PRIVACY POLICY

1. Introduction and Overview.

This Privacy Policy describes how Opinionated (“Opinionated,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices about such use and sharing, and applies to your use of any online service location that posts a link to this Privacy Policy and all features, content, and other services that we own, control, and make available through such online service location (collectively, the “Service”). This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection), such as our products and services that our customers may use to collect information on their own behalf.

By using the Service, you agree to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.

If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below.

2. Information Collection.

A. Information You Provide.

We collect information you provide directly via the Service and submit to us voluntarily, such as when you contact us for any inquiry or to ask about our products and services. The information we collect may include information that identifies or could identify you (whether alone or in combination), such as your name, email address, or physical address. Do not submit any information to us that we have not requested.

B. Information Collected Automatically.

We automatically collect information about your device and how your device interacts with our Service. We may use Service Providers to collect this information. Some examples of information we collect include the following:

We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:

Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/ or other content to you on the Service and certain Third Party Services.

For further information on Tracking Technologies and your rights and choices regarding them,
see the sections entitled “Third Parties” and “Your Rights and Choices” below.

C. Information from Other Sources.

We may obtain information about you from other third party sources. To the extent we combine such third party sourced information with information we have collected about you through the Service, we will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third party sources vary over time, but have included:

For further information on Third Party Services, see the section entitled “Third Parties” below.

3. Use of Information.

We use information about you to:

We may use information that does not identify you (including information that has been deidentified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.

4. Sharing of Information.

We share information about you as follows:

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.

5. Third Parties.

A. Third Party Services.

Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). These Third Party Services may use Tracking Technologies to independently collect information about you and may solicit information from you. The information collected and stored by third parties, whether through our Service, a Third Party Service, a Third Party Feature (defined below), or a third party device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

B. Third Party Features.

We may allow you to connect our Service to a Third Party Service or offer our Service through a Third Party Service (“Third Party Features”). If you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature, and you should carefully review the third party’s privacy policy and terms of use.

C. Analytics and Interest-Based Advertising.

Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics provides, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage. We also work with ad serving services, advertisers, and other third parties to serve advertisements on the Service and/or on Third Party Services. These third parties may use Tracking Technologies on our Service and Third Party Services (including in e-mails and advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Service and Third Party Services or third party devices after you have left the Service (“Interest-based Advertising”).

We may serve ads on Third Party Services, such as Facebook and Google, which are targeted to reach people (or similar people) on those services that have visited our Service or that are also identified in one of more of our databases (“Matched Ads”). This is done by matching common factors between our data and the data of Third Party Services. If we use Facebook Custom Audiences to serve Matched Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad and find out how to opt-out. We are not responsible for such Third Party Services’ failure to comply with your opt-out instructions.

For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.

6. Your Rights and Choices.

A. Tracking Technology Choices.

Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.

B. Analytics and Interest-Based Advertising.

You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Addon.

Some of the third parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit (i) for website opt-out, http://www.aboutads.info/choices; and (ii) for mobile app opt-out, http://www.aboutads.info/appchoices. In addition, some of these third parties may be members of the Network Advertising Initiative (“NAI“). To learn more about the NAI and your opt-out options for their members, please visit http://www.networkadvertising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected 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). We are not responsible for effectiveness of, or compliance with, any thirdparties’ opt-out options or programs or the accuracy of their statements regarding their programs.

You may also limit our use of information collected from or about your mobile device for purposes of serving online behavioral advertising to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

C. Communications.

Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions.

D. Your California Privacy Rights.

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.

Opinionated may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Opinionated is not required to respond to requests made by means other than through the provided e-mail address or mail address.

Any California residents under the age of eighteen (18) who have registered to use the Service and posted content or information on the Service, can request that such information be removed from the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.

7. Children.

The Service is intended for a general audience and not directed to children under thirteen (13) years of age. Opinionated does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe Opinionated has collected such information in a manner not permitted by COPPA, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such data to the extent required by COPPA.

8. Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

9. International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy.

10. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your e-mail address.

11. Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us.