PRIVACY STATEMENT SCOTCH & SODA

GENERAL

This Privacy Statement applies to the collection and processing of the personal data of Scotch & Soda's visitors, users and customers, while interacting with us via our stores, website(s), social media channels, app, consumer care services and/or other services.

Scotch & Soda values great importance to the protection and security of your privacy and your personal data. We process your personal data in accordance with the EU General Data Protection Regulation (EU 2016/679), the California Consumer Privacy Act and/or any other local privacy laws (when applicable).

Scotch & Soda amends this Privacy Statement from time to time. The latest version of the Privacy Statement can be found at http://www.scotch-soda.com. under "Privacy Statement" at the bottom of the website.

This Privacy Statement was last amended on 1 January 2022.

THE PRIVACY PRINCIPLES OF SCOTCH & SODA

We commit ourselves to follow below privacy principles when it comes to the protection and security of your privacy and your personal data:
1. Scotch & Soda uses strict rules for processing personal data, and we regularly evaluate the functioning of the rules. We process personal data that is relevant and necessary to give you a wonderful experience. Where possible, we remove personal identifiers from personal data so that we can use this for data analysis. We use this information to provide you with targeted information about inter alia promotions and events.
2. Scotch & Soda has taken appropriate organisational and technical security measures for processing your personal data. We have taken appropriate measures to prevent data breaches. In case of any unfortunate event such as a data breach, we of course inform the parties concerned and the regulatory authority when necessary. Any notification regarding a data breach can be made by telephone, e-mail or by a general publication on our website.
3. Scotch & Soda uses the principles of 'privacy by design' and 'privacy by default'. This means that our privacy principles have been included in the design process of our IT systems, and insofar possible we always use the most privacy-friendly level.
4. Scotch & Soda wants to offer transparent and clear information about which personal data we process, why this is necessary, and how we process your personal data. If you need any further details, please contact us via consumercare@scotch-soda.com.

THIS PRIVACY STATEMENT INFORMS YOU ABOUT THE FOLLOWING:

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?
2. HOW DO WE COLLECT YOUR PERSONAL DATA, WHAT TYPE OF PERSONAL DATA AND FOR WHICH PURPOSE?

2.1 Completion of purchases and online orders, customer services and fulfilment of any other request
2.2 Customer related marketing initiatives or personalised advertising, use of website
2.3 Functionality of use website(s) and app
2.4 Prevent fraud, theft, or other misconduct
2.5 Social Media
2.6 Customer (satisfaction) surveys
2.7 Business purposes

3. LEGAL GROUNDS FOR PROCESSING OF PERSONAL DATA
3.1 Consent
3.2 The performance of a contract
3.3 Legitimate interests
3.4 Compliance with legal obligations

4. HOW DO WE PROTECT YOUR PERSONAL DATA?
5. RETENTION PERIODS
6. DO WE SHARE YOUR PERSONSAL DATA WITH THIRD PARTIES?
7. YOUR PRIVACY RIGHTS
8. MINORS PROVIDING PERSONAL DATA
9. COMPLAINTS
10. CONTACT
11. CALIFORNIA PRIVACY RIGHTS

11.1 Information for Customers
11.2 Information for Authorized Agents
11.3 Information Sharing Disclosure

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?

Scotch & Soda Group B.V. is responsible for the processing of your personal data. You can find our contact details in the Contact section at the end of this Privacy Statement.

2. HOW DO WE COLLECT YOUR PERSONAL DATA, WHAT TYPE OF PERSONAL DATA AND FOR WHICH PURPOSE?

We will use your data for different purposes. Depending on the purpose for which we process your data from time to time, we need to process one or other data, which we have set out in a detailed overview below.

2.1 Completion of purchases and online orders, customer services and fulfilment of any other request

2.1.1 Offline store purchases, online orders and personal Scotch & Soda accounts

  • Store:
If you choose to receive a digital receipt when purchasing in any of our stores, we process your e-mail address and record an overview of the items you purchased.
Online orders can be collected or returned in our stores. To provide these services, we need to process your personal data, such as your name, e-mail address, residential address and optionally the reason for your return. Our store employees will register whether you have collected or returned any online order.
When you book a styling session in one of our stores, we process your name, e-mail address, telephone number and optionally your size and collection preferences, to set up a personal appointment.

  • Online:
If you place an order through our website(s), app or via our digital environment in our stores, we process your name, e-mail address, telephone number, billing information (including billing address), shipment address and other data needed to complete and deliver your order. Some of this information is necessary to complete your order, as without a name and shipment address, we cannot deliver any purchases.
To deliver your order in accordance with the delivery method you have chosen, we will notify you per e-mail about the status of your delivery. We will share your contact details with our contracted carriers, for example PostNL, DHL and UPS.
All carriers involved act as independent data controllers, responsible for processing your personal data. In case of any questions relating to how they process your personal data, please consult the privacy statement on the website of the respective carrier. You can find the carrier fulfilling your delivery in the notification e-mail about the status of your order.

  • Online Account:
If you create an online account on our website(s), app or via our digital environment in our stores, we process your personal data on a secure server. You are asked to fill in your name, e-mail address, telephone number, billing information (including billing address), shipment address, to create a password and to subscribe to our newsletter(s) (optional). Furthermore, we will create a user-ID in our system. We also give you the option to store your credit card details in an encrypted format.
With your user-ID and your opt-in, we also offer you the possibility to create a digital customer card, which you can use in our stores to add your purchases to your personal account.

2.1.2 Payments and prevention of fraud
When you pay for an online order or store purchase, we need to process your personal data. All payments done with a debit or credit card are processed by a payment (service) provider, who acts as independent data controller for the processing of personal data for this specific payment purposes. In case of any questions relating to how such payment (service) provider processes your personal data, please consult their privacy statements on their website.

In case of a payment with your credit card, we are legally obliged to check your personal data against your ability to fulfil your payment obligation or fraud. To recognize, detect or to prevent fraud, our payment (service) provider will use transactional data, such as your bank account number, the type of debit or credit card, expiration date, location of the purchase, time of the purchase and the country of origin of the credit. When you pay online, our payment (service) provider will also process the IP address of your mobile device or your computer. Scotch & Soda will not process any personal data for this specific purpose.

2.1.3 Communicating with consumer care and other Scotch & Soda employees
We collect personal data to be able to answer any of your questions raised to our consumer care by regular mail, by telephone, by e-mail, via chat or face-to-face to a store employee. If you contact our consumer care, we collect your name, e-mail address (and any additional data you provide us with or necessary in relation to your purchase), the content of correspondence, conversation notes and call recordings in case of contact by telephone to be able to respond to your questions or comments, to provide better service and for training purposes. If you make use of our chatbot service on our website, you can always speak with someone in person.

2.2 Customer related marketing initiatives or personalised advertising, use of website

2.2.1 To offer you Scotch & Soda products and services.
If you have placed items in your shopping cart while logged in via your online account and not yet purchased any of these items, we send you an e-mail to inform and remind you that the items are still available for you. For this purpose, we collect data about the items placed in your shopping cart.

Scotch & Soda uses interest-based advertising. We automatically collect data regarding your website behaviour, use of applications and your shopping behaviour to improve your customer experience, our customer service and to provide you with communications and promotions from us or from advertising partners working on behalf of us. By using interest-based advertising, Scotch & Soda or its advertising partners want to show you advertisements that match your interests. You can always limit Scotch & Soda's and our partners' ability to collect and use your data for these purposes. To opt out of receiving interest-based advertising, please click on either one of the following links: https://www.networkadvertising.org or https://youradchoices.com.

To successfully opt-out, please note that you must have cookies enabled in your web browser and that if you choose to opt-out, you continue to see advertisements on our websites and receive communications from us. Such advertisements and communications will not be based on your website behaviour or shopping behaviour. As described above, you can also prevent automatic collection of some data by disabling cookies on your web browser. For more information about cookies, please see our Cookie Statement on our website(s).

2.2.2 To be able to send you our newsletter and other promotional communications per e-mail.
Scotch & Soda loves to keep you updated through our newsletter, in which we will inform you about new products, special offers and other promotional activities. If required by law, we will first obtain your consent / subscription before sending our newsletter and other special offers by e-mail. Subscription is based on your e-mail address, no other personal data will be collected by Scotch & Soda, other than any preferences specified by you. Preferences specified by you in your account will also be used in our communications.

You always have the option to opt-out of receiving our newsletter or other marketing related communications from us by choosing one of the following options:
  • By clicking the 'unsubscribe' link at the bottom of the respective Scotch & Soda e-mail.
  • By clicking the 'unsubscribe from all' link in the newsletter preferences in your personal Scotch & Soda account.
  • By sending an e-mail to consumercare@scotch-soda.com.
  • By notifying consumer care in writing using the postal address mentioned in the 'Contact' section below or by using the contact form on http://www.scotch-soda.com.
When you unsubscribe to marketing related communications from us, we will remove you from the mailing list as quickly as possible. Clicking the 'unsubscribe' link at the bottom of the Scotch & Soda e-mail or via your personal Scotch & Soda account is the most efficient way to unsubscribe.

2.2.3 To personalize our services by creating a marketing profile
Scotch & Soda creates marketing profiles to optimise our day-to-day business and to provide you with better offers and services. For example, we use your feedback, information about your purchases and the use of our services to make your shopping experience as good as possible. We use this data to personalize our products and services and to recommend products you might be interested in. By analysing your purchases and use of the various services of Scotch & Soda, we can better match our services and communication to your preferences. We therefore link and add available information about you to your account, including your interests, selected preferences, (online) purchases and information about your use of our website(s), app and other digital environment.

We also use this data to find patterns that can be used to further optimize our marketing. We process data regarding your online and offline purchase history and behaviour on our website(s) and app, social media and e-mail data in a Data Management Platform. When you log in to your online account on our website(s) and app, we link this data to your customer ID. The sources from which we collect data change regularly. If you would like to know which sources we currently use, you can reach out to us via one of the communication channels mentioned in the 'Contact' section below. Using a Data Management Platform allows us to show you specific (targeted) advertisements on our website(s), app and/or or on third party websites or platforms, such as Facebook, Instagram and Google.

The Data Management Platform also supports us to send you targeted e-mails and to personalize our website(s) and app to your interests. We never sell your personal data to third parties. We analyse the data collected to target a specific audience, to match your data with other customers who have a similar profile, to link devices that you use, and to show you targeted advertisements and special offers and to customize your online experience.

Based on your customer profile, we determine the communication you receive as a customer. We work with segmentation based on profile characteristics. For example, a birthday gift based on the date of birth. We have also set up our systems to ensure the accuracy of personal information.

Scotch & Soda does not make use of automated decision-making. This means that the way we compose your profile has no significant legal implications for you. Furthermore, we do not use any special categories of personal data for marketing purposes, such as personal data revealing racial or ethnic origin, political opinions and religious or philosophical beliefs.

2.3 Functionality of use website(s) and app

2.3.1. To optimize the use of the Scotch & Soda website(s) and app
We use technology service providers to better understand the needs of the users of our website(s) and app with the purpose to optimize our website(s), app and your user experience (e.g., how much time do you spend on which pages, which links do you click, what users do and do not like). This enables us to build and maintain our service with user behaviour. We use technology service providers such as Google to collect and display detailed statistics from our website(s). The purpose of this service is to give us a clear overview of visitor flows, traffic sources and pageviews. Based on this information we improve and secure our website(s) and app, offer you services and products via other media and improve and personalize your shopping experience.

The technology service providers use cookies and other technologies to collect (personal) data on our users' behaviour and their devices. This personal data collected while using cookies and other technologies include a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), operating system, browser type, geographic location (country only), the preferred language used to display our websites, mouse events (movements, locations, clicks), keypresses, referring URL and web domains & web pages visited and date and time when our pages were visited.

2.3.2. Cookies
When you visit the Scotch & Soda website(s), Scotch & Soda uses cookies to improve your user experience. Cookies are small text files saved on your computer's hard drive or memory. We use cookies to record the preferences you set for a particular service or website(s), so that you do not have to fill them in again during subsequent visits. In addition, cookies ensure that the products or services that you purchase are saved when you use our online 'shopping cart'. You can read more about cookies in the Cookie Statement on our websites.

The legal basis for the use of personal data obtained through cookies and other technologies is based on your consent (with the exception of functional cookies and cookies with a minimum infringement on your privacy). You can withdraw your consent any time.

2.4 Prevent fraud, theft, or other misconduct

To prevent any fraud, theft or other misconduct in our stores and to secure an effective instore security policy (e.g., by using access control, conducting camera surveillance or by registering incidents) we collect the necessary personal data.

Scotch & Soda has security cameras in its stores to guarantee your security, the security of its store employees, to prevent any fraud, theft or other misconduct and to be able to comply with its legal obligations. You will be informed about the most important information regarding the use of our cameras via a warning sticker displayed when entering our stores and all our security cameras are clearly visible. Camera footage is automatically erased after 4 weeks, unless an incident has occurred, in which case the period will be extended under strict conditions. Once the incident has been handled completely, the footage will be erased. Only a limited number of trained staff members have access to surveillance footage. Footage may be provided to the police and judicial authorities in case of incidents.

2.5 Social Media

Scotch & Soda is active on various social media channels, such as Facebook, Twitter, Pinterest, Instagram and LinkedIn.

By using social media and by following or communicating with one of our social media channels, you may already be familiar with and understand the way how we use and/or collect your personal data. You can always decide as to how and to whom these social media channels share your personal data. For example, if you follow us, mention us in one of your posts or communicate with us in any other manner, we get access to your public profile information (which includes personal data). Furthermore, depending on the choices you have made regarding your settings on various social media channels and in combination with your settings on our website(s) and app, certain personal data can be shared with us about your online activities and social media profiles, for example via Facebook Connect or Google Connect.

When you use social media, we strongly advise you to only communicate any of your personal data to us via a DM (direct message), as we have no influence on the way social media-providers handle your personal data.

Scotch & Soda tracks how many times posts and other content on social media have been viewed, shared and liked to analyse the range. Furthermore, Scotch & Soda will receive notifications about content, posts and other communication on social media channels which involve Scotch & Soda. By doing this, Scotch & Soda processes the information necessary to optimize our content on our social media channels.

Scotch & Soda is bound by the privacy principles and privacy statements of these social media, so we also encourage you to read the applicable privacy statements and other terms of use in case you use and such as well, while using any social media channel.

2.6 Customer (satisfaction) surveys

Scotch & Soda gives you the possibility to write online reviews, either via our website or via e-mail after your received a purchase confirmation. This enables Scotch & Soda to research the customer satisfaction and usability of our website(s) and app and to optimise our products and services. When you write a review, we collect the following personal data: your name and e-mail address. Please note that we always give you the option to write a review anonymously.

2.7 Business purposes

We share your personal data with third parties in the context of a corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, bankruptcy, transfer or other disposition or acquisition of all or any part of our businesses, assets or stock or similar events. Such third parties may include, for example, an acquiring entity and/or its advisors. We will only do so if permitted by applicable law or where we have a legitimate commercial interest.

3. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

The legal grounds for processing personal data (depending on the person and the circumstances) are:

3.1 Consent

If you have not purchased any product or service from us, we will not send you marketing related communications (such as newsletters, promotions, news on products or service updates) via e-mail, other electronic means, via telephone or per hardcopy mail (such as flyers), unless you have given your consent / opt-in. You can withdraw your consent at any time (please see the section 'Your Privacy Rights' below). Without your consent we are not allowed to process any personal data for other purposes than described in this Privacy Statement.

3.2 The performance of agreement

Once you have purchased a product or service from us, we need to process your personal data to send you e-mail notifications about your purchase, to deliver the product or to respond (if any) to your requests to our consumer care and to provide you with other essential information regarding our products and services.

3.3 Legitimate interests

We use your personal data on both aggregated and individual basis for the marketing of our products and services, to contact you via e-mail, social media, for interest-based advertising or other commercial purposes. We also use your personal data to create a marketing profile to analyse and improve the quality of our products and services, to analyse your interests, to personalize our advertisements and to measure and understand the effectiveness of our personalized advertisements. All these examples are based on our legitimate interests.

We also use your personal data for other legitimate commercial interests such as to operate and expand our business activities, to develop, improve or modify our products and services, to generate aggregated statistics about the users of our products and services, to facilitate our business operations, to operate company policies and procedures, to enable us to make corporate transactions, such as any merger, sale, reorganization, transfer of our assets or businesses, acquisition, bankruptcy, or similar event, intragroup restructuring or for other legitimate business purposes permitted by applicable law.

In this Section, we refer to a legitimate interest as described in article 6, paragraph 1, sub paragraph f of the EU General Data Protection Regulation. We have performed a balancing test to weigh the legitimate interests of Scotch & Soda (as described above) against your personal interests, personal rights and freedoms. Please note that the infringement of your privacy rights and freedoms is minimised because, if possible, we use pseudonyms, aggregated data and apply other principles of privacy by design. Furthermore, only a limited number of staff have access to your personal details and only when required to exercise their duties. Scotch & Soda has carefully safeguarded your personal data (please see 'How do we protect your personal data' below). Based on the balancing test performed, Scotch & Soda believes that our legitimate interests do not harm your personal rights or freedoms.

3.4 Compliance with legal obligations

Any personal data that will be used to comply with a legal obligation to which we are subject, such as personal data to be provided to supervisory bodies, fiscal authorities or investigation bodies. For example to provide camera footage to the police and judicial authorities in case of incidents.

4. HOW DO WE PROTECT YOUR PERSONAL DATA?

Scotch & Soda has taken appropriate technical and organisational measures to protect your personal data against loss or any form of unlawful processing. We protect your personal data using a wide range of security measures, including secure storage.

Our information security policy is based on industrial standard norms and includes regulations about:
  • organisation of the security of personal data (assigning responsibilities in function profiles);
  • managing company resources;
  • physical security of the premises;
  • entry control and authorisations for staff members;
  • maintenance and development of systems;
  • emergencies;
  • business continuity;
  • monitoring potential threats (external or internal);
  • monitoring information security incidents; and
  • conducting a periodic security audit of the systems.

5. RETENTION PERIODS

Scotch & Soda will only store your personal data for as long as needed for the specific purpose of the personal data. The term for which we store your personal data depends on the type of product or service, the country specific applicable law(s), the nature of the personal data and the purposes for which they have been processed. The retention period can therefore differ per purpose and country. We have an extensive Retention Policy in place, which covers all different scenarios applicable.

If we receive a request from you, as further set out under 'YOUR PRIVACY RIGHTS' below, to delete your personal details, we will honour your request, unless applicable law prohibits us to do so.

6. DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

Our basic principle is that we do not share your personal data with third parties, and that we only share your personal details with other Scotch & Soda group companies (intragroup) if needed. Within our Scotch & Soda group companies, we have safeguarded the transfer of personal data by adopting an Intragroup Data Processor Agreement (including, if applicable, EU Model Contract Clauses for the international transfer of personal data). In some cases, however, we need to share your personal data with third parties (e.g., in the context of performing an agreement, to provide our products and services, or to send out marketing related messages) such as:
  • business partners, suppliers (such as IT service providers) and subcontractors;
  • contact centres, to assist us with respect to consumer care;
  • advertising and media companies that carry out marketing and media activities on our behalf; and
  • analytics and search engine providers that assist us in the improvement and optimisation of our website(s) and app.
With all such third parties we have Data Processing Agreements in place. Some of our suppliers or third parties are based in countries outside of the European Economic Region (EER) or store their data outside of the EER. The regulations in these countries do not always offer an adequate level of data protection. A list of countries that do provide an adequate level of data protection can be found here. For that reason, we have taken additional appropriate adequate measurements to safeguard any transfer of personal data to these countries such as the EU Model Contract Clauses, approved and adopted by the European Commission.

We also provide your personal data to third parties to comply with laws and regulations or in the context of legal proceedings or a court order.

7. YOUR PRIVACY RIGHTS

You can always request Scotch & Soda for access to the personal data that Scotch & Soda has stored about you. You have the right to request:
  • access to your personal data (access);
  • change or correction of your personal data (rectification);
  • deletion of your personal data (erasure/right to be forgotten);
  • restriction of the processing of your personal data (restriction);and
  • transfer of your personal data to another controller or to yourself if we have processed your data based on your consent or based on the agreement you have entered with us (data portability).

Furthermore, you are entitled to object to the (further) processing of your personal data if we have processed your data based on our legitimate interests (objection).

If you would like to know more or would like to invoke any of your rights, please contact us at consumercare@scotch-soda.com.

8. MINORS PROVIDING PERSONAL DATA

The age threshold of minors for obtaining parental consent is established by each EU Member State and can be between 13 and 16 years. Minors are only allowed to provide personal data to Scotch & Soda if they have written consent from one of their parents or a legal guardian.

9. COMPLAINTS

  • If you have a complaint about our products or services, please contact us at: consumercare@scotch-soda.com.
  • If you have any question / complaint relating to how we process your personal data, please contact our Data Privacy Officer at dataprivacy@scotch-soda.com.
  • If you are not satisfied about we handle / process your requests or how we processes your personal data, you can contact your local Data Protection Authority. Here you find the link to the overview of your EU National Data Protection Authority.

10. CONTACT

  • The e-mail address for contacting Scotch & Soda is consumercare@scotch-soda.com.
  • Scotch & Soda's postal address is Jacobus Spijkerdreef 20, 2132 PZ, Hoofddorp, the Netherlands.
  • Scotch & Soda Group B.V. is registered in the commercial register under number 53020863, and its registered office is located at Jacobus Spijkerdreef 20, 2132 PZ, Hoofddorp, the Netherlands.
  • You can also contact Consumer Care via the telephone number as communicated on our website.

11. CALIFORNIA PRIVACY RIGHTS

11.1 Information for Customers

If you are a California resident you have the right to ask that we (1) grant you access to the personal data that we have stored about you, (2) delete the personal data that we collected from you, and (3) grant you access to a list of categories of personal data disclosed to third parties for the third parties' direct marketing purposes. We do not discriminate against California customers who exercise any of their rights described in this Privacy Statement. In certain circumstances we may not be able to honour your access or deletion request.

Please address written requests and questions about your rights to consumercare@scotch-soda.com or call us at 1-866-544-1557. Please note that, as required by law, we will require you to prove your identity. We may conduct an identity verification by telephone call or e-mail. Depending on your request, we will ask for information such as your name, the last item you have purchased from us, or the date of your last purchase. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

11.2 Information for Authorized Agents

If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of the following information to the request:
  • a completed Authorized Agent Designation Form (available upon request) indicating that you have authorization to act on the customer's behalf. We will reimburse the customer for reasonable notary costs evidenced by a receipt.
  • in case the Authorized Agent is no natural person, proof of company registration with the Secretary of State to conduct business in California.

If we do not receive both pieces of information, the request will be denied.

11.3 Information Sharing Disclosure

California requires organizations to disclose whether the following categories of personal information are collected, transferred for "valuable consideration," or transferred for an organization's "business purpose" (as those terms are defined under California law). The list below indicates the categories of personal information we collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself. In all cases, we share personal information with government entities as may be needed to comply with law or prevent illegal activity.
  • Identifiers - We may disclose this type of information to third parties for our business purposes. This may include advertising networks, affiliates or subsidiaries, business partners, data analytics providers, internet service providers, marketing partners, operating systems and platforms, other service providers, payment processors and financial institutions, professional services organizations, and social media networks.
  • Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) - We may disclose this type of information to third parties for our business purposes. This may include affiliates or subsidiaries, business partners, internet service providers, marketing partners, operating systems and platforms, and other service providers.
  • Characteristics of protected classifications – We may disclose this type of information to third parties for our business purposes. This may include operating systems and platforms, and other service providers.
  • Commercial information – We may disclose this type of information to third parties for our business purposes. This may include advertising networks, affiliates or subsidiaries, business partners, data analytics providers, internet service providers, marketing partners, operating systems and platforms, other service providers, payment processors and financial institutions, professional services organizations, and social media networks.
  • Internet or other electronic network activity information – We may disclose this type of information to third parties for our business purposes. This may include advertising networks, affiliates or subsidiaries, business partners, data analytics providers, internet service providers, marketing partners, operating systems and platforms, other service providers, payment processors and financial institutions, professional services organizations, and social media networks.
  • Geolocation data - We may disclose this type of information to third parties for our business purposes. This may include advertising networks, affiliates or subsidiaries, business partners, data analytics providers, internet service providers, marketing partners, operating systems and platforms, other service providers, payment processors and financial institutions, professional services organizations, and social media networks.
  • Audio, electronic, visual, thermal, olfactory, or similar information - We may disclose this type of information to third parties for our business purposes. This may include other service providers.
  • Professional or employment-related information - We may disclose this type of information to third parties for our business purposes. This may include other service providers.
  • Non-public education information (as defined in the Family Educational Rights and Privacy Act) - We may disclose this type of information to third parties for our business purposes. This may include other service providers.
  • Inferences drawn from any of the information listed above - We may disclose this type of information to third parties for our business purposes. This may include advertising networks, affiliates or subsidiaries, business partners, data analytics providers, internet service providers, marketing partners, operating systems and platforms, other service providers, payment processors and financial institutions, professional services organizations, and social media networks.

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