, consultants, and commercial mail and email providers; partners that assist us with operations and infrastructure, including analysts and engineers, operations consultants, software and Web developers, security consultants, hosting providers; and other vendors we engage so that they may provide site to us or on our behalf;
  • We share personal data we collect in aggregated, demographic form, with certain partners and prospective partners in order to provide us and/or our affiliates and partners with information about the use of the Site and levels of engagement with the Site, to allow us to enter into new business relationships, and to allow us to market products or site on their behalf; and
  • We share personal data with third parties when we believe it is required by, or necessary to comply with, applicable law.

Protecting Personal Data

We employ reasonable physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data.

However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Site is or will be secure.

Retention of Personal Data.

We retain personal data to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our personnel, members, users, visitors, and other third parties.

Your Rights Regarding Personal Data

You have a variety of legal rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us as provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Notice or in communications sent to you. Please be prepared to provide reasonable information to identify yourself and authenticate your requests.

Note, however, that we may request certain reasonable additional information (that may include personal data) to help us authenticate the request and/or to clarify or understand the scope of such requests.

These rights vary depending on the particular laws of the jurisdiction applicable to you.

Accessing, Changing, and Correcting Collected Personal Data. We strive to maintain the accuracy of any personal data collected from you, and will use commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections.

If you wish to access, review, or make changes to certain personal data you have provided to us through the Site, you may do so at any time through your account and/or by contacting us as provided below.

In accordance with applicable law, you may have the right to access or obtain from us certain personal data in our records by contacting us as provided at the end of this Privacy Notice. Please note, however, that we reserve the right to deny access as permitted or required by applicable law.

Your California Privacy Rights. California residents, see our “CALIFORNIA PRIVACY NOTICE” section below for more information about certain legal rights.

Your Choices

In addition to your choices with respect to the collection of personal data (see What Information Do We Collect? above), you have the ability to make certain choices about how we communicate with you, and how we process certain personal data.

Communications Opt-Out. You may opt out of receiving marketing or other communications from us at any time through a given communications channel (such as email or telephone) by following the opt-out link or other unsubscribe instructions provided in any email message received, by contacting us as provided at the end of this Privacy Notice.

Note that if you do business with us, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce).

Cookies, Web Tracking, and Advertising. You may opt out of certain tracking technologies through your device’s or browser’s cookie and/or advertising settings (including by blocking, deleting, or restricting cookies, or resetting your device’s applicable advertising ID). Consult your device and/or browser documentation for more information about how to do this.

Please note that blocking, deleting, or restricting cookies may negatively affect the performance or certain functionality of the site, and opting out of online behavioral advertising will not prevent the delivery of ads, but rather may result in more repetitive and/or less relevant advertisements.

If you would like to opt out of Google Analytics, and certain Google advertising functionality, you may do so using Google’s opt-out tool.

 

Other Important Information About Personal Data and the Site.

Our Privacy Notice also includes information about other practices with respect to personal data, including:

  • Collection of personal data from children;
  • Links and references to third-party websites and site on our site:
  • What happens to personal data in the event we sell or transfer some or all of our business; and
  • Information about where we process and transfer personal data.

Collection of Personal Data from Children. The site is intended for use by adults and authorized individuals aged 14 to 18 (16 to 18 in California), and by using the site, you represent that you are 18 years of age or older, or are 14 years of age (16 years of age in California) or older and have valid parental consent to do so. Children under 14 years of age are not permitted to use the Site, and we do not knowingly collect information from children under the age of 13.

Third-Party Apps, Websites and Site. As a convenience, we may provide links to third-party websites and site, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business (including, but not limited to, Third-Party Apps, social media platforms, Google Maps, third-party partnerships, job application sites, and Amazon Web Site. When you access these third-party site, you leave our Site, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and site or Third-Party Apps. You access these third-party site and Third-Party Apps at your own risk. This Privacy Notice does not apply to any Third-Party Apps or site; please refer to the privacy notices or policies for such third-party site for information about how they collect, use, and process personal data.

Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Site may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.

International Use. Your personal data will be stored and processed in the United States and other jurisdictions. If you are using the Site from outside the United States, by your use of the Site you acknowledge that we will transfer your data to, and store your personal data in, the United States, which may have different data protection rules than in your country, and personal data may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States.

Modifications and Updates to this Privacy Notice

This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Site. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this Privacy Notice, such as by posting a notice on the Site or sending you an email. Your continued use of the Site following our posting of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.

Applicability of this Privacy Notice

This Privacy Notice is subject to any agreements, Terms of use, and any other terms that govern your use of the site. This Privacy Notice applies regardless of the means used to access or provide information through the site.

This Privacy Notice does not apply to information from or about you collected by any third-party site, Third-Party Apps, or advertisements associated with, or websites linked from, the site. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.

Additional Information and Assistance

If you have any questions or concerns about this Privacy Notice and/or how we process personal data, please contact us at: office@display-copy.com

CALIFORNIA PRIVACY NOTICE

This California Privacy Notice (“California Notice”) supplements the Privacy Notice and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopted this California Notice to comply with California privacy laws, including the California Consumer Privacy Act (“CCPA”). Any terms defined in the CCPA and not defined here have the same meaning when used in this California Notice.

Collection and Use of Personal Data

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal data”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.

Use of Personal Data

We collect and process your personal data for our business purposes, which include the following:

  1. Processing orders and enrollments, providing you with information tailored to your requests, responding to inquiries, and delivering site and products;
  2. Providing a more personalized, relevant, and curated experience to our members, users, and personnel.
  3. Operating, maintaining, and improving the quality of the site, content, and products we make available through the site;
  4. Communicating with you by email, mail, text message (SMS, MMS), telephone, push notification, and other methods of communication, in each case with your consent, if such consent is required in accordance with applicable laws, about products, site, order status, and other topics;
  5. Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;
  6. Endeavoring to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our personnel, members, users, visitors, and other third parties; and
  7. For marketing purposes, including sending messages to you about us, our partners, and the products and site we and our partners offer, which may from time to time include contests, rewards, sweepstakes, events, new offerings, and special offers for products and site; using personal data you enter into incomplete or unsubmitted forms on the site may be processed to send you reminders about completing the forms, as well as to save that information to make completing the forms easier; and processing personal data collected through social media platforms and web tracking technologies to market to and understand our audience.
  8. For other purposes, as permitted or required by law.

We will not use the personal data we collected for material different, unrelated, or incompatible purposes without providing you with notice and obtaining your consent.

Sharing of Personal Data

We share personal data with the following categories of third parties:

  • Affiliated Entities. We share personal data among our affiliated entities;
  • Service Providers. We share personal data with service providers that provide services to us and/or to you directly, including: payment processors and point-of-sale platforms, order processing and fulfillment site; partners that assist us with marketing, advertising, and business development such as analysts, consultants, and commercial mail and email providers; partners that assist with our operations and infrastructure, including analysts and engineers, operations consultants, software and Web developers, security consultants, hosting providers, job application platforms; and other vendors we engage so that they may provide site to us or on our behalf; and
  • Third Parties. We share personal data with third parties when you ask us to do so; when we believe it is required by, or necessary to comply with, applicable law; or to certain technology providers and our partners to allow them to provide site to us and assist in carrying out your requests, and to our partners in connection with our marketing and business development efforts.

California Privacy Rights under the Shine the Light law. 

California Civil Code Section 1798.83, known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to office@display-copy.com and are free of charge.

We do not disclose personal data protected under the “Shine the Light” law to third parties for their own direct marketing purposes.

The CCPA provides California residents with the following rights:

  1. Right to Know: You have the right to request that we disclose certain information to you about the personal data we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:
    • The categories of personal data collected about you;
    • The categories of sources from which we collected your personal data;
    • The categories of personal data that we have sold or disclosed about you for a business purpose;
    • The categories of third parties to whom your personal data was disclosed for a business purpose;
    • Our business or commercial purpose for collecting or selling your personal data; and
    • The specific pieces of personal data we have collected about you.
  2. Data Portability: You have the right to request a copy of personal data we hold about you.
  3. Right to Deletion: You have the right to request that we delete the personal data we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your personal data, we may deny your request or may retain certain elements of your personal data if it is necessary for us or our service providers to:
    • Complete the transaction for which the personal data was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
    • Debug to identify and repair errors that impair existing intended functionality.
    • 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.
    • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
    • 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 the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
    • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Otherwise use the personal data, internally, in a lawful manner that is compatible with the context in which you provided the information.
  4. Right to Opt-Out/In: You have the right to opt-out of the sale of your personal data. You also have the right to opt-in to the sale of personal data. However, we do not and will not sell your personal data.
  5. Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:
    • Deny you goods or site.
    • Charge you different prices or rates for goods or site, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or site.
    • Suggest that you may receive a different price or rate for goods or site or a different level or quality of goods or site.

Some of our Site, however, may require your personal data. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide any aspect of our Site, you may not be able to use those Site. In addition, as described in the section above captioned YOUR CHOICES in the PRIVACY NOTICE above, it is possible to change your browser settings to block the automatic collection of certain information.

Submitting a Verified Consumer Request

To exercise your Right to Know, Data Portability, and Right to Delete, you must provide us with sufficient information to allow us to verify your identity, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Once we receive the information you provide to us, we will review it and determine if more information is necessary to verify your identity as required by law, and we may request additional information in order to do so.

To exercise your California privacy rights described above, please submit a verifiable request to us by:

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your personal data.

You may make a verifiable consumer request for Right to Know or Data Portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative. Given the sensitivity of your personal data that we collect and retain, we will need to verify your identity with at least five pieces of information, such as name, phone number, email address (associated with Us), street address, and zip code.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

Request by Authorized Agent

If any authorized agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorized agent’s identity, we require the below items:

  • To verify your authorization to request on behalf of a California resident, provide one or more of the following: (1) California Secretary of State authorization, (2) notarized written permission from the California resident, or (3) power of attorney.
  • Evidence of your identity.
  • To verify the identity of the California resident for whom the request is being made, provide the information required above.

Please note that we may require additional information to verify your identity or authority. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. We will only use personal data provided in a verifiable consumer request to verify the request’s identity or authority to make the request.

We will acknowledge receipt of the request within ten (10) days of its receipt. We will respond to a verifiable consumer request from a California resident within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability requests, we will provide the responsive information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Sale of Personal Data

We never sell your personal data to third parties for money. However, the CCPA defines “sale” broadly, and that definition could include information that we have shared with our service providers and certain technology providers. In the past twelve (12) months, we have “sold” (as defined under the CCPA) the following categories of personal data set forth in the table above under the section “Processing of Personal Data”: 1, 2, 3,  4, 6, 7, 8, and 9. We disclosed personal data to our service providers and partners to allow them to provide site to us and assist in carrying out your requests, and to our partners in connection with our marketing and business development efforts.

Do Not Track. We use analytics systems and providers and participate in ad networks that process personal data about your online activities over time and across third-party websites or online site, and these systems and providers provide some of this information to us. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.

Note, however, that you may find information about how to opt out of, block, or reject certain online tracking technologies (including certain analytics and online behavioral advertising and remarketing tracking technologies) in the YOUR CHOICES section above in the PRIVACY NOTICE.

We do not and will not knowingly sell the personal data of minors under the age of 16 without affirmative authorization.

Modifications and Updates to this California Notice

This California Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Site. We reserve the right, at any time, to modify, alter, and/or update this California Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised California Notice. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this California Notice, such as by posting a notice on the Site or sending you an email. Your continued use of the Site following our posting of any revised California Notice will constitute your acknowledgement of the amended California Notice.

Additional Information and Assistance

If you have any questions or concerns about this California Notice and/or how we process personal data, please contact us at: office@display-copy.com