At WE GOT FRIENDS, we want you to know that we respect your privacy, the privacy of our BPs and the privacy of our customers. This document provides information regarding our policy as it relates to the collection, use and disclosure of personal information. It also outlines our customer's rights to limit the collection use or disclosure of personal information.Personal information may include your name, email, mailing and/or business address, phone numbers, or other information that identifies you personally. We at WE GOT FRIENDS hold this personal information seriously and we maintain this information in the strictest of confidence. We do not sell any information to any third party. We also maintain a secured web site on all pages that require you to provide any personal information. This policy applies to users of WE GOT FRIENDS services anywhere in the world.
The practices described in this policy are subject to applicable laws in the places in which we operate. This means that we only engage in the practices described in this policy in a particular country or region if permitted under the laws of those places. Please contact us if you have questions on our practices in your country or region.
Personal Information does not include:
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits consumers who are California residents, to request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties' direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. If you are a California resident and would like to make such a request, contact us as provided in the “Contact Us” section below.
We may have collected Personal Information in the following categories from consumers within the last twelve (12) months. The categories and examples provided in the chart below are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact collected but reflects our good faith belief to the best of our knowledge that some of that information may have been collected about consumers. We will update this disclosure from time to time as appropriate.
|A. Identifiers.||A name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.|
|G. Geolocation data.||Physical location or movements.|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
WE GOT FRIENDS collects information on the Site at two different stages. First, we collect anonymous aggregate information (such as a domain name or IP address) from all visitors to the Site. This type of information if never linked to any personally identifiable information and is only used in the aggregate to general statistical reports about the use of the Site.
Second, we require the submission of certain personally identifiable information when you use the services available for the site. We collect information from you when you register on our site, place an order or fill out a form. When ordering or registering on our site, as appropriate, you may be asked to enter your: name, e-mail address, mailing address, phone number, credit card information, banking information or social security number. You may, however, visit our site anonymously.
We obtain the categories of Personal Information listed above from the following categories of sources:
We may have "sold" (as that term is defined in the CCPA) Personal Information in the following categories from consumers within the last twelve (12) months. Please note that the CCPA uses an expanded definition of the term, in which "sell" means:
Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration; or (B) sharing orally, in writing, or by electronic or other means, a consumer's personal information with a third party, whether for valuable consideration or for no consideration, for the third party's commercial purposes.
When we disclose that we may have sold Personal Information, it means that we may have received some kind of benefit to our WE GOT FRIENDS in return for sharing Personal Information, but not necessarily received any money in exchange.
The categories below are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact "sold" but reflects our good faith belief to the best of our knowledge that some of that information may have been shared for value in return. We will update this disclosure from time to time as appropriate.
We may use or disclose Personal Information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples. The examples provided are illustrative and not intended to be exhaustive.
We may disclose your Personal Information to the following categories of other parties for a business purpose or commercial purpose, as those terms are defined in the CCPA:
The CCPA provides California residents with specific rights regarding their Personal Information as described below.
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. After we receive and confirm your verifiable consumer request, we will disclose to you within the time required by the CCPA, the relevant information, which may include:
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions, including if we need the Personal Information for a reason related to our business, such as:
After we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records within the time period required by the CCPA, unless an exception applies.
To exercise the rights described above, please submit a verifiable consumer request to us through the web form link provided below in Contact Us.
You may only make a verifiable consumer request for access 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 information or an authorized representative, which may include: providing your email and phone verification, known customer information, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the Personal Information in question.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by email.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable. For data portability requests, we will select a commercially reasonable format to provide your Personal Information that is commonly useable and should allow you to transmit the information from one entity to another entity without hindrance, but we do not guarantee that all formats are useable in all media. 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.
We will not discriminate against you for exercising any of your CCPA rights. In particular, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
We currently do not offer any financial incentive, benefit, or price differences in return for the disclosure, deletion, or sale of Personal Information. However, in general, our business model is based on providing a certain amount of monthly free content to readers, after which we may require that additional content access must be paid for. On some of our Websites and apps, this content may be paid for either through the delivery of advertisements, or through subscriptions. On those Websites and apps, consumers who use ad-blocking technology will be notified of the option to turn off the ad blocking or to pay for a subscription to access the content. On some other Websites and apps, content must be paid for after a certain number of monthly free articles, whether advertising is present or not.
The CCPA requires businesses to provide a method where consumers can opt out of the ''sale" of their Personal Information. To opt out, simply submit a support ticket through your WE GOT FRIENDS back office support ticket system or email firstname.lastname@example.org with your request.
In addition, you may opt out of certain interest-based advertising by using the following resources:
WE GOT FRIENDS collects a variety of information for many different purposes that are related to the use and sale of our products. These purposes include product interest and purchasing trends, credit information, payment information, contact information, usage information as it relates to our products, service requirements. We do this to develop a good understanding of your needs, analyze those needs and respond to those needs. This is done to identify products and services offered by our WE GOT FRIENDS affiliates or by other companies that we believe could be of interest to you. When doing so, we may offer these products or services to you for your purchasing consideration.
Further to the above, any of the information we collect from you may be used in one of the following ways:
Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
We implement a variety of security measures to maintain the safety of your personal information when you place an order or access your personal information. Protecting the security of your personal information is very important to us.
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. All transactions are processed through a third party via SSL API. We do not store data OF ANY KIND on this website with exception to the fields noted herein.
After a transaction, your private information (credit cards, social security numbers, financials, etc.) will be kept on file for more than 60 days in order to facilitate future orders as some customers maintain ongoing, monthly purchasing transactions with WE GOT FRIENDS.
If you register with us, your online account information is protected by a password chosen by you. The site does not store plaintext (human-readable) passwords, nor does it store encrypted (computer decryptable) passwords. Alternatively, this site uses password hashes and if exposed/compromised, can not reveal your human-readable password. This is to help limit any further use of your password on unrelated sites. Access to that online account requires your username and password. We recommend that you do not disclose your username and password to any other person. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online. We use the latest in encryption technology when collecting or transferring sensitive data, such as credit card and bank account information.
When registering for access to a secure area of the Site, we will ask you to select a username and password. We recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited email. Also, remember to sign out of the registered site and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence when accessing your computer.
We use commercially reasonable procedures and various technical, administrative and physical safeguards to help protect the confidentiality of Personal Information. However, no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure given the reality of communication via technology systems. Therefore, although we believe the measures implemented by us are commercially reasonable and reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Personal Information or private communications sent to us over those systems will always remain private or secure. We are not responsible for the circumvention of any privacy settings or security features.
If you believe that your Personal Information has been accessed or acquired by an unauthorized person, please promptly Contact Us so that necessary measures can quickly be taken.
Yes (Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify cookies. If you turn off cookies, some of the features that make your site experience more efficient may not function properly.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. (https://support.google.com/adwordspolicy/answer/1316548?hl=en)
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Some of WE GOT FRIENDS’s products, services and features require that we share information with other users or at your request. We may also share your information with our affiliates, subsidiaries and business partners, for legal reasons or in connection with claims or disputes.
The Fair Information Practices Principles (FIPP) form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protect laws around the globe. Understanding the FIPP and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with FIPP we will take the following responsive action, should a data breach occur: we will notify you via email within 7 days.
The Can-Spam Act is a law that sets the rules for commercial email, established requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with Can Spam, we agree to the following: not use false or misleading subjects or email addresses, identify the message as an advertisement in some reasonable way, include the physical address of our business or site headquarters, monitor third-party email marketing services for compliance, if one is used, honor opt-out/unsubscribe requests quickly, and allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can email us at email@example.com and we will promptly remove you from ALL correspondence.
Questions, comments and complaints about WE GOT FRIENDS’s data practices can be submitted to WE GOT FRIENDS's data protection office through the contact information provided above.
We process personal information inside and outside of the United States. WE GOT FRIENDS transfers information of users' outside the United States on the basis of mechanisms approved under applicable laws.
WE GOT FRIENDS retains user profile and other information for as long as you maintain your WE GOT FRIENDS account.
WE GOT FRIENDS retains transaction, location, usage and other information for 7 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. WE GOT FRIENDS thereafter deletes or anonymizes such information in accordance with applicable laws.
Users may request deletion of their accounts at any time. Following such request, WE GOT FRIENDS deletes the information that it is not required to retain, and restricts access to or use of any information it is required to retain. You may request deletion of your account at any time by emailing to firstname.lastname@example.org. Following such request, WE GOT FRIENDS deletes the information that it is not required to retain. In certain circumstances, WE GOT FRIENDS may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, WE GOT FRIENDS will delete your account as described above.
WE GOT FRIENDS may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, if WE GOT FRIENDS shuts down a user's account because of unsafe behavior or security incidents, WE GOT FRIENDS may retain certain information about that account to prevent that user from opening a new WE GOT FRIENDS account in the future.
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.
As part of the California Online Privacy Protection Act, all users of our site may make any changes to their information at anytime by logging into their control panel and going to the 'Edit Profile' page.
These Websites are not intended for use by children under the age of 13.
If you have reason to believe that a child under the age of 16 has provided Personal Information to us through a Website without the appropriate consent, please contact us as provided in the Contact Us section below with sufficient detail to enable us to delete that information from our databases.
Beginning May 25, 2018, the processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (“GDPR”).
This section summarizes WE GOT FRIENDS grounds for processing personal information under the GDPR, and the rights of EU users as relates to WE GOT FRIENDS handling of personal information.
If you are a WE GOT FRIENDS user in the EU, you have the following rights with respect to WE GOT FRIENDS handling of your personal information. To exercise these rights, please see below or submit your request to email@example.com or submit a support ticket through your member portal.
Users outside the EU may also request explanation, correction, deletion or copies of their personal data by submitting your request to firstname.lastname@example.org or submitting a support ticket through your member portal.
US Department of Commerce EU-US & Swiss-US Privacy Shield 1401 Constitution Ave NW Washington, DC 20230 https://www.privacyshield.gov/Individuals-in-Europe
The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, WE GOT FRIENDS processes the information of EU users based on one or more of the grounds specified under the GDPR:
WE GOT FRIENDS provides means for you to see and control the information that WE GOT FRIENDS collects.
You may also request that WE GOT FRIENDS provide you with explanation, copies or correction of your data.
You may request that WE GOT FRIENDS:
You may opt out of receiving promotional emails from WE GOT FRIENDS here. You may also opt out of receiving emails and other messages from WE GOT FRIENDS by following the instructions in those messages. Please note that if you opt out, we may still send you non-promotional messages.
Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website at WE GOT FRIENDS.com.
We may occasionally update this policy.
We may occasionally update this policy. If we make significant changes, we will notify you of the changes through email. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this policy.
We encourage you to periodically review this policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review.
To fill out a Data Information or Deletion Request, submit your request via email to email@example.com or submit a support ticket through your member portal.
Do Not Sell My Personal Information, submit your request via email to firstname.lastname@example.org or submit a support ticket through your member portal.
Email us at email@example.com