Effective Date: June 1, 2020
- The information that Chido, its affiliates, Service Providers (defined below), and Third-Party Services (defined below) collect about you.
- How that information may be used.
- With whom your information may be shared.
- How Chido protects your information.
- Certain jurisdiction-specific rights (as applicable).
A. Information Collected by Us
1. Information That You Provide
Pink Reef, Inc. and/or its, parents, subsidiaries, or affiliates (d/b/a Chido) (“Chido,” "we" or "us") provide websites and any online services, software, or applications to you (our "Services"). Depending on how you interact with our Services, you may provide us, our Service Providers, and Third-Party Services with information, which may include:
- Your name, email address, age (to comply with legal requirements), user name, password, address, postal code, phone number, credit card number, gender, school attending, graduation year, and other registration information;
- Information about your preferences;
- Transaction-related information, such as, your orders for any products or services, if any, that you make from us;
- Information you otherwise provide us, such as when you contact us (e.g., for help); and
- Other information related to your use of particular offerings on our Services.
2. Information Collected Automatically
We, our Service Providers, or Third-Party Services may automatically receive or collect from you certain information when you use the Services. This information may include:
- Your browser or operating system;
- Your manner of connecting to the Internet (including the type of device you are using) and the name of your Internet service provider or wireless carrier;
- Data relating to malfunctions or problems that occur when you use the Service;
- Log file information, including your Web request, Internet Protocol ("IP") address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on our service, domain names, landing pages, pages viewed, and other such information; and
- Information collected by cookies and other tracking technologies: cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Services or emails, including information about your browsing and purchasing behavior.
We will treat information that does not personally identify you as non-personal information, and we may de-identify, anonymize or otherwise convert your personal information to non-personal information. As permitted by applicable law, we reserve the right to use, process, share and otherwise exploit your non-personal information without limitation.
B. Use of Information
1. Our Use of Your Information
We may use your information:
- To process your registration, manage your account (including your payment information and preferences), and deliver our Services and features desired by you (including any customization features requested by you);
- To improve our Services;
- To fulfill other purposes disclosed to you at the time you provide us with your information or otherwise where we are legally permitted to do so;
- To personalize content and offers and serve you advertising that may be of interest to you;
- To respond to your inquiries;
- To fulfill your request for products or services;
- To provide you with updates and other information regarding the Services;
- To understand your general location (i.e., not your specific geolocation) based on your IP address;
- To keep our Services safe and secure and to prevent detect fraud and abuse;
- To comply with our legal obligations, policies, and procedures; and
- To administer and manage our Services including content and layout, site usage, troubleshooting, data analysis, testing, research, statistical and survey purposes.
We may share your information:
- With our agents, vendors, consultants, and other service providers (“Service Providers”) in connection with their work on our behalf;
- With our family of companies and affiliates and partners who may have content and offers of interest to you.
- To comply with law, law enforcement or other legal process, and, where permitted, in response to governmental requests or legal process (for example, a court order, search warrant or subpoena); and
- To other circumstances in which we have a good faith belief that a crime has been or is being committed by a user.
In addition, Chido may share your Personal Information, in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Chido assets, or transfer of all or a portion of Chido’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
D. Sweepstakes, Contests, and Promotions
E. Information you Disclose Publicly or to Others
F. Third-Party Content, Third-Party Services, Social Features, Advertising, Analytics
1. Third Party Content, Social Features, Third-Party Services
- The Service may include hyperlinks to, or include on or in connection with, the Services (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own Tracking Technologies to independently collect information about you and may solicit personal information from you. For example, Chido maintains Chido-branded pages on various social networks. When you visit these Chido-branded social media pages, the provider of the social network and other Third-Party Services may set Tracking Technologies on your browser or device.
- Certain functionalities on the Service may permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Chido’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see “Information You Disclose Publicly or to Others” section above) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with Chido or its affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Chido and its affiliates. Also, both Chido and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
- We may engage and work with Service Providers and other third parties to serve advertisements on the Services and/or on Third-Party Services. Some of these ads may be tailored to your interest based on your browsing, across time, of the Service and elsewhere on the Internet, which may include use of data from cross-device usage, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Service (i.e., “retargeting”). Our advertisers' and ad networks’ use of Tracking Technologies are governed by their own privacy policies.
b. Your Tracking Technologies Choices
- Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
- Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
- Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but we are not responsible for the completeness or accuracy of this third-party information. You have the right to request information from us about the Services that currently do not respond to "do not track" mechanisms featured in any Internet browser by contacting us according to the “How to Contact Us” section below.
- Many advertisers and Service Providers that perform advertising-related services for us and third parties participate in voluntary programs that provide tools to opt-out of such interest-based advertising such as the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising for DAA members, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies also are members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/.
- Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected, participating members should no longer deliver certain interest-based advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your browser-based opt-out may not, or may no longer, be effective.
- We support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (https://www.iab.com/wp-content/uploads/2015/05/ven-principles-07-01-09.pdf) and expect that ad networks that we directly engage to serve you interest-based advertising will do so as well, though we cannot guaranty their compliance. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
- In addition, we may serve ads on Third-Party Services that are targeted to reach people on those services that are also identified on one of more of our databases (“Matched List Ads”). This is done by using Tracking Technologies, or by matching common factors between our databases and the databases of the third-party services. We are not responsible for these Third-Party Services, including without limitation their security of the data. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions as they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
We may use Third Party Services such as Google Analytics to help us analyze our performance and our delivery of services and advertising to you. For example, we may use Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager and Google Analytics Demographics and Interest Reporting.
F. Opting Out of Promotional Communications
You can make choices about how your information may be used by us to provide information and offers to you. You may opt out of commercial messages by clicking on the "opt out" or "unsubscribe" link provided with each message. These preferences do not apply to transactional communications, such as those that are related to your registration with us, required or important notices related to your use of our Services, or the fulfillment of a specific transaction.
G. Accessing and Changing Information
We may provide web pages or other mechanisms allowing you to access, delete, correct, or update some of the personal information that we collect from you, and potentially certain other information about you (e.g., profile and account information). We will make good faith efforts to make requested changes in our then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from our databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
M. How to Contact Us
O. Jurisdiction Specific Terms
Your California Privacy Rights
Shine the Light
If you are a California resident, in addition to the rights set forth above, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties, for the third parties' direct marketing purposes. California law provides that you have the right to submit a request to us at the designated address and receive the following information:
- The categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year;
- The names and addresses of third parties that received such information, and
- If the nature of a third party's business cannot be reasonably determined from the third party's name, examples of the products or services marketed.
You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. Our designated email address for such requests is firstname.lastname@example.org. You may also mail us requests at 16508 75th Ave North, Palm Beach Gardens, FL 33418, Attn: Privacy.
California Consumer Privacy Act
This notice reflects our good faith understanding of the law and our data practices as of the date posted (set forth above), but the implementing regulations of the California Consumer Privacy Act (“CCPA”) are not yet final and there remain differing interpretations of the law. Accordingly, we may from time-to-time update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.
California residents, or “Consumers,” have the right to exercise the privacy rights under the CCPA as to their Personal Information (as defined in the CCPA) (also referred to herein as “PI”). California Consumers may also exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.
Some PI we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
To make a request according to your rights to know or to request deletion of your PI set forth below, please send an email to email@example.com.
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of PI we have collected about you.
- The categories of sources from which we collected your PI.
- The business or commercial purposes for our collecting or selling your PI.
- The categories of third parties to whom we have shared your PI.
- The specific pieces of PI we have collected about you.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
- A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
- The categories of your PI we have sold.
- The categories of third parties to which we sold PI, by categories of PI sold for each third party.
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.
Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.
Your Nevada Privacy Rights
If you are a Nevada resident, in addition to the rights set forth above, you have the right to request that we do not make any sale (as such term is defined in N.R.S. 603A) of your covered information (as such term is defined in N.R.S. 603A.320) that we may have collected from you (or may collect from you in the future). Such requests should be made to our designated email address at firstname.lastname@example.org.
Opting out of these sales will not cease marketing communications from Chido. To opt out of marketing communications, see “Opting out of Promotional Communications” above.