Last updated [month day, year]
COLLECTION OF YOUR INFORMATION
We may collect information about you in a variety of ways. The information we may collect on the Site includes:
Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us [when you register with the Site [or our mobile application,] or] when you choose to participate in various activities related to the Site [and our mobile application], such as online chat and message boards. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site [and our mobile application].
Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site. [If you are using our mobile application, this information may also include your device name and type, your operating system, your phone number, your country, your likes and replies to a post, and other interactions with the application and other users via server log files, as well as any other information you choose to provide.]
The Site [and our mobile application] may by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.
Data From Social Networks
User information from social networking sites, such as [Apple’s Game Center, Facebook, Google+, Instagram, Pinterest, Twitter], including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. [If you are using our mobile application, this information may also include the contact information of anyone you invite to use and/or join our mobile application.]
Mobile Device Data
Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.
Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.
Data From Contests, Giveaways, and Surveys
Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.
Mobile Application Information
If you connect using our mobile application:
- Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s [bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Data. We may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
- Push Notifications. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site [or our mobile application] to:
- Administer sweepstakes, promotions, and contests.
- Assist law enforcement and respond to subpoena.
- Compile anonymous statistical data and analysis for use internally or with third parties.
- Create and manage your account.
- Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site [and our mobile application] to you.
- Email you regarding your account or order.
- Enable user-to-user communications.
- Fulfill and manage purchases, orders, payments, and other transactions related to the Site [and our mobile application].
- Generate a personal profile about you to make future visits to the Site [and our mobile application] more personalized.
- Increase the efficiency and operation of the Site [and our mobile application].
- Monitor and analyze usage and trends to improve your experience with the Site [and our mobile application].
- Notify you of updates to the Site [and our mobile application]s.
- Offer new products, services, [mobile applications,] and/or recommendations to you.
- Perform other business activities as needed.
- Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
- Process payments and refunds.
- Request feedback and contact you about your use of the Site [and our mobile application].
- Resolve disputes and troubleshoot problems.
- Respond to product and customer service requests.
- Send you a newsletter.
- Solicit support for the Site [and our mobile application].
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
Interactions with Other Users
If you interact with other users of the Site [and our mobile application], those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.
When you post comments, contributions or other content to the Site [or our mobile applications], your posts may be viewed by all users and may be publicly distributed outside the Site [and our mobile application] in perpetuity.
We may use third-party advertising companies to serve ads when you visit the Site [or our mobile application]. These companies may use information about your visits to the Site [and our mobile application] and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.
We may share your information with our business partners to offer you certain products, services or promotions.
Our mobile application may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.]
[Social Media Contacts
If you connect to the Site [or our mobile application] through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.]
Other Third Parties
We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.
Sale or Bankruptcy
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.
Cookies and Web Beacons
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
POLICY FOR CHILDREN
We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.
CONTROLS FOR DO-NOT-TRACK FEATURES
OPTIONS REGARDING YOUR INFORMATION
You may at any time review or change the information in your account or terminate your account by:
- Logging into your account settings and updating your account
- Contacting us using the contact information provided below
Emails and Communications
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
- Noting your preferences at the time you register your account with the Site [or our mobile application].
- Logging into your account settings and updating your preferences.
- Contacting us using the contact information provided below.
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Site [or our mobile application], you have the right to request removal of unwanted data that you publicly post on the Site [or our mobile application]. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site [or our mobile application], but please be aware that the data may not be completely or comprehensively removed from our systems.
[City, State Zip]
- Privacy notice
- Privacy page
- Privacy clause
- Privacy agreement
- What information is collected
- Where information is collected from
- Why information is collected
- How information is collected (including through cookies and other tracking technologies)
- Who information is shared with or sold to
- What rights users have over their data
- The site’s contact details
Privacy policies should be clear, thorough, and easy for internet users to find on any given site.
If you target users in the European Economic Area (EEA), you’re subject to comply with the General Data Protection Regulation (GDPR).
The GDPR is one of the world’s most comprehensive privacy laws, setting international standards for appropriate data handling. Article 12 of the GDPR grants users the right to transparent information about how their data is collected and handled. For business and website owners, this means that transparent privacy policies are mandated by the GDPR.
If your website markets to children, strict rules and regulations apply. Most notably, the Children’s Online Privacy Protection Act (COPPA) governs websites that market specifically to kids.
The California Online Privacy Protection Act (CalOPPA) was the original privacy law in the US which mandated that websites make privacy policies available to users. The act also outlines what information needs to be made available regarding data handling — including what data is collected, where from, and whether it’s shared or sold.
For businesses operating in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) outlines ten fair information principles, including “openness.”
In action, complying with this principle means website operators need to make transparent privacy policies available to their users.
Other Notable Laws
If your website is “significantly engaged” in financial activities, you may be subject to the Federal Trade Commission’s (FTC) Gramm-Leach-Bliley Act, which requires the publication of “clear, conspicuous and accurate statements” regarding information collection and sharing practices.
What Information You Collect
- Personal data (like names and email addresses)
- Derivative data (like IP addresses and browser types)
- Financial data (like credit card details)
- Social network data (like Facebook login information)
- Mobile data (like mobile device IDs and manufacturers)
- Third-party data (like social network friends lists)
Both the GDPR and CCPA state that privacy policies should disclose what types of information a website collects. The above are only some basic examples of what types of information may mean for your site.
Why You Collect Information
Here are just a few examples of ways you may use the user data you collect:
- To send marketing materials or newsletters
- To process orders
- To complete transactions
- To enter users in sweepstakes, contests, or surveys
- To create and maintain user accounts
- To prevent fraudulent activities
Whether You Disclose Data to Third Parties
It’s not uncommon for a website to be integrated with other sites and services. For example, nearly 30 million live websites use Google Analytics. Given this online ecosystem, it’s only to be expected that your website might need to transfer data to third parties to operate smoothly.
- Service providers
- Ad vendors
- Social networks
- Business partners
- Other site users
|Third-Party Service Providers|
|We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.|
|With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.|
|Interactions with Other Users|
|If you interact with other users of the Site [and our mobile application], those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.|
The green text highlights the type of third party that user information could be shared with, while the blue section gives a brief explanation of how and why that information may be shared.
User Rights Over Their Data
This section of Airbnb’s policy goes on to specify four more data rights, and includes links to pages with more information on acting on those rights.
Links to Other Policies
Also gaining increasing popularity and legal necessity are cookie policies. All of these documents should link to one another, so users can always find answers to their questions about your site’s operations.
Here are some privacy statement examples from notable companies:
Not only does Twitter’s policy notice include a navigable sidebar menu, but it also highlights important words and phrases in each section as you scroll down the page.
Privacy policies for news websites are unique in that they tend to focus less on data collection and transfer for business purposes, and more on user accounts and user-to-user interactions.
It clearly states the reason data is shared with this service, by what means that data is collected, and how users can opt out of their data being shared with Google Analytics.