Last Updated: September 2023
- We may collect information on you either directly from you, passively as you use our Services, and from third parties.
- We do not collect information from children under 16 years of age.
- We take your information seriously.
- We may share your personal information with our vendors, suppliers and partners in connection with the services you are seeking.
- We may aggregate information.
- In certain legal situations, we may be compelled to disclose your personal information.
- We store and process personal information in the United States.
WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.
We collect contact information and other identifying information. For example, we may collect your email address when you use the Services. We may also collect your name, phone number, address, and username and password if you register with us. We may also collect the following personal information about you:
- Photo, avatar, and social media handle or profile;
- Biographical information, such as date of birth and locale;
- Professional or employment-related information, such as company name, location, and other details about your company;
- Payment information such as billing name and address, credit or debit card number, or bank account information. All payment processing services connected with your use of the Services are provided to you by third-party payment processors. soona may access the last four digits of your credit card and expiration but does not access or keep full credit card numbers or information related to banking information or other sensitive financial information;
- Account information, such as the contact and log-in information mentioned above, information that you store in your account, and other details about your use of the Services;
- Preferences, such as any preferences you set in your account and any marketing or communications preferences;
- Transaction history, such as records of products and services you have purchased from us;
- Survey responses, such as the information you provide in response to our surveys, questionnaires, or contests;
- User submissions including your ratings, tips, updates, alerts, comments, feedback, or any other information that you voluntarily provide. We and our service providers may record or monitor any call or chat you have with us for quality control or training purposes, or to enforce our rights.
We collect information about your device and Internet usage. If you use the Services, we, our service providers, and our advertising partners might collect information from your computer or device. We also collect information about the parts of our Services you use or third party apps or websites you visit when you leave our Services. Information collected automatically may include:
- Online activity information, such as the website you visited before browsing to the Services, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.
WE COLLECT PERSONAL INFORMATION IN DIFFERENT WAYS.
We collect information directly from you. For example, we collect information if you register on the Services or otherwise voluntarily submit it to us, such as by filling out a form on the Site, participating in a survey, visiting us in-person at one of our studios, or communicating with us.
- Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
- Local storage, which is used to save data on a visitor’s device. We use data from local storage to [turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our services, remember your preferences, and measure ad effectiveness.]
- Session-replay technologies, which are third-party software used to record a video replay of users’ interactions with the Services. The video replay may include users’ clicks, mouse movements, scrolls, mobile app touches, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Services, understand how users interact with and use the Services, and identify areas for improvement.
We may get information about you from third parties. For example, our affiliates or partners, service providers, advertising partners, data analytics partners, operating systems and platforms, event sponsors, or publicly available sources, may give us information about you. If our Services have social media or other app integrations, such third parties may also give us information about you. We may merge or combine such personal information with the personal information we collect from you directly or passively.
Referrals. Users of the Services may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.
WE USE PERSONAL INFORMATION FOR BUSINESS & COMMERCIAL PURPOSES.
We use personal information to provide the Services. We use personal information to provide our Services and operate our business. For example, we use personal information to process your transactions, including purchasing products and services; establish, manage, monitor, and maintain your account; improve and personalize your experience on or with the Services; verify your identity or determine your eligibility for offers and promotions; provide any contests, surveys, sweepstakes, or other promotions you participate in; provide maintenance and support; and fulfill any other purpose for which you provide personal information.
We use personal information to respond to your requests or questions. For example, we might use your information to respond to your customer feedback.
We use personal information to improve our products and services. We may use your personal information for research and development purposes, including to study and make our Services and products better, to understand and analyze the usage trends and preferences of our users, and to develop new features, functionality, products, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.
We use personal information for security purposes. We may use personal information to protect our company, our customers, and our Services. For example, we may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Services, products, business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce our Terms; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
We use personal information for direct marketing purposes. For example, we might provide you with information about new products and special offers from us. We might tell you about new features or updates. These might be third party offers or products we think you might find interesting. To manage this, read the choices section below.
We use personal information to comply with law. We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
We use personal information with your consent. In some cases, such as where required by law, we may specifically ask you for your consent to collect, use, or share your personal information.
WE USE REASONABLE EFFORTS TO PROTECT PERSONAL INFORMATION.
We maintain commercially reasonable administrative and technical safeguards to protect your personal information. However, no method of transmission over the Internet, or method of electronic storage, is fully secure and we cannot guarantee the security of your personal information.
WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES.
We will share personal information with individuals and companies that you have designated. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent.
We may share personal information with our vendors and partners. These are third parties who perform services on our behalf, such as those who help us to improve our Services and products, send emails for us, host our Site, provide database or customer relationship management, provide fraud protection, provide marketing services, and other purposes.
We may share personal information with our advertising partners. These are third parties who we partner with for advertising campaigns or that collect information about your activity on the Services for the purposes described in the “Interest-Based Advertising” section above.
We may share personal information with sweepstakes and joint marketing partners. We may also share your personal information with other partners in order to provide you with content and other features through the Services, and such partners may send you promotional materials or otherwise contact you regarding products and services that they offer. When you choose to enter a contest or sign up for a sweepstakes, we may share the personal information you provide as part of the offer with the named co-sponsors or other third parties affiliated with such offer.
We may share personal information if we think we have to in order to comply with the law or for security reasons. For example, we may share personal information to respond to a court order or subpoena. We may share personal information if a government agency or investigatory body submits a valid request to us. We might share personal information when we are investigating potential fraud or for the security or legal compliance purposes described above.
We may share personal information with our professional advisors. We may share personal information with persons, companies, or professional firms providing soona with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.
We may share personal information as part of a business transaction. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).
We may share your contact information with other users and the public. We may provide functionality that enables you to disclose personal information to other users of the Services or the public. For instance, you may be able to share your edited content, which may contain information about yourself, your product or service, or your use of the Services that you can make available to other users or the public. You may also be able to submit other content to the Services (such as comments, questions, stories, reviews, surveys, blogs, photos, and videos), and we will identify you by displaying information such as your name, username, social media handle, or a link to your user profile along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users or the public.
We may share your personal information with related companies. We may share your personal information with our current or future affiliates, subsidiaries, and other related companies.
We may share personal information for other reasons we may describe to you.
YOU HAVE CERTAIN CHOICES ABOUT SHARING AND MARKETING PRACTICES.
You can opt out of receiving our marketing emails. To stop receiving our promotional emails, follow the instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we will still send you transactional messages (such as notices about your account or transaction, and responses to your questions).
You can review, update, and request the deletion of your personal information in your account. When you register for an account with us and submit personal information through the Services, you can access, update, and delete it by logging into your account or by contacting customer service. We may maintain a copy of the original version of your account information in our records and may keep historical information in our backup files as permitted by law. If you would like us to delete your account, please contact us at email@example.com.
You can manage social network logins. If you use the social networking connection functions offered through the Services, you may manage the information that is shared with us through your social network accounts.
You can opt out of analytics cookies. The Services use Google Analytics to help us analyze how the Services are being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here.
Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
YOUR CALIFORNIA PRIVACY RIGHTS (SHINE THE LIGHT LAW).
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at firstname.lastname@example.org, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.
NOTICE TO NEVADA RESIDENTS.
THE SERVICES ARE NOT INTENDED FOR CHILDREN.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION.
Personal information we collect is processed and stored both within and outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your information to the United States and potentially other countries outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.
Users located in Europe can view more information about cross-border transfers in the section below titled “NOTICE TO EUROPEAN USERS.”
WE MAY LINK TO OTHER SITES OR THIRD-PARTY SERVICES.
NOTICE TO EUROPEAN USERS.
We retain personal information to fulfill the purpose of collection. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your rights. European data protection laws may give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Port. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us at email@example.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.
Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at firstname.lastname@example.org for further information about any such transfers or the specific safeguards applied.
FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS.
If you have any questions about this Policy or want to correct or update your information, please email us at email@example.com.
You can also write to us at: soona Co., 1235 S. Broadway, Denver, Colorado 80210.
WE MAY UPDATE THIS POLICY.
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