Privacy Policy
This Privacy Policy was last updated on August 29, 2024.
Effective Date: 8/29/2024
- Introduction
2. Scope
3. What Information We Collect
4. Use of Cookies and Other Tracking Technologies
5. Why We Collect Information
6. When We Disclose Information
7. Your Privacy Choices
8. Children’s Privacy
9. Visitors to the Site Outside of the United States
10. Links
11. Security
12. Retention of Personal Information
13. Your California Privacy Rights
14. Your Privacy Rights under Other US State Laws
15. Your Rights Under the General Data Protection Regulation
16. Your Rights Under the UK GDPR
17. Changes to This Privacy Policy
18. Contact Us
1. Introduction
Welcome. You have arrived at a website provided by Make SpringHill, which is operated by The SpringHill Company LLC (“Make SpringHill,” “we,” “our” or “us”). The mission of Make SpringHill is to empower greatness in every individual, from creators to consumers.
At Make SpringHill, we take your privacy seriously. We provide this Privacy Policy (“Policy”) to tell you what information we collect about you, how we obtain it, how we share it, and how you may limit the ways in which we use your personal information. If you have questions about this Policy after you review it, feel free to contact us at privacy@makespringhill.com.
2. Scope
This Policy governs www.makespringhill.com its subdomains, and all subdomains or portals that link to this Policy (“Site”); or otherwise provide Personal Information or interact with us online or in-person.
“Personal information” means any personal information relating to an identified or identifiable individual that is protected by applicable privacy laws. We refer to all the above as our “Services.” Our Services are used by our business partners (“Partners”), current and potential clients (“Clients”), individuals who visit the Site or shop at our online store (“Visitors”) and individuals seeking employment with us (“Employment Applicants”).
By using our Site or otherwise using our Services, you consent to this Policy and agree to our Terms of Use.
3. What Information We Collect
As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you.
Information You Provide to Us
As you interact with our Site, App or Services, we collect the following Personal Information via online webforms or inputs/uploads on our Site, and through telephone calls, text messages, letters, emails and other communications with you.
Website Visitors
- Contact information, such as your first and last name or email address, if you sign up for a newsletter or use our Contact Us forms.
Customers
- Contact information, such as your first and last name, email address, job title, shipping and/or billing address, telephone numbers, mobile numbers; and
- Financial information, such as your credit card or debit card number, bank account information, and your payment, service and purchase history.
Clients
- Contact information, such as your first and last name, job title, email address, business address, shipping address, telephone numbers, mobile numbers;
- Financial information, such as your credit card or debit card number, bank account information, and your payment and service history; and
- Personal preferences or other information that could be used to identify you personally.
Partners
- Contact information, such as your first and last name, user name, email address, home or business address, shipping address, telephone numbers, mobile numbers.
Visitors to Our Offices
- Contact information, such as your first and last name, email address, job title, home or business address, telephone numbers, mobile numbers; and
- Your Drivers’ License or Government-issued identification or passport to verify identity.
Employment Applicants
- Contact information, such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers;
- Your current or past employment or educational information;
- Relevant licenses and certifications; and/or
- Other information that could reasonably be used to identify you personally.
Information Automatically Collected
Like many businesses, we and our service providers automatically collect and/or store certain information when you visit or interact with the Site, App or Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information includes:
- Your Internet Protocol (“IP”) address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
- Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
- Referring and exit web pages and URLs;
- The areas within the Site and App that you visit and your activities there, including remembering you and your preferences;
- Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
- Your Device characteristics;
- Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;
- Information about your engagement with our emails; and
- Statistical information about how both unregistered and registered users, collectively, use the Site and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.
For location information, some of our Services include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). If you use Location-Based Services, we collect and store information about your location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information comes from a variety of sources depending on the device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used.
If you do not wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.
Information Collected from Third Parties
The Site includes functionality that allows interactions with your account on social media services or other third-party websites, plug-ins, integrations and applications. This functionality may involve the third-party site providing information to us. For example, through these interactions, we may have access to certain Personal Information in your profile, including your name, e-mail address, gender, birthday, location, account ID, user files such as photos and videos, your list of friends or connections, accounts you follow and/or who follow you, or your posts or “likes.” We may also provide links to allow third parties to process credit card and/or electronic payments for our online store or other applications. These third parties may retain any information used or provided in any such interaction and these parties are not subject to this Policy.
We may not control or have access to your communications through these third parties. For a description on how social media services and other third- party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings. Please note that when you use third-party sites or services, you are using their services and not our Services, and they, not we, are responsible for their practices.
Information We Infer
We derive information or draw inferences about you based on information we collect about you. For example, based on your browsing or purchases, we may infer your gender, your interest in certain activities or brands, or information about your purchasing activities over time.
4. Use of Cookies and Other Tracking Technologies
We use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Site, geographic location, your web requests, the date and time of your web request, your IP address, the domain name of your Internet service provider and other data. If you can be identified from this information – for example by combination with other pieces of information – then we will treat this as Personal Information.
A few of the Tracking Technologies used on the Site include, but are not limited to, the following (as well as future-developed tracking technologies or methods not listed here):
- Cookies. A cookie is a file placed on a Device to identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies and other types of cookie technology to store information on local storage.
- Pixels: A pixel is a small graphic file that allow us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site.
- Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on pages and messages of our Site.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.
- ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
- Browser Fingerprinting. Browser fingerprinting allows collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data for purposes of identification.
- Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
We may use the following types of cookies:
- Strictly necessary cookies. These cookies are essential for you to browse the Site and use its features, such as accessing secure areas of the site.
- Functional cookies. Also known as “preference cookies,” these cookies allow the Site to remember choices you have made in the past, like what language you prefer, or what your user name and password are so you can automatically log in.
- Analytics cookies. Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited and which links you clicked on. Their purpose is to improve website functions. This includes cookies from third-party analytics services if the cookies are for the exclusive use of the owner of the website visited.
- Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always of third-party provenance.
Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our Site.
If you have any questions about cookies or to generally find out more about cookies, the All About Cookies website is a trusted resource.
Purposes of Tracking Technologies
We may use Tracking Technologies for a variety of purposes, including:
- To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality;
- To facilitate navigation, display data more effectively, collect statistical data, personalize your experience while using the Site, and recognize your computer to assist your use of the Site.
- To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
- To offer you enhanced functionality when accessing the Site or Services, including identifying you when you sign into our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
- To deliver content relevant to your interests on our Site and third-party sites based on how you interact with our content.
5. Why We Collect Information
We use the information we collect about you in a variety of ways, including the following:
To Provide Our Services
We process certain Personal Information when you access or use our Services, including to:
- process your purchases of, or requests for, products and services;
- create and verify user accounts;
- facilitate the functionality of our Site and App, including payment-related functionality; and
- customize experiences and personalization when you are on our Site or using our App.
To Communicate with You
We process certain information to communicate with you in relation to your accounts, our Services, our marketing, and your requests, including to:
- communicate with you about orders, purchases, returns, Services, accounts, programs, campaigns, events, contests, and sweepstakes;
- respond to customer service inquiries and requests for information;
- respond to Client inquiries;
- post your comments or statements on our Site;
- send you personalized promotions, content, and special offers;
- communicate with you about our brands, products, events, or other promotional purposes;
- implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives; and
- provide important product safety information and notice of product recalls.
For Improvement of Our Site, App or Services
We want to ensure that our Site, App, and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we process certain Personal Information, including to:
- maintain, improve, and analyze our Site, App or Services; and
- detect, prevent, or investigate suspicious activity or fraud.
To Comply with Applicable Laws
We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:
- maintain appropriate records for internal administrative purposes; and
- comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.
To Enforce our Terms, Agreements, or Policies
To maintain a safe, secure, and trusted environment for you when you use our Site, App, and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.
To Evaluate Your Application for Employment
We use your Personal Information to evaluate your application for employment or administer employment benefits.
With Your Consent
We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.
6. When We Disclose Information
Service Providers
We share your Personal Information with our third-party service providers who provide services such as website hosting, payment processing, data analysis, information technology, customer service, email delivery, online advertising, auditing, event planning and other services. We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here.
Partners
We share your Personal Information with our Partners, affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Policy.
Third-Party Advertising
You may see certain ads on our Site because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the Tracking Technologies described above. They then use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our Site, such as the pages you viewed. This collection and ad targeting takes place on our Site and on third-party websites that participate in the ad network. This process also helps us track the effectiveness of our communications and marketing efforts.
For more information about how targeted advertising works, visit the Network Advertising Initiative’s educational page here.
You can opt out of targeted advertising on certain platforms by visiting the following:
Other
To the extent permitted by law, certain Personal Information about you may be disclosed in the following situations:
- To comply with a validly issued and enforceable subpoena or summons.
- In conjunction with a prospective purchase, sale, or merger of all or part of our business, if we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.
- As a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.
- To provide information to our Partners and nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party that prohibits them from disclosing or using the information other than for the purposes for which it was disclosed.
Finally, we may aggregate, de-identify, and/or anonymize any information collected through the Site, App or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.
7. Your Privacy Choices
Communications Preferences
We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us using the information in the Contact Us section below. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).
You can opt out of receiving emails or text messages from us at any time. To manage your email preferences with us — or to opt out of emails entirely — please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below. Your choice will not affect our ability to share information in the other ways described in this Policy.
To opt-out of text messages from us, text “STOP” at any time. Message and data rates may apply.
Please note that certain of your Personal Information, such as your name or other identifying information, may remain in our database even after an unsubscribe or deletion request to service your account, maintain the integrity and historical record of our database and systems, or to comply with applicable laws and regulations.
Controlling Your Cookies
You can opt-out of cookies by enabling an opt-out preference signal on your browser or opting-out of cookies in our Site’ cookie preference centers.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below to learn how to modify your web browser’s settings on the most popular browsers:
Note that if you turn cookies off, you may be unable to access certain parts or benefit from the full functionality of the Site. To learn more about cookies and similar technologies or to opt-out of targeted advertising cookies, visit resources from the Digital Advertising Alliance’s (“DAA”) http://www.aboutads.info/choices or the Network Advertising Initiative’s (“NAI”) http://www.networkadvertising.org/choices. We do not control these opt-out links or whether any company chooses to participate in these opt-out programs.
Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective.
Analytics
We use Google Analytics to help us understand how visitors use the Site. Read more about how Google uses your Personal Information here and opt-out of Google Analytics here.
Do Not Track
Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.
8. Children’s Privacy
We recognize the importance of children’s safety and privacy. Our Site and App are not intended for use by children under the age of 16. We do not request, or knowingly collect, any Personal Information from children under the age of 16. Minors under the age of 16 (but older than 12) may use the Site only under the supervision of a parent or guardian who agrees to be bound by our Terms of Use. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.
9. Visitors to the Site Outside of the United States
Our Site and App are not intended for visitors outside of the United States and we do not direct our activities at users outside of the United States. If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the U.S. may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the U.S. according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the U.S. and in other countries, as set forth in this Policy.
10. Links
For your convenience, the Site and this Policy may contain links to other websites. We are not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that we endorse or have any affiliation with the links.
11. Security
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Site, and you provide us with your information at your own risk.
12. Retention of Personal Information
We will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
All information you provide to us is stored on our secure servers or those of our third-party data storage providers.
When deciding how long to keep your information, we consider:
- How long we have had a relationship with you or provided our Services to you;
- Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period before we can delete them)
- Whether we have taken any legal positions (e.g., in connection with any statutes of limitation).
Rather than delete your data, we might de-identify it by removing identifying details.
13. Your California Privacy Rights
This section of the Policy applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.
California residents have the following rights:
- To know the categories of personal information being collected about you, the purposes for which the categories of information are collected or used, and whether that information is sold or shared;
- To know the length of time we intend to retain each category of personal information;
- To know whether your personal information is sold or disclosed and to whom;
- To access your personal information;
- To delete the information you have provided to us, with certain exceptions;
- To correct your personal information;
- To opt out of the sale of personal information;
- To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;
- To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and
- Not to be discriminated against, even if you exercise your privacy rights.
The sections above describe in detail what categories of information we collect and the purposes for which we use that information.
Request for Information, Correction, or Deletion
California consumers have the right to request, under certain circumstances, that a business that collects Personal Information about the consumer disclose to the consumer the information listed below for the preceding 12 months:
- The categories of personal information collected about you;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting, selling or sharing personal information;
- The categories of third parties to whom the business discloses personal information; and
- The specific pieces of personal information collected about you.
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your Personal Information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.
Personal Information Collected
We have collected the following categories of Personal Information from consumers within the last twelve (12) months:
Category of Personal Information |
Examples of this Category
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Sources of Personal Information |
Business Purpose for Collection |
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Identifiers |
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To provide, market and improve our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
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Personal information described in California Civ. Code § 1798.80(e) |
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You Automatically Third Parties |
To provide, market and improve our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
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Characteristics of protected classifications under California or federal law |
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You Automatically |
To provide, market and improve our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
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To provide, market and improve our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
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N/A | ||||
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You Automatically |
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You |
To provide, market and improve our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
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N/A | ||||
Inferences drawn from other Personal Information |
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You Automatically Third Parties |
To provide, market and improve our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law |
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Information related to how long we retain each category of Personal Information is included in the Retention of Personal Information section above.
Personal Information Sold or Shared
We have sold or shared (as those terms are defined in the CCPA) to third parties the following Categories of Personal Information in the last twelve (12) months:
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Advertising, marketing, and analytics providers |
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Biometric information | N/A | N/A | |||
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Geolocation data |
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Sensory data | N/A | N/A | |||
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N/A | N/A | |||
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N/A | N/A | |||
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N/A | N/A |
We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.
Personal Information Disclosed for Business Purposes
We have disclosed the following categories of Personal Information for business purposes in the last twelve (12) months:
Category of Personal Information |
Recipient Categories |
Business Purpose for Disclosure |
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Identifiers | Service Providers |
Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
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Personal information described in California Civ. Code § 1798.80(e) |
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Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
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Characteristics of protected classifications under California or federal law |
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Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
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Biometric information |
N/A | N/A | ||
Internet or other electronic network activity information |
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Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
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Geolocation data | N/A | N/A | ||
Sensory data | Service Providers |
Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
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Professional or employment-related information | Service Providers |
Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
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Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) |
N/A | N/A | ||
Inferences drawn from other Personal Information | Service Providers | Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration |
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Sensitive Personal Information |
N/A | N/A |
Do Not Sell or Share My Personal Information
As a California resident, you also have the right, at any time, to tell us not to sell personal information – this is called the “right to opt-out” of the sale of personal information. We do not sell Personal Information, but we recognize that some privacy laws define “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt-out of this, please email privacy@makespringhill.com.
Right to Limit Use of Sensitive Personal Information
California consumers have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Consumers can revoke this permission at any time. We do not provide your Sensitive Personal Information to any third parties for cross-contextual behavioral advertising.
Right Not to Be Discriminated Against
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, as permitted by California law, we may offer you certain financial incentives that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to the value of your Personal Information, for instance, if you sign up for a newsletter with us, we may provide you with discounts for future Services. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Notice of Financial Incentives
As permitted by the CCPA, we may offer you certain financial incentives and benefits by subscribing to our marketing emails. This information allows us to tailor our communications and products and services suggestions for you. This, in turn, helps us establish a stronger relationship with you – something we value.
If you subscribe to our marketing emails, we may send you promotions to discounted products, exclusives, giveaways and other products and services. The value of these discounts vary. For example, you could receive a 50% off discount or free shipping.
In determining the value of this data to us, we consider the profit generated from products that include Personal Information, which is reasonably correlated to the value provided to the consumer through personalized coupons, promotions, and other discounts or offers.
Subscription to our marketing emails is voluntary and requires your prior opt-in consent, which you may revoke at any time. You may unsubscribe to our marketing emails at any time. To do so, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below.
Third Party Marketing
California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what personal information (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. We do not currently disclose personal information protected under this section to third parties for their own direct marketing purposes.
How to Exercise Your California Privacy Rights
You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by contacting us as follows:
Email: privacy@makespringhill.com
Address:
The SpringHill Company LLC
1500 N. El Centro Ave., Suite 200
Los Angeles, CA 90028
United States
If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
14. Your Privacy Rights under Other US State Laws
If you are a resident of Colorado, Connecticut, Utah or Virginia, you may have the right, upon a verified request, to:
- To confirm whether a controller is processing your personal data and to access such personal data;
- To correct inaccuracies in your personal data (not Utah);
- To delete your personal data;
- To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
- To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
To exercise these rights, you or your authorized agent may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling emailing us at privacy@makespringhill.com.
If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency in order to obtain the information. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident of Colorado, Connecticut or Virginia. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
Right to Opt Out Under Applicable State Laws
Residents of Colorado, Connecticut and Virginia have the right to opt out of the sale of their Personal Information and targeted advertising. To exercise your right, please email us at privacy@makespringhill.com.
California residents may have additional rights, as shown in the “Your California Privacy Rights” section above.
Opt-Out Preference Signals
Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.
Appeals of Our Decisions
In some states, you may appeal to us if we refuse to take action on your exercise of certain choices described above. To appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. If your appeal is denied, residents of certain states can contact their attorney general as follows:
15. Your Rights Under the General Data Protection Regulation
Although we do not direct our activities at visitors outside of the United States, we recognize that in this global economy, certain visitors to our website or users of our Services may fall under the GDPR. This section of the Policy applies if you are a data subject who is a citizen of the European Economic Area (“EEA”). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this section.
Under applicable law, we are considered the “data controller” of the Personal Information we handle under this Policy. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law.
We want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process is limited to the Personal Information that are reasonably required in connection with the purposes set out in this Policy.
If you are a citizen of or located within the EEA, you have certain data protection rights. These rights include:
- The right to access, update or delete the information we have collected from you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the information in the Contact Us section below.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Information.
- The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.
Legal Basis for Processing Personal Information
We rely on the following legal bases for processing your Personal Information:
- Contract: To conclude or perform a contract with you; for example:
- To manage and fulfill orders, facilitate delivery, and to provide other Services;
- To manage our accounts and records;
- To handle your inquiries and requests;
- When you apply for employment through our Site, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.
- Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:
- To respond to your customer service inquiries and requests for information;
- To maintain, improve, and analyze our Site, App, ads, and Services we offer;
- To conduct marketing activities;
- To detect, prevent, or investigate security breaches or fraud; and
- To facilitate the functionality of our Site and App;
- Legal Compliance: To comply with our legal obligations; for example:
- To maintain appropriate records for internal administrative purposes and as required by applicable law, and
- To provide important product safety information and notice of product recalls
- Consent: We will send you information by email on our Services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.
How to Exercise Your Rights Under the GDPR
If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.
Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.
Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:
Email: privacy@makespringhill.com
Address:
The SpringHill Company LLC
1500 N. El Centro Ave., Suite 200
Los Angeles, CA 90028
United States
16. Your Rights Under the UK GDPR
If you are based in the United Kingdom, the following provisions also apply:
UK GDPR means the Retained Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
If we share your personal data with our partners or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.
You have the same data subject rights as those for the EU listed above, except that references to the "GDPR" should be read as references to the "UK GDPR" and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.
17. Changes to This Privacy Policy
We may change this Privacy Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified notice's effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy policy. If required by the applicable law, we will notify you of the changes.
By continuing to use the Site, App or Services or providing us with information when a replacement Policy is uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Policy as changed.
18. Contact Us
If you have any questions or suggestions regarding this Policy, please contact us as follows:
The SpringHill Company LLC
1500 N. El Centro Ave., Suite 200
Los Angeles, CA 90028
Email: privacy@makespringhill.com